IEP compliance read into every draft, before the meeting, not sampled after it
Every draft IEP read against the rule before the meeting, not a sample after it.
See one case, screen by screen ↓IEP compliance means a draft IEP contains everything 34 CFR 300.320 and the state form require: present levels, measurable annual goals, services with their frequency and location, and the dates the rule sets. IEP Compliance Review reads every draft against that rule before the meeting, with seven agents that check each other and cite every finding to its clause and page.
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IEP compliance is checked today after the meeting, not before it. A district runs one IEP meeting a year for every student with a disability, and the draft that goes into that meeting is written by a case manager with a caseload of twenty-odd students, on the state form, at night, under a clock. A compliance coordinator reads a sample of files months later, during a state monitoring cycle, when the IEP is already in force and services are already running.
The goal sentence is where it breaks. A measurable goal needs a condition, a behavior, a criterion and a timeframe, and a published review of IEP goals found a clear criterion and timeline in almost none of them — a sentence can be grammatically complete and still tell nobody how well, how often or by when. Nothing joins the pages either: a need named in the present levels on one page, a goal on the next, a service two pages after that, so a need with no goal is invisible to a check that only looks at one field at a time. Written state complaints reached 9,927 in school year 2023-24, 79% above the ten-year mean, and only 81% were resolved inside the 60-day clock, down from 92% a decade earlier.
Estimated split for one draft IEP review, against the district's own timed file review.
Seven agents read every draft and check each other; a case manager decides and a coordinator signs.
Marlow Bay Unified School District — 48,000 students, 62 schools, 6,720 students with IEPs. Mateo R., grade 4, Saltmeadow Elementary, uploads draft v3 for his June 11 annual review. Here is what happens next, screen by screen, in the working solution.
Renata Alvarez uploads draft v3. Seven agents read it in 2 minutes 40 seconds and raise 8 findings. Goal 1 — "When given fourth-grade text, Mateo will improve his reading" — is parsed into Condition, Behavior, Criterion and Timeframe chips, and the last two sit dashed and empty inside the sentence itself. The required-content column on the right lists the 14 items 34 CFR 300.320 and the state form ask for, each with the page it was read from, and the clock strip on top shows the meeting on June 11 and the family's notice due June 1 — 20 days, not sent.
"The condition and the behavior are on the page. There is no criterion, so nothing says how well or how often, and no timeframe, so nothing says by when." — Measurability agent
Goal 1 has no criterion and no timeframe (Measurability agent, 96%, page 5). Written expression is named as a need with no goal and no service (Alignment agent, 91%, page 4). Goal 3 may serve no documented need (contested, page 5). Progress reporting says "periodically" with no frequency stated (Content agent, 94%, page 8). Extended time is in the service grid but not on the assessment page (Consistency agent, 89%, page 7). The speech-language service has no location (Content agent, 97%, page 6). The language-needs special factor is unanswered (Content agent, 93%, page 2). Progress report 3, due April 17, is not on file (Clock agent, 99%).
Nothing is asserted without a source: every finding names the agent, its confidence and the page.
The finding opens on 34 CFR 300.320(a)(2) and the sentence read from page 5, then a proposed replacement: "Given a grade-4 passage, Mateo will read 95 words correct per minute with 95% accuracy on 3 of 4 weekly probes by June 11, 2027." Under it, the arithmetic: a baseline of 62 words correct per minute at 91% accuracy on April 21, 2026, a district grade-4 benchmark of 112, and 95 as 33 words above the baseline — about one word a week across the 33 instructional weeks of this IEP year.
No goal library knows that this student reads 62 words a minute. The proposal is built from the page, and cites it.
Following the finding's citation back to page 3: "On the district's spring grade-4 curriculum-based measure, given April 21, 2026, Mateo read 62 words correct per minute with 91% accuracy on a grade-4 passage. The district grade-4 benchmark is 112 words correct per minute." The sentence the agent used highlights in the document while the proposal stays beside it.
Every value is one click from the sentence it came from, in the draft itself.
The Alignment agent traces every need in the present levels forward to a goal and a service. Written expression reaches neither: page 4 records 14 correct word sequences in a 3-minute probe against a grade-4 expectation of 32, and that Mateo leaves 4 of 5 independent writing assignments unfinished. The agent proposes a written-expression goal built from that number, or a recorded reason for leaving the need without one.
