Writing IEP Goals in Maryland: What Makes a Goal Measurable and Enforceable

IEP goals are the legal heart of your child's program. They are not aspirational statements — they are the measurable commitments the school makes about what your child will achieve during the school year. In Maryland, COMAR 13A.05.01.09 requires that annual goals in the IEP be measurable, tied to the student's documented present levels, and paired with a specific method for tracking and reporting progress.

When goals are vague, too easy, or disconnected from your child's actual deficits, the IEP becomes a document that technically satisfies compliance requirements while failing to drive meaningful educational progress. This guide explains what legally adequate Maryland IEP goals look like, how to identify weak ones, and what to do about them.

What COMAR Requires for IEP Goals

Maryland's IEP document requirements under COMAR 13A.05.01.09 are explicit. Annual goals must:

1. Be measurable — they must be specific enough that progress can be objectively measured, not just estimated
2. Address the student's academic and functional needs as documented in the Present Levels of Academic Achievement and Functional Performance (PLAAFP)
3. Include benchmarks or short-term objectives for students who take alternate assessments (such as the DLM Alternate Assessment)
4. Be accompanied by a progress reporting method — how progress will be measured and how often parents will be informed

The measurability requirement is the one most frequently violated in practice. A goal that says "John will improve his reading skills" is not measurable. A goal that says "John will read grade-level passages at 90 words per minute with no more than 3 errors, as measured by weekly curriculum-based reading probes, with 80% accuracy across four consecutive data collection periods by the end of the IEP year" is.

What SMART Goals Mean in Practice

You may have heard IEP goals described as needing to be SMART. This framework is commonly applied in Maryland IEP development:

• Specific: What skill, behavior, or knowledge will be targeted?
• Measurable: How will progress be quantified?
• Achievable: Is the target realistic given the student's present levels?
• Relevant: Does the goal address an actual deficit documented in the PLAAFP?
• Time-bound: By when should the goal be achieved?

The SMART framework is useful, but it does not capture one additional element that Maryland parents need to track: the growth expectation. The U.S. Supreme Court's 2017 decision in Endrew F. v. Douglas County School District established that IEP goals must be reasonably calculated to enable a child to make progress appropriate in light of their circumstances — not merely de minimis (minimal) progress. Maryland courts and MSDE apply this standard, which means goals that represent only token growth from a child's current baseline may be legally insufficient, even if they are technically measurable.

The Connection Between PLAAFP and Goals

Every goal in your child's IEP should trace directly back to the Present Levels of Academic Achievement and Functional Performance section. If the PLAAFP says your child reads at a 2nd-grade level while in 5th grade, there should be a reading goal that addresses that gap. If the PLAAFP documents significant difficulties with written expression, there should be a writing goal. If the PLAAFP mentions behavioral challenges that disrupt learning, there should be functional behavioral goals.

When you see a goal in your child's IEP that does not correspond to anything documented in the PLAAFP, ask the team: where in the present levels is this need identified? When there is a documented need in the PLAAFP that has no corresponding goal, ask: why isn't there a goal addressing this area?

A well-constructed PLAAFP makes it much harder for the school to write inadequate goals, because it creates an explicit record of what needs to be addressed.

Examples of Weak vs. Strong IEP Goals

Understanding the difference between legally adequate and inadequate goals helps you evaluate what the school proposes.

Weak goal: "Maria will improve her math skills during the school year." Why it fails: No baseline, no target criterion, no measurement method, no timeframe beyond "the school year."

Stronger goal: "Given 20 two-digit by two-digit multiplication problems, Maria will solve 16 or more correctly (80% accuracy) as measured by bi-weekly teacher-administered probes, by the end of the annual IEP period." Why it works: Specific skill, measurable criterion, defined measurement method, time-bound.

Weak goal: "Dante will improve his behavior in class." Why it fails: Behavior is not defined, no measurement, no target.

Stronger goal: "During unstructured transitions between activities, Dante will independently move to the next activity within 2 minutes of the transition cue, as measured by daily teacher observation logs, with 80% success rate across 4 consecutive school weeks." Why it works: The specific behavior, the context, the timeframe, the measurement method, and the success criterion are all defined.

Weak goal: "Sarah will improve her reading fluency." Why it fails: Same problems as the first example.

Stronger goal: "Sarah will read 3rd-grade level passages at 90 correct words per minute with 3 or fewer errors, as measured by bi-weekly DIBELS Next oral reading fluency probes, on 3 out of 4 consecutive data points by the IEP's annual review date." Why it works: Grade level specified, fluency metric defined, error ceiling set, specific assessment tool named, frequency of measurement clear, target criterion includes consistency requirement.

How to Push Back on Inadequate Goals at the IEP Meeting

You do not have to accept goals as presented. As a full, equal member of the IEP team, you have the right to propose modifications or reject goals you believe are inappropriate.

Practical strategies:

Ask for the baseline data. Before the meeting, request to see the assessment data and progress monitoring data that informed the proposed goals. Under Maryland's five-day document rule (Ed. Art. § 8-405), the school must provide these to you at least five business days before the meeting.

Ask what growth rate the goal represents. If your child's current reading rate is 40 words per minute and the goal is set at 55 words per minute, that is 15 words of growth over a year. Ask the team: what is the expected rate of growth for a child at this level who is receiving effective intervention? The answer may reveal whether the goal reflects genuine ambition or minimal compliance.

Ask which assessment tool will be used. Goals should name a specific measurement tool or method. If the team cannot tell you how progress will be measured, the goal is not written correctly.

Propose alternative language in writing. If you believe a goal is inadequate, you can write an alternative version and submit it to the team in writing before the meeting. The team must consider and respond to your proposal. If they reject it, that rejection should be documented in the Prior Written Notice.

Request more time. If you are being asked to approve goals in a meeting and you have not had sufficient time to review them, you can invoke the five-day rule and request a follow-up meeting. Do not let time pressure force you into approving goals you have not had the opportunity to evaluate.

The Maryland IEP & 504 Blueprint includes a goal evaluation worksheet that walks through each component of a goal and provides the questions to ask when something looks incomplete or insufficiently ambitious.

Progress Reporting: Holding the School to the Goals

Once goals are written, COMAR requires schools to report progress to parents at least as frequently as they report progress for non-disabled students. In practice, this usually means at each report card period. But parents should not wait passively for progress reports.

You have the right to request a copy of your child's progress monitoring data at any time. If progress reports consistently say "making progress" without supporting data, ask for the raw data — the specific scores on the probes or assessments used to measure each goal. Meaningful progress monitoring tracks growth over time and includes enough data points to identify trends, not just a subjective rating.

If progress data shows your child is not on track to meet a goal, you have the right to call an IEP team meeting to review the data and adjust services or supports. You do not have to wait for the annual review.

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