Maryland IEP Annual Review: What Happens and How to Prepare

The IEP annual review is the most important meeting in your child's school year. It is where goals are set or revised, services are continued or changed, and placement decisions are made. If you show up unprepared, the meeting is likely to be a formality that rubber-stamps whatever the school has already decided. If you prepare strategically, it is your most powerful opportunity to meaningfully shape your child's education.

Here is what actually happens at a Maryland IEP annual review, what your rights are, and what preparation looks like when you take it seriously.

What the Annual Review Is and When It Must Occur

Under IDEA and COMAR 13A.05.01.09, an IEP must be reviewed and, as appropriate, revised at least once every 12 months. This is the annual review meeting.

The 12-month timeline is not a suggestion. It is a hard deadline. If your child's IEP anniversary date is October 15, the annual review must happen on or before October 15 of the following year. If the school misses this date — even by one day — without obtaining a proper agreement from you to delay, the district is in violation of COMAR. Some districts in Maryland, particularly those already under MSDE monitoring, have documented histories of missing annual review timelines. Track your child's anniversary date and raise it proactively if the school does not initiate scheduling well in advance.

Who Is on the IEP Team

A Maryland IEP meeting must include specific required participants. Under COMAR:

• At least one regular education teacher (if the student participates in general education)
• At least one special education teacher
• A district representative who can commit district resources (typically a special education administrator or coordinator)
• Someone who can interpret evaluation results
• The parent
• The student (when appropriate, and required when transition planning is on the agenda)
• Other specialists at the discretion of the parent or district

You have the right to invite anyone to the IEP meeting who has knowledge of your child, including private therapists, tutors, doctors, or a parent advocate. Inform the school in advance who you plan to bring.

What Gets Reviewed and Revised

The annual review covers:

Present levels of academic achievement and functional performance (PLAAFP). This section describes where your child currently is across all relevant domains — academic achievement, communication, social-emotional functioning, behavior, and life skills. The PLAAFP is the foundation for everything else in the IEP. If it is inaccurate or vague, the goals built on top of it will be inadequate.

Annual goals. The team reviews progress on the previous year's goals and develops new measurable annual goals for the coming year. Under the post-Endrew F. standard, IEP goals must be ambitious enough to enable meaningful progress, not merely maintenance of current performance. Maryland courts have applied this standard. Vague goals like "Student will improve reading comprehension" are not legally sufficient — goals must be measurable with specific baselines and criteria.

Services and supports. All special education services, related services (OT, PT, speech-language therapy, counseling, etc.), supplementary aids, and accommodations are reviewed and either continued or modified.

Placement. The team considers the least restrictive environment appropriate to implement the IEP. Any change in placement requires Prior Written Notice.

ESY eligibility. Extended School Year must be considered at every annual review. See the separate post on ESY eligibility for what this determination requires.

Transition planning. Beginning no later than the first IEP in effect when the student turns 14 (younger if appropriate), transition goals must address postsecondary education, employment, and independent living.

Maryland's Five-Day Rule: Your Most Powerful Procedural Protection

Maryland has a unique procedural protection that sets it apart from most states. Under COMAR 13A.05.01, school personnel must provide parents with copies of every document the team plans to review at the meeting — assessments, reports, data charts, draft IEPs — at least five business days before the scheduled meeting.

This is not a courtesy — it is a legal requirement. And it is transformative for parent preparation.

With five days of advance notice:

• You can review the draft IEP goals and identify vague or unambitious language before you are sitting at the table
• You can consult with a private therapist or advocate about whether proposed service hours are adequate
• You can prepare data-based counter-arguments if the school's data paints a different picture than what you have observed

If the school fails to provide documents five business days in advance, you have the right to request a postponement of the meeting. Put the request in writing: "I did not receive the documents required under COMAR's Five-Day Rule in time to adequately prepare for tomorrow's meeting. I am requesting that the meeting be rescheduled."

Do not simply show up and sit through a meeting where you are reviewing a draft IEP for the first time. That is exactly what the Five-Day Rule was written to prevent.

Preparing Your Parent Concerns Letter

Best practice in Maryland is to submit a formal Parent Concerns Letter at least two weeks before the annual review. This letter:

• Establishes you as the expert on your child
• Sets your priorities for the meeting
• Flags areas where you have concerns about progress or proposed changes
• Creates a written record that your concerns were raised

A strong parent concerns letter is specific. It does not say "I want her to do better." It says: "Based on her progress monitoring data from Q2, [child's name] advanced only two points on the oral reading fluency measure against a projected growth of 12 points. I am concerned the current reading intervention is not sufficient and want to discuss both the intervention approach and the service hours at the annual review."

Your letter becomes part of your child's educational record.

At the Meeting: What to Document

Even with Maryland's Five-Day document requirement, IEP meetings can move fast. Bring your own notes. Write down every commitment the team makes verbally, because verbal commitments that don't make it into the written IEP do not exist legally.

If you disagree with something proposed in the IEP, state your disagreement and ask for it to be noted in the meeting minutes. You can also submit a formal Parent Addendum to be permanently attached to the IEP — a written statement of your position, the data supporting it, and what you are requesting.

Do not feel pressured to sign an IEP at the meeting. You can take the document home to review it. Maryland law does not require you to sign on the spot.

After the Meeting: Monitoring and Follow-Through

Once the IEP is in effect, the school is legally obligated to implement it exactly as written. If services are missed — a therapist is out and sessions are not made up, an aide is not provided, a promised evaluation is not scheduled — those missed services may constitute a denial of FAPE and are grounds for compensatory education.

Keep a log. Note the dates of services your child receives and any gaps. If services are routinely missed, address it in writing first with the special education coordinator. If the pattern continues, an MSDE State Complaint is the appropriate mechanism to compel compliance and seek make-up services.

The Maryland IEP & 504 Advocacy Playbook provides a Parent Concerns Letter template, IEP review checklist, and guidance on filing MSDE complaints for missed services — specific to Maryland's timeline rules and COMAR requirements.

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