Speech Therapy and OT in a Colorado IEP: What Parents Need to Know

Related services are the supports that make it possible for a child to benefit from their special education program — and they are legally required, not optional, when the IEP team determines they're necessary. In Colorado, speech-language therapy and occupational therapy are the two most commonly needed related services. They are also the two most commonly denied, reduced, or simply never delivered due to statewide staffing shortages.

If your child's IEP includes speech therapy or OT and those services are not happening, you have a legal basis to act.

What Makes a Related Service Required

Under IDEA and Colorado's ECEA, related services must be provided when they are necessary for a child to benefit from their special education program. The IEP team — which includes you — makes this determination. It is not the school principal's call. It is not the district's budget office's call.

Speech-language therapy is required for students with communication disorders affecting their educational performance. This includes articulation, language processing, fluency, and augmentative and alternative communication (AAC) needs. Occupational therapy addresses fine motor skills, sensory processing, self-care, and handwriting when those areas impede participation in the educational environment.

Both services must be individualized. The frequency, duration, and delivery model — whether pull-out, push-in, or consultative — must be determined based on your child's specific needs, not based on what slots happen to be available in the SLP's or OT's schedule.

How Services Get Into the IEP

Related services are added to the IEP during the development process. The PLAAFP (Present Levels of Academic Achievement and Functional Performance) identifies specific deficits, and those deficits drive the goals and services. If the PLAAFP documents that your child has significant expressive language delays affecting classroom communication, the team should then determine what speech therapy frequency is necessary to address that identified deficit.

If you believe your child needs speech or OT but those services are not included in the draft IEP, do not sign until you have asked for the team's reasoning to be documented in a Prior Written Notice. A verbal "we don't think that's necessary" is not sufficient — you are entitled to a written explanation of what the team considered and why they decided against the service. That written documentation protects you if you need to challenge the decision later.

The Staffing Shortage Problem in Colorado

Colorado is facing a severe shortage of licensed speech-language pathologists and occupational therapists, particularly in rural and mountain communities. State-level complaint decisions and news reporting have documented scenarios where students go weeks or months without receiving mandated services because a position is vacant.

The district's staffing crisis is not a legally valid reason to deny or delay your child's IEP services. Under IDEA and ECEA, the district is required to implement the IEP as written. If they cannot find a licensed SLP to fill a school-based position, the district must arrange and fund an alternative — including hiring a contracted therapist or arranging services through a neighboring BOCES. "We couldn't find anyone" does not satisfy the FAPE standard.

If services are not being delivered as written in the IEP, document it. Send an email to the special education director (not just the teacher or case manager) asking for a written explanation of how the district intends to fulfill the IEP services that have not been delivered. Keep a log of missed sessions with dates.

What Compensatory Education Means for Missed Services

When a student has been denied mandated IEP services for a sustained period, they may be entitled to compensatory education — additional services provided after the fact to make up for the denial of FAPE. Colorado State Complaint decisions have repeatedly ordered compensatory speech therapy and OT hours when districts failed to staff positions and allowed IEP services to go undelivered.

Compensatory education is not automatic — you typically need to file a State Complaint or request a due process hearing to get it ordered. But the paper trail you build by documenting missed sessions and sending written inquiries to the special education director is exactly what makes a State Complaint viable.

Requesting an IEE for Related Services

If the district's evaluation concluded that your child does not need speech therapy or OT, and you disagree with that conclusion, you have the right to request an Independent Educational Evaluation (IEE) at public expense. The IEE can include a speech-language evaluation by an independent SLP or an occupational therapy evaluation by an independent OT — professionals not employed by the district.

Upon receiving your IEE request, the district must either agree to fund the evaluation or file for due process to defend its own evaluation. It cannot simply deny the request. If the IEE finds that your child does need services the district declined to provide, that report becomes a powerful foundation for demanding an IEP revision.

Pushing Back at the IEP Meeting

When the team tries to reduce services — cutting speech from 60 to 30 minutes per week, or moving from individual to group OT — ask for the specific data driving that decision. Reductions require the same individualized analysis as initial placement decisions. If the reason for the reduction is staffing, not your child's progress data, demand a Prior Written Notice documenting the actual rationale.

The Colorado IEP & 504 Advocacy Playbook includes templates for requesting IEEs, demanding Prior Written Notice when services are reduced or denied, and filing a State Complaint when IEP services go undelivered. Access the full toolkit at /us/colorado/advocacy/.

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