A need with no goal is the finding state monitoring writes most often, and no field-level check can see it.
Renata rejects the finding that the speech-language service has no location, choosing from the district's reason codes — not applicable, already addressed, team decision at the meeting, deferred to the meeting — and leaving the note "The location is on the service grid on page 6, line 3." Both the decision and the reason go on the audit trail.
The person can disagree with the agents, and the record says why.
Goal 3 — "Given a visual checklist, Mateo will begin an independent written task within 2 minutes of the direction, on 4 of 5 days, by June 11, 2027" — is passed by the Measurability agent at 88%: all four parts are in the sentence. The Alignment agent fails it at 84%: the need on page 4 is written production, and this goal measures the start of a task. Compliance coordinator Dana Whitcombe decides which agent is right, or sends the question to the meeting; both positions stay on the record.
The case manager cannot accept a contested finding — only the compliance coordinator can resolve it.
Dana's queue is ordered by notice date: seven drafts waiting, Mateo's at the top with 5 open findings and a notice due June 1. She sees what Renata decided — Goal 1 accepted, the written-expression finding accepted, Goal 3 contested, the service-location finding rejected — agrees with the Alignment agent on Goal 3, asks the team to add a written-expression goal, and signs. The person who decided cannot sign their own draft.
"The meeting notice is held until a second named person signs."
Across 62 schools, 147 drafts are in review this week and 22 are waiting for a second read. Each row carries the meeting date, the notice date with days remaining, the findings count and the stage — Aiden T.'s notice is a day late and escalated, Sofia M.'s is due today, and Priya N.'s draft could not be read because the upload was a scan with no text layer.
The clock that actually matters — the family's notice — drives the order.
38 meeting notices due inside 10 days, 214 annual reviews due inside 30 days, 96 reevaluations due inside 60 days and 7 escalations, each row naming the student, the school, the clock, the days left and the owner. Escalation triggers at 5 school days with an open finding, and the threshold is a setting.
One place, instead of the IEP system, a spreadsheet, a calendar and a case manager's head.
A plain-language summary of what the draft proposes for Mateo, in Spanish, with the English original line by line beside it: that he reads 62 words correct per minute against a benchmark of 112, that the team proposes 95 words correct per minute with 95% accuracy by June 11, 2027, and that the meeting notice goes out before June 1, 2026. A person approves every line before anything is sent.
The IEP itself is not required to be translated — but the notice is, and a person reads it first.
Every read, finding, decision, reason code and signature on Mateo's draft, with the agent, model and rule-set version that produced it — assembled into the pack a state monitor, a complaint investigator or a hearing officer would ask for: the draft in every version, each finding with its clause and page, both positions on the contested finding, the second read and the signature. Other students are redacted, and the export is itself recorded.
What used to be rebuilt by hand is assembled from the record.
The same draft, seen by the four people who carry it — their day before, and their day now.
Seven agents read every draft and check each other; a case manager decides and a coordinator signs.
Tests every required item of 34 CFR 300.320 and the state form against the draft, and records the page each one was read from.
Parses every annual goal into condition, behavior, criterion and timeframe, and proposes a replacement built from the present levels, with its arithmetic.
Traces every need named in the present levels to a goal and a service, and every goal and service back to a need.
Computes the annual review, reevaluation, meeting-notice and progress-report clocks, and raises what is near or late.
Checks the same fact across pages — names, dates, minutes and accommodations — and shows both passages when they disagree.
Drafts the family's plain-language copy in the home language, beside the English original.
Assembles the evidence pack and records the agent, model and rule-set version behind every statement.
Decide with a reason, and sign. The agents propose; a named person decides.
Ask about a goal, a student, a clock or a rule — or tell the assistant what to change. Every answer points to its source.
Why is Goal 1 a finding?
Goal 1 reads "When given fourth-grade text, Mateo will improve his reading." The condition and the behavior are there. There is no criterion — nothing says how well or how often — and no timeframe, so nothing says by when. 34 CFR 300.320(a)(2) asks for a measurable annual goal. A replacement was drafted from the present levels on page 3, where his rate is 62 words correct per minute against a district benchmark of 112.
Which notices will be late?
