DC Early Intervention Transition: Moving from IFSP to IEP Before Age 3

The months between a child's second and third birthday are among the most anxiety-producing in early childhood special education. Your child is receiving services under an Individualized Family Service Plan (IFSP) through DC's Strong Start early intervention program. In a matter of months, that system ends and a new one—DCPS's Part B preschool special education—begins. What gets lost in the handoff, and how to prevent it.

The Two Systems and What Separates Them

Part C (early intervention): For infants and toddlers from birth to age three with developmental delays or conditions likely to cause delays. In DC, this is managed by OSSE's Strong Start program. Services are delivered through an IFSP—a family-centered plan that addresses the child's development in the context of the whole family. Strong Start providers may include speech-language pathologists, occupational therapists, physical therapists, and developmental specialists.

Part B (preschool special education): Once a child turns three, responsibility shifts to the Local Education Agency—DCPS for most families, or the charter school the child is enrolled in. The legal document becomes an IEP, not an IFSP. Services focus on educational goals rather than family-centered outcomes. The child enters the school system.

These are two legally distinct systems with different eligibility criteria, different service delivery models, and different bureaucracies. A child who qualifies under Part C does not automatically qualify under Part B—a separate evaluation and eligibility determination is required.

DC's Transition Conference Rule: Age 2 Years, 9 Months

Under DC's Early Childhood Transition Guidelines, when your child reaches 2 years and 9 months of age (which is three months before the third birthday), Strong Start is required to coordinate a transition conference with the appropriate LEA. The purpose of this conference is to:

• Review the child's current IFSP
• Discuss the differences between Part C and Part B services
• Begin planning for the Part B evaluation
• Identify which LEA will be responsible (DCPS Early Stages for most families not already enrolled in a charter; the charter LEA for children already enrolled there)

If Strong Start has not initiated this conference by the time your child is 2 years and 9 months, contact your service coordinator immediately and request the transition meeting in writing. Do not wait for them to reach out—the timeline is strict and the consequences of missing it can delay your child's entry into Part B services by weeks or months.

The DCPS Early Stages Program

For children ages 2 years 8 months to 5 years 10 months who are enrolled in DCPS, are enrolled in private child care centers in the District, or are DC residents not yet enrolled in any school, DCPS's Early Stages program operates as the centralized Part B evaluation hub.

Early Stages conducts the comprehensive evaluation to determine whether the child is eligible for Part B services. The evaluation may include:

• Psychological assessment
• Speech-language evaluation
• Occupational and physical therapy assessments
• Developmental screening
• Review of existing IFSP data and provider reports

Once parental consent is signed for the Part B evaluation, the 60-day evaluation completion timeline applies—the same timeline that governs all DCPS evaluations under DC regulations.

For children already enrolled in a charter school, the charter LEA is responsible for conducting its own Part B evaluation—not Early Stages. This is a point of confusion for many families: if your three-year-old is attending a charter school's preschool program and shows developmental concerns, the charter is responsible for the Child Find evaluation, not DCPS.

IFSP to IEP: The Critical Differences

Parents who are accustomed to the IFSP model frequently experience the transition to an IEP as a shift in focus from the whole family to the child alone. Some specific differences to understand:

The transition also changes the nature of parent rights. Under Part B, parents gain the full IDEA procedural safeguards: the right to request independent evaluations, the right to dispute placement and services through OSSE's Office of Dispute Resolution, and the right to Prior Written Notice for any proposed changes.

What Parents Should Do Six Months Before the Third Birthday

Four months before the third birthday: If you have not been contacted about a transition conference, call your Strong Start service coordinator and request one in writing. Include your child's date of birth and confirm which LEA will handle the Part B evaluation.

Three months before the third birthday: The transition conference should have occurred. Ensure the Part B evaluation referral has been made. If you are transitioning to DCPS Early Stages, confirm the referral has been transmitted and request written confirmation of when the 60-day evaluation clock begins.

Six weeks before the third birthday: Check the status of the evaluation. If it has not been completed, it needs to be done before or on the third birthday to ensure there is no gap in services. A Part B IEP must be in place and ready to implement on the child's third birthday if the evaluation confirms eligibility.

On or before the third birthday: The IEP must be in effect by the third birthday for a child found eligible under Part B. If the evaluation was completed but the IEP meeting has not happened, escalate immediately—this is a compliance failure.

When Services Gap Between Part C and Part B

Despite these requirements, service gaps are common. Strong Start ends; Part B has not yet begun. The child goes without speech therapy or OT for weeks while paperwork moves through systems.

If this happens, document every missed session. The gap in services—if caused by the LEA's failure to timely complete the evaluation or convene the IEP meeting—may constitute a denial of FAPE and give rise to compensatory education. Under DC's Reid standard, compensatory education is designed to put the student in the position they would have been in but for the denial. Missed early intervention services are recoverable.

An OSSE State Complaint is the most efficient remedy for a Part C to Part B transition failure: it is free, resolves in 60 days, and OSSE can order immediate service delivery and compensatory make-up sessions.

Part B Preschool Programs in DCPS

Once an IEP is in place, DCPS Early Stages refers the child to the appropriate preschool program. Options include:

• DCPS school-based preschool classrooms: Self-contained or integrated preschool programs at neighborhood DCPS elementary schools.
• Community-based preschool partners: DCPS contracts with community-based organizations to provide Part B services in settings closer to the child's home.
• Head Start programs with Part B coordination: Some families receive Part B services through coordinated agreements between DCPS and Head Start providers.

Parents have the right to participate in the placement decision. LRE applies to preschool placements: the goal is to educate the child in settings with non-disabled peers to the maximum extent appropriate. A proposal to place your three-year-old in a fully self-contained program must be justified by data showing that less restrictive options with appropriate supports cannot meet the child's needs.

For a complete guide to navigating the DC special education system—including the transition from early intervention, eligibility categories, and the IEP process from start to dispute resolution—the District of Columbia IEP & 504 Advocacy Playbook covers each step with DC-specific templates and regulatory citations.

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