Hawaii Indicator 13 Secondary Transition Compliance

What Indicator 13 Measures

Indicator 13 is a federal accountability metric under the IDEA State Performance Plan that measures whether secondary transition planning in IEPs meets eight specific compliance requirements. It applies to students with an IEP who are age 16 or older; Hawaii begins transition planning earlier, during the school year the student turns 14.

The eight requirements check whether the IEP includes:

1. Appropriate measurable postsecondary goals in education, training, and employment
2. An independent living goal where appropriate
3. Goals that are updated annually
4. Goals based on age-appropriate transition assessments
5. Transition services that will reasonably help the student reach their postsecondary goals
6. Courses of study that align with postsecondary goals
7. Documentation that the student was invited to the IEP meeting where transition was discussed
8. Written consent to invite outside agency representatives (DVR, DOH-DDD) when appropriate

A single missing element makes the entire IEP non-compliant under Indicator 13. The score is binary for each student file reviewed: compliant or not.

Hawaii's Compliance Track Record

Hawaii's Indicator 13 compliance rates have drawn federal attention. In the 2023 Special Education Determination, HIDOE was rated as a state that "Needs Assistance" for the second consecutive year, earning zero points for secondary transition compliance. That means a substantial portion of reviewed transition IEPs did not meet the minimum federal standards.

The most common failure points are vague postsecondary goals that are not measurable, missing documentation of transition assessments, and a lack of evidence that outside agencies were invited to participate in the IEP meeting. These are not exotic requirements — they are basic documentation steps that the IEP team is supposed to complete for applicable transition-age students.

For parents, the practical consequence is straightforward: the transition plan your child's school produces may not actually comply with federal requirements. Generic goals like "the student will explore career options" or "the student will work on independent living" do not satisfy Indicator 13 unless they include specific, measurable criteria and are grounded in documented age-appropriate transition-assessment results.

How Parents Can Use Indicator 13 at the IEP Table

Understanding Indicator 13 gives parents a concrete framework for evaluating whether the school's transition planning is adequate. Before the next annual IEP review, walk through the eight requirements and check each one against the current document.

Check the postsecondary goals. Each goal should name a specific outcome and include measurable criteria. "Student will attend a community college program in culinary arts" is measurable. "Student will think about college" is not.

Ask about the transition assessment. The IEP must reference an age-appropriate transition assessment used to develop the goals and update that information annually. Interest inventories, skills assessments, and career exploration tools can all contribute, but the school needs to name the assessment or method and document the results. If the transition section references no assessment at all, the IEP is non-compliant.

Confirm agency invitations. For students age 16 and older whose goals involve employment or adult services, the school should invite representatives from the Division of Vocational Rehabilitation or the Department of Health Developmental Disabilities Division when appropriate. The school must document the required written consent before sending those invitations.

Verify the student invitation. The student must be invited to their own IEP meeting when transition is discussed. If the student cannot attend, the school must document how the student's preferences and interests were considered.

What to Do When Transition Planning Falls Short

If the IEP does not meet Indicator 13 requirements, request an IEP meeting in writing to address the gaps. Be specific: name the missing assessment, the vague goal, or the absent agency invitation. Schools respond more effectively to concrete requests than to general complaints about quality.

If the school does not correct the deficiencies after a meeting request, families can file a State Written Complaint with the HIDOE Complaints Management Program. Include the specific missing assessment, goal, or agency-invitation documentation in the complaint.

The Hawaii IEP Transition to Adulthood Guide includes an IEP meeting preparation worksheet that maps each Indicator 13 requirement to specific questions parents can bring to the table.

See more Hawaii guides →