Four students across the schools: Aiden T. (notice was due yesterday), Sofia M. (due today), Priya N. (4 days, and her draft could not be read) and Noah W. (5 days, with a contested finding). All four are escalated to the compliance coordinator. District-wide that is 7 of the 38 notices due inside 10 days.
What are the agents arguing about?
Goal 3 for Mateo. The Measurability agent passes it at 88%: condition, behavior, criterion and timeframe are all in the sentence. The Alignment agent fails it at 84%: the need on page 4 is written production — 14 correct word sequences against an expectation of 32 — and this goal measures the start of a task, not the writing. Nobody picks a winner; it is marked contested and goes to the compliance coordinator.
What would the state see if they asked for Mateo's file today?
One pack, in the order a reviewer reads it: every version of the draft, every finding with its clause, page and passage, every decision with its reason code, both positions on the contested finding, the second read and its signature, the clocks and what went to the family, and the agent, model and rule-set version behind each statement. Other students are redacted, and the export itself is recorded.
13 screens from the working solution, on its sample data. Pick one to see it large.
The rule set, the clocks and the thresholds a draft is checked against are settings, versioned and on the audit trail.
| Setting | Default | Choose from |
|---|---|---|
| Rule set | 34 CFR 300 (2016 revision) · state manual rev. 2026-01 · state form SE-11 | Pinned by rule-set version; a change re-runs open drafts |
| Meeting notice lead time | 10 days before the meeting | District procedure; IDEA requires only "early enough" |
| Review SLA | Agents review within 1 school day; second read within 2 school days | Always before the notice date |
| Escalation | Notice inside 5 school days with an open finding | Routes to the compliance coordinator and the program specialist |
| Confidence threshold | 75% | Findings below the threshold route to the coordinator, not the case manager |
| Second-read rule | Every draft with an open finding, plus a 10% sample of clean drafts | Configurable sample rate |
| Contested findings | Always a person — never auto-resolved | Compliance coordinator or above |
| Reason codes | Accepted · Rejected — not applicable · Rejected — already addressed · Rejected — team decision at the meeting · Deferred to the meeting | A director can add a reason code |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
"demo" = seen in the working solution, on its sample draft · "target" = the design goal, measured in the live solution · "typical" = published figures (OSEP dispute-resolution data via CADRE, SY 2023-24; AASA, Rethinking Special Education Due Process) · 34 CFR 300.320, 300.303, 300.322, 300.324. People, students and the school district named on this page are fictional — characters and sample data in the working solution.
IEP compliance means a draft IEP contains everything 34 CFR 300.320 and the state form require: present levels, measurable annual goals, services with their frequency and location, and the dates the rule sets. IEP Compliance Review reads every draft against that rule before the meeting, with seven agents that check each other and cite every finding to its clause and page.
The 14 required items: present levels, measurable annual goals, how progress is measured and reported, special education and related services, program modifications, the extent of non-participation with peers, assessment accommodations, and — from age 16 — transition services. The Content agent tests each one against the draft and records the page it read it from.
The Measurability agent parses every annual goal into its four required parts — condition, behavior, criterion and timeframe — and shows a missing part as a dashed, empty chip inside the sentence itself. Where a part is missing, it proposes a replacement built from the student's own present levels, with the arithmetic shown and cited to the page.
The Alignment agent traces every need named in the present levels forward to a goal and a service. A need that reaches neither is a finding — the one state monitoring writes most often, and the one a field-level check cannot see because the need and the goal sit on different pages.
The Clock agent recomputes every clock nightly and after each new draft version — the annual review, the reevaluation, the meeting notice and the progress-report dates — and raises what is near, late or at risk, with an owner named on every row.
No. Every draft with an open finding is still read by a named compliance coordinator before the meeting notice is released, and the person who made the first decision cannot sign their own draft. When two agents disagree, the finding is marked contested and only a person resolves it.
No. Accepted findings go back to the IEP system as tracked suggestions only, never an automatic edit and never a second record. No agent sends a notice, decides eligibility, or resolves a contested finding.
The Agentic Solution Engine builds and deploys it from your rule set, your state form and a sample of your own draft IEPs, and it goes live once every quality gate has passed. We will walk you through it on your own drafts first.
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1-min demoWe'll run IEP Compliance Review on a sample of your own draft IEPs before the next meeting cycle.