Delaware IEP Present Levels (PLAAFP): What Parents Need to Know

The Present Levels of Academic Achievement and Functional Performance section — commonly called the PLAAFP — is the most important two pages in your child's IEP. Everything else in the document flows from it: the annual goals, the related services, the accommodations, the placement. If the PLAAFP is vague, outdated, or inaccurate, every goal built on top of it is legally suspect. Delaware parents report this as one of the most frequent sources of IEP disputes: not the goals themselves, but the baseline data underneath them.

What the PLAAFP Is Required to Include

Under 14 DE Admin. Code 925, Delaware mandates that the IEP's present levels describe how the child's disability affects their involvement and progress in the general education curriculum. For preschool children, this means participation in age-appropriate activities. For school-age students, it must address academic performance and functional skills.

A legally compliant PLAAFP in Delaware must:

• State the child's current performance in measurable terms — not impressions, but data points
• Describe the impact of the disability on participation in general education
• Reflect information from multiple sources: standardized assessments, classroom-based measures, teacher observations, and parent input
• Be specific enough that a new teacher who has never met the child could understand exactly where the child stands

The DDOE's current IEP Initiative, a four-phase statewide framework for data-based decision-making, specifically requires that present levels be grounded in assessment data that ties directly to grade-level or standards-based expectations. This is not optional administrative guidance — it is the framework Delaware trains its IEP teams with.

Why Vague PLAAFPs Are So Common — and So Damaging

Delaware's special education population has grown 41 percent over the last decade, against only a 7 percent increase in overall enrollment. Roughly 26,941 students currently receive special education services. In larger districts like Christina, Red Clay, and Colonial, that volume creates real pressure on special education staff to reuse language across IEPs rather than build each one from scratch.

The result: PLAAFPs that read like templates. Phrases like "Johnny struggles with reading fluency" or "Maria has difficulty focusing in class" appear across dozens of IEPs in the same district. These statements describe a general impression, not a measurable baseline. They make it impossible to write a meaningful, measurable annual goal — and they make it impossible to later determine whether the child made progress.

A weak PLAAFP damages the IEP in several concrete ways:

Goals become unmeasurable. If you cannot state where the child currently is with precision, you cannot write a goal that meaningfully measures growth from that point.

Progress reports become meaningless. Delaware requires schools to report on progress toward IEP goals at least as often as they report to parents of non-disabled students. If there is no baseline, the progress report has nothing to measure against.

Placement decisions lose their foundation. The Least Restrictive Environment determination is supposed to flow from the student's current needs as described in the PLAAFP. Without specific data, districts make LRE decisions that are harder to challenge.

What Good PLAAFP Data Looks Like

Strong Delaware PLAAFPs cite specific assessment scores with dates: "As of March 2026, student scored at the 12th percentile on the GORT-5 oral reading fluency measure, reading at a 2.1 grade equivalent. Teacher observation indicates the student loses place in text approximately twice per page when reading silently." That is a baseline. It is tied to an instrument, a date, and observable behavior.

Sources of data that should appear in a Delaware PLAAFP include:

• Results from the initial psychoeducational evaluation or triennial reevaluation (with scores, not just narrative summaries)
• DIBELS, AIMSweb, or other curriculum-based measurement data from the classroom
• STAR, Renaissance Learning, or similar progress monitoring data
• Results from the Delaware State Assessment (DCAS) where applicable
• Occupational therapy, speech, or physical therapy assessments if related services are involved
• Parent input — Delaware regulations specifically require the IEP team to consider parental concerns about enhancing the education of their child

How to Push Back When the PLAAFP Is Inadequate

If you review your child's draft IEP and find the PLAAFP is vague, generic, or missing data, you have several options — all of them backed by Delaware law.

Request the underlying assessment data before the meeting. Under 14 DE Admin. Code 926 and Delaware's procedural safeguards, you have the right to review all education records. Request the Evaluation Summary Report (ESR) and any recent progress monitoring data at least five business days before the IEP meeting. Do this in writing.

Write your own parent input statement. Delaware regulations require the IEP team to consider parent concerns as part of the present levels. Submit a written statement describing what you observe at home: how long your child can sustain attention on homework, the reading level of materials they can access independently, behaviors that impair daily functioning. Attach it to the IEP as a formal document.

Request an amendment if the present levels are inadequate after the IEP is finalized. Under Delaware law, the IEP can be amended without convening a full meeting if the parent and district agree in writing. If you believe the PLAAFP is materially deficient, put your concerns in a letter citing 14 DE Admin. Code 925 and request either an amendment or a full IEP meeting.

Request an Independent Educational Evaluation (IEE). If you disagree with the district's assessment data entirely — not just the write-up, but the evaluation itself — you have the right under 14 DE Admin. Code 926 to request an IEE at public expense. The district must either fund it or file for due process to defend its evaluation.

The Delaware IEP & 504 Blueprint includes a PLAAFP review checklist with the specific questions to ask at your child's IEP meeting — including what to document if the district's present levels cannot be traced back to measurable data.

The PLAAFP's Role in Delaware's One-Tier System

Delaware uses a one-tier due process system. If a dispute reaches a hearing, the decision from that panel is final at the administrative level. There is no state-level review board. The only appeal is to federal or state court, which is expensive and slow.

This makes the PLAAFP critical as a pre-dispute document. In due process hearings, hearing panels examine whether the IEP was reasonably calculated to provide meaningful educational benefit — and that determination starts with whether the present levels accurately described the child's needs. A poorly documented PLAAFP is one of the most common ways districts lose Delaware due process cases.

Building a strong PLAAFP is not adversarial. It is the foundation of a legally sound IEP. If your child's present levels are vague, the time to fix them is before the IEP is signed — not after a dispute has already escalated.

What to Do Right Now

Before your child's next IEP meeting, request the draft IEP at least five days in advance. Open to the present levels section. Ask: Can I trace each annual goal directly back to a specific, dated, measurable data point in this PLAAFP? If the answer is no for any goal, that is the first issue to raise at the meeting.

The Delaware IEP & 504 Blueprint walks you through exactly how to read a Delaware PLAAFP, what questions to ask, and how to request corrections — without needing to hire a private advocate to do it for you.

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