Maryland IEP Reevaluation: What Happens at the Three-Year Triennial

Three years goes quickly when you're managing your child's IEP, and many Maryland parents arrive at the triennial reevaluation unprepared — either unaware it was coming or unsure of what they're entitled to ask for. The three-year reevaluation is not a formality. It is one of the most important checkpoints in the special education process, and how it is handled significantly affects your child's services going forward.

Why Reevaluations Are Required

Under IDEA and COMAR 13A.05.01.06, every child receiving special education services must be reevaluated at least once every three years. The purpose is to verify that:

1. The child continues to meet eligibility criteria — that they still qualify as a student with a disability under one of the 13 IDEA categories
2. The disability continues to cause the child to require specially designed instruction
3. The current IEP reflects the child's actual, present needs — not needs that were documented three years ago when the child was younger

The three-year timeline runs from the date of the most recent full eligibility evaluation, not from the date of the first IEP meeting. If the school is approaching this date without having initiated the reevaluation process, that is worth raising in writing.

The Two Pathways: Full Reevaluation vs. Review of Existing Data

A critical aspect of the triennial that surprises many parents: not every three-year reevaluation requires new, formal testing. COMAR and IDEA allow the IEP team — with your agreement — to determine that a full battery of new assessments is unnecessary if existing evaluation data is sufficient to make eligibility and programming decisions.

This determination happens at a formal review meeting called an Evaluation Team Meeting or Eligibility Planning Meeting. The team reviews all existing data, including current progress monitoring, classroom assessments, state assessment results, teacher input, and any private evaluations you've obtained. If the team — and you — agree that the existing data adequately answers the eligibility questions, they can document that conclusion and no new testing is administered.

Your right in this process: You have the right to request that the school conduct specific additional assessments even when the team proposes to rely on existing data. If you believe the current data is outdated, incomplete, or does not address a new area of concern, you can — and should — request new evaluations.

The school's right in this process: The school can propose to skip new testing and rely on existing data. But this requires your agreement. If you want new testing and the school refuses to conduct it, they must issue a Prior Written Notice explaining why they declined, and you retain the right to dispute that decision.

What a Full Triennial Reevaluation Should Include

When the team determines that new assessments are needed, the triennial reevaluation must be comprehensive enough to address your child's current educational needs across all relevant domains. Depending on the disability category and your child's profile, this may include:

• Cognitive and processing assessment: Updated intelligence testing, processing speed, working memory, executive function
• Academic achievement testing: Current reading, writing, and mathematics performance compared to grade-level expectations
• Speech-language evaluation: If communication remains a concern or if there have been changes in language use or articulation
• Occupational therapy assessment: If fine motor skills, sensory processing, or handwriting are relevant
• Behavioral and functional assessment: If the child's disability affects behavior or social-emotional functioning
• Adaptive behavior scales: For students whose functional daily living skills are relevant to program planning

One issue that frequently arises in triennial reevaluations: the school proposes a narrow evaluation that only revisits the areas tested initially, without addressing new concerns that have emerged over the three years. If your child has developed new challenges — anxiety, attentional difficulties that weren't previously assessed, a change in behavioral presentation — this is the time to request that these areas be formally evaluated.

Requesting a Reevaluation Before Three Years

You do not have to wait for the three-year clock to run out. COMAR allows parents to request a reevaluation at any point during the IEP period if you have reason to believe your child's educational or functional needs have changed significantly.

Valid reasons to request an early reevaluation include:

• A new medical diagnosis (ADHD, anxiety disorder, a sensory processing diagnosis, a sleep disorder)
• A significant change in academic performance — either a sudden decline or plateauing after previous progress
• The emergence of behavioral challenges not previously documented
• Evidence from private therapy or neuropsychological evaluation that the school's data does not reflect the child's actual functioning
• An upcoming major transition (from elementary to middle school, middle to high school) where updated data would improve planning

Schools may push back on requests for early reevaluations by saying the existing data is sufficient. If they decline, they must issue a Prior Written Notice with their rationale. You then have the right to challenge that decision through mediation, a state complaint, or due process.

The 60-Day Timeline Applies to Reevaluations

Once you sign consent for the triennial reevaluation, the same 60-calendar-day evaluation timeline that applies to initial evaluations applies here. The school has 60 days from your signed consent to complete all assessments, convene the eligibility meeting, and make a determination.

The same rules apply to the five-day document rule: all evaluation reports and data must be provided to you at least five business days before the eligibility meeting.

What Happens After the Reevaluation

The eligibility meeting following a triennial can result in three outcomes:

Continued eligibility: The child is found to still meet eligibility criteria. The team proceeds to revise the IEP, which must be developed within 30 days of the eligibility determination. This is the most common outcome and the moment to ensure that updated evaluation data is actually reflected in revised goals and services — not just carried forward unchanged from the previous IEP.

Changed disability category: The child is found eligible under a different or additional disability category than originally identified. This can affect what services are appropriate and how the IEP is structured.

Exiting special education: The team determines the child no longer meets eligibility criteria. If you disagree with this determination, you can dispute it — request an Independent Educational Evaluation at public expense, request mediation, or file a due process complaint. The school must provide you with a PWN explaining the basis for the exit determination.

How to Prepare for the Triennial

The triennial reevaluation is one of the most consequential IEP meetings your child will have. Preparation matters:

Review your child's current IEP and all existing evaluation data before the meeting. Identify gaps — areas of concern that have not been formally assessed or that were assessed with tools that may now be outdated.

Request all proposed assessment tools in advance. Ask what specific tests and instruments the school plans to use, who will administer each, and what domains each test covers.

Bring your own documentation. Observations from private therapists, pediatricians, tutors, or mental health professionals are valuable. The evaluation team must consider all relevant data, including data you provide.

Invoke the five-day rule. Request that all evaluation reports be provided at least five business days before the eligibility meeting. Do not attend the meeting having read reports for the first time that morning.

Come with updated goals in mind. If new assessment data reveals growth in some areas and persistent deficits in others, be prepared to discuss what revised IEP goals should address.

The Maryland IEP & 504 Blueprint includes a reevaluation preparation checklist and guidance on how to use triennial data to negotiate stronger services at the IEP meeting that follows.

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