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Early On Michigan Transition to IEP: The Timeline Every Parent Must Know Before Age 3

Early On Michigan Transition to IEP: The Timeline Every Parent Must Know Before Age 3

If your child is currently receiving services through Michigan's Early On program, a hard legal deadline is approaching — and most parents don't know exactly when it hits or what has to happen by then. The transition from Part C early intervention services to Part B school-based special education is one of the most procedurally dense moments in the entire special education system. When it goes right, your child receives a full IEP with services in place on their third birthday. When it goes wrong — because a district missed a notification, skipped a required meeting, or didn't complete the evaluation in time — your child can fall through a gap in services at the most developmentally critical window of their life.

What Early On Is and What It Covers

Michigan's Early On program provides early intervention services to infants and toddlers from birth to age 3 who have a developmental delay or a condition with a high probability of resulting in a developmental delay. Services are delivered through an Individualized Family Service Plan (IFSP), not an IEP. The IFSP is family-centered — it addresses both the child's developmental needs and the family's capacity to support those needs.

Early On services are governed by IDEA Part C. Once a child turns 3, Part C services end and the child either transitions to Part B services (school-based special education under an IEP) or to general education with no special education services if they do not qualify.

This transition is not automatic. It requires a new evaluation, an eligibility determination, and, if eligible, a fully developed IEP — all completed before the child's third birthday.

The Legal Timeline: What Must Happen and When

MARSE and the Michigan Alliance for Families' transition timeline documents establish the following required sequence. Every date is tied to the child's third birthday, which is referred to as "B-3" in transition planning language.

Between 2 years 3 months and 2 years 9 months (27 months to 33 months of age): Transition planning must begin. The Early On service coordinator is responsible for initiating this process. If your child is in this age window and no one has discussed transition with you, contact your Early On service coordinator immediately.

No later than 2 years 9 months (33 months of age): The local school district must be notified that a child receiving Early On services will be turning 3 and may need Part B services. This notification triggers the local educational agency's (LEA's) obligations. A transition conference must be convened before the child reaches 33 months. This meeting brings together the Early On team and the local school district to discuss the process, the timeline, and what the family can expect.

Written consent for evaluation: Once parents provide written consent to the school district for an initial special education evaluation, the district's 30-school-day evaluation clock begins. Under MARSE, the district has 30 school days from the date of consent to complete the comprehensive evaluation, convene the IEP team, and issue an offer of FAPE.

No later than the child's third birthday: The initial IEP must be fully implemented and services must begin. "Implemented" means services are actively being delivered, not just written in a document. Michigan law allows a maximum of 15 school days from parental consent to service implementation after the IEP is offered. If the third birthday falls during summer, the district must determine a specific start date for services that ensures FAPE begins on or before the birthday.

What Frequently Goes Wrong

Several specific failure patterns appear repeatedly in Michigan transition cases.

Late notification. The school district doesn't receive timely notification from the Early On program because the service coordinator dropped the ball or there was a miscommunication between agencies. The clock starts late, the evaluation is rushed, and the IEP isn't ready on the birthday.

"Wait and see" evaluations. Some districts discourage parents from consenting to evaluations early, suggesting that the child might not need services and should be re-evaluated after starting preschool. This is not illegal in every case, but it can result in a child with documented developmental delays sitting without services while the district waits to see if they "catch up." If your child has a current IFSP and documented delays, you have every right to request an immediate evaluation.

Eligibility criteria mismatch. A child may qualify for Early On services under a different standard than the MARSE eligibility criteria for Part B. Early On uses developmental delay as a category. MARSE Part B has 13 specific eligibility categories with their own criteria. A child may have qualified for Early On but not meet the stricter MARSE thresholds for the equivalent Part B category. This transition evaluation is where many families first encounter a denial, and parents need to know they can request an IEE if they disagree with the MET findings.

Third birthday in summer. If a child turns 3 during the summer when school is not in session, the 30-school-day timeline must still be completed before the birthday. This means consent must be provided and the evaluation must be completed during the preceding school year. Parents who consent to evaluation in May or June of the year their child turns 3 in July must be aware that the 30-school-day window needs to be calculated with summer recess excluded — and that the IEP needs to be ready before summer ends.

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What to Do If You're in the Transition Window

If your child is receiving Early On services and is between the ages of 2 years 3 months and 3 years, take these steps now:

Verify the notification timeline. Ask your Early On service coordinator when they plan to notify the local school district and when the transition conference will be scheduled. If these haven't happened and your child is past 27 months, follow up in writing.

Request the evaluation in writing. When you're ready to consent to the evaluation, submit written consent to the school district's special education director — not just verbally to the Early On coordinator. This starts the district's legal clock.

Prepare for the eligibility determination. Review your child's current IFSP and any Early On evaluation reports before the MET meets. The MET may use different assessment tools and apply different eligibility criteria. If your child's IFSP documents progress but the MET finds them ineligible for Part B, that is not necessarily accurate — ask for specific data that supports the "no longer meets criteria" determination and consider requesting an IEE.

Document everything. Keep copies of every evaluation, every transition conference note, every written communication with the school district. Transition is a common moment for procedural violations, and your paper trail from this period is the foundation for any future advocacy.

If your child turns 3 and services have not been implemented — whether because of a district delay, a missed timeline, or a disputed eligibility determination — this is a potential FAPE violation. The Michigan IEP & 504 Advocacy Playbook covers how to document these violations and what formal steps are available when the transition process breaks down.

After the Third Birthday: What Changes

Once your child transitions to Part B services, the IFSP is replaced by an IEP. The IEP team structure, meeting requirements, and procedural safeguards shift from Part C's family-centered framework to IDEA Part B's student-focused framework. The family's role changes from co-author of the service plan to member of the IEP team.

Importantly, Michigan's MARSE extends Part B services through age 26 — well beyond the federal floor of age 21. This extended eligibility is a significant state-specific protection that Michigan families should know they have, and it applies to students who remain eligible for special education services and haven't received a standard high school diploma.

The transition from Early On to the IEP system is your first major advocacy moment. How that initial IEP is written — what goals are set, what services are included, what placement is determined — will influence your child's educational trajectory for years. Going in informed and prepared is not optional.

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