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If you’re an IEP team member, you already know that IEP goals drive everything to help students with disabilities. The U.S. Supreme Court’s ruling in Endrew vs. Douglas County School District (2017) stated that IEP goals must be “appropriately ambitious.” Now, IEP teams may be wondering how to ensure compliant goals in light of this new legal standard.

The Individuals with Disabilities Education Act (IDEA) requires states to provide a free appropriate public education (FAPE) for all students with disabilities. In order to comply with the FAPE requirement, Individualized Education Program (IEP) goals must be established for every child covered by IDEA.

Let’s take a closer look at the Endrew decision and what it means for IEP teams, parents and students.

What Was the Endrew Case About?

Endrew, a student with autism, attended public school from kindergarten through fourth grade in the Douglas County School District in Colorado.

  • Endrew’s parents rejected the district’s proposed IEP goals for fifth grade, because their son wasn’t making adequate progress while his IEP goals remained essentially unchanged from year to year.
  • They enrolled Endrew in a private school which specializes in serving students with autism, where he exhibited significant improvement.
  • Endrew’s parents sought reimbursement for the private school tuition from the district, which rejected their request.
  • Their appeal was also rejected by the Tenth Circuit Court of Appeals, which ruled that districts are only required to provide a “de minimis” or minimal educational benefit to students with disabilities. The parents then appealed to the U.S. Supreme Court, which accepted the case.

In an 8-0 opinion written by Chief Justice John Roberts, the court overturned the Tenth Circuit decision. The justices rejected the “de minimis” standard and ruled that every child must have the chance to meet “challenging objectives” that are “appropriately ambitious in light of his circumstances, just as advancement from grade to grade is appropriately ambitious for most children in the regular classroom.”

The ruling changed the precedent set by the 1982 case Board of Education of Hendrick Hudson Central School District v. Rowley, in which the Court ruled that IEP goals merely have to be “reasonably calculated to enable the child to receive educational benefits.” This new ruling strengthened the concept of FAPE for students with disabilities.

What Does “Appropriately Ambitious” Mean?

The court acknowledged that there is no one-size-fits-all approach for providing an appropriate education for children with different abilities and needs.

The U.S. Department of Education points out that IEP goals should enable children to make progress in their school’s general education curriculum whenever possible. While grade advancement may be “appropriately ambitious” for most students, a different standard may be required for those with more severe impairments.

In post-Endrew cases, courts and parents alike will be paying close attention to two primary issues:

  • Whether IEP goals are appropriately ambitious in light of a child’s individual circumstances
  • Whether the child is making progress on his or her IEP goals

How Can You Implement “Appropriately Ambitious” IEP Goals?

IEP teams must demonstrate that goals are “appropriately ambitious,” as well as challenging, attainable and measurable. The student must also demonstrate academic and functional progress.

Developing Attainable, Ambitious IEP Goals

Appropriately ambitious and attainable IEP goals enable the student to access instruction and other services. Interventions must be aligned with state academic standards and written in light of the child’s circumstances. In order to set legally compliant goals, IEP teams must:

  • Set evidence-based annual goals that include both academic and functional outcomes
  • Determine specific procedures for measuring and reporting the child’s progress

Demonstrating Progress on IEP Goals

Even the best-written IEP goals accomplish nothing if the student fails to make progress once they are implemented.

Therefore, IEP teams must demonstrate the following indicators of progress:

  • The child is receiving all special education, supplementary aids, and related services outlined in the IEP
  • The IEP team is making appropriate modifications as required
  • School personnel receive the supports and professional development they need
  • Appropriate accommodations are provided

Measurable IEP goals enable a clear assessment of whether the child is making adequate progress. Determining “acceptable” progress is based on the child’s level of achievement at the beginning of the year, the nature and severity of the disability and the child’s potential for future growth.

The SMARTER Steps program, developed by special education experts Kelly Ott and Lara Wakefield, uses a clear, seven-step process that simplifies the IEP goal writing process for all stakeholders, by setting attainable, ambitious goals and putting them into action.

  • Specific
  • Measurable
  • Attainable
  • Research/Evidence-based
  • Teachable
  • Evaluation
  • Relevant to general education, curriculum, alternative curriculum, and/or transitional goals

SMARTER Steps provides IEP teams with an evidence-based road map to meet the new standard in the Endrew decision.  This process helps IEP teams create compliant goals that are ambitious, measurable, and tailored to the specific needs of the student. SMARTER Steps inspires IEP teams to achieve optimal outcomes.  

Would you like more information on SMARTER Steps? Do you have questions about how the Endrew decision might affect your child or students? Contact us to learn more.

S.M.A.R.T.E.R. Steps is a consulting business developed for special education staff and parents of children with special needs ages birth to 21. This organization is designed to assist special education teams on how they can achieve federal and state compliance while empowering self-advocacy skills throughout development and implementation of Individual Education Programs (IEP’s).  We are focused on simplifying the process and procedures so that you can spend more time where it matters most—with your students!

S.M.A.R.T.E.R. Steps provides consulting, live and recorded tutorials, professional education and parent resources, and information for each step of the IEP process. These educational resources reveal for parents and professionals how easily they can achieve compliance while creating quality personalized learning programs. When teams work collaboratively toward building comprehensive educational plans, the student outcomes are much more successful.

Kelly Ott, MEd, MHS, CCC-SLP  and Lara Wakefield, PhD, CCC-SLP
S.M.A.R.T.E.R. Steps resources and support services on TPT and at smartersteps.com



“How to Save Time and Develop Legally Compliant IEP Goals” is the overview webinar of the SMARTER Steps system.  Learn this easy 7-step prompting system to gain a solid foundation on how to develop goals for optimal outcomes for children with IEPs. This webinar is for everyone: parents, advocates, school staff, administrators, college students, and university instructors.  This webinar is 1 hour and 30 minutes in length and was recorded on 5-21-18. This is an example of our SMARTER series recorded webinars available through our membership program.

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