Maryland Infants and Toddlers Program: Transitioning from IFSP to IEP at Age 3

Your child has been receiving early intervention services since infancy. A therapist comes to your home or daycare. The IFSP is family-centered, flexible, and working. Then someone tells you that services end at age 3 and everything changes.

The transition from Maryland's Infants and Toddlers Program to school-age special education is one of the most disorienting moments in any family's special education journey. It is not just a paperwork change — it is a shift from a family-centered service model to an educational model governed by an entirely different set of federal and state regulations. If you do not understand what is required, when it must happen, and what your options are, your child can lose months of critical services during the transition.

What Is the Maryland Infants and Toddlers Program?

The Maryland Infants and Toddlers Program (MITP) provides early intervention services to children from birth through age 2 under Part C of the Individuals with Disabilities Education Act (IDEA). Services are delivered through an Individualized Family Service Plan (IFSP), which is distinct from a school-age IEP in several important ways.

An IFSP is family-centered by design. It identifies not just the child's developmental needs, but the family's resources, priorities, and concerns as they relate to supporting the child's development. Services are typically provided in the child's "natural environment" — the home, daycare, or community settings where children without disabilities spend their time. The service coordinator works directly with your family to coordinate therapies and supports.

Over 111,000 students with disabilities ages 3 through 21 receive special education services in Maryland. Many of those families entered the system exactly as you are: through early intervention, via the MITP.

When Does the Part C to Part B Transition Start?

This is where many families are caught off guard. The transition from Part C (MITP/IFSP) to Part B (school-age special education/IEP) is not something that happens automatically on your child's third birthday. It requires active planning that must begin months earlier.

Under IDEA and COMAR, transition planning must begin between 9 months and no later than 90 days before your child's third birthday. For a child with a birthday in September, that means transition planning should begin by early June at the latest — and should ideally start closer to 9 months out.

Your IFSP service coordinator is responsible for facilitating this transition. They must convene a transition conference and coordinate with the local education agency (your county school system) to ensure that services continue without a gap. If your service coordinator has not raised the transition by the time your child is approximately 2 years and 3 months old, you should raise it yourself in writing.

The goal is a seamless transition. In practice, families frequently experience disruptions if they don't actively track these timelines.

What Happens at the Evaluation: Part C to Part B

To receive school-age special education services under Part B, your child must be separately evaluated and found eligible by your local school district. The IFSP your child has been receiving does not automatically transfer to an IEP.

This evaluation is governed by COMAR's strict timeline: once the school district receives written referral and you provide consent, the district has 60 calendar days to complete all assessments and convene an eligibility meeting. Because the referral in a Part C to Part B transition is typically initiated during the transition conference well before the third birthday, this timeline should run comfortably before services need to begin.

However, the criteria for eligibility are different under Part B. Under Part C, a child qualifies based on developmental delay or an established condition with a high probability of causing delay. Under Part B, the child must meet one of the 13 federally recognized disability categories and, by reason thereof, require specially designed instruction and related services.

Some children who received IFSP services will qualify for IEPs under Part B. Others may qualify for a Section 504 Plan (which provides accommodations but not specially designed instruction). And some children, particularly those who showed significant progress through early intervention, may no longer meet the legal threshold for services at all.

If the district determines your child is not eligible for an IEP, you have the right to request an Independent Educational Evaluation (IEE) at public expense if you disagree with the district's assessment. That right does not disappear just because your child is newly entering the school system.

Maryland's Extended IFSP Option: What It Is and When to Use It

Maryland offers something most states do not: the Extended IFSP Option. This is one of the most important and least-understood options available to families of young children approaching age 3.

Here is how it works. If your child is evaluated and found eligible for preschool special education under Part B, you have a choice. You can transition to a traditional school-based IEP — which typically means your child receives services in a preschool classroom setting. Or you can elect to keep your child on an Extended IFSP until the beginning of the school year following the child's fourth birthday.

The Extended IFSP retains the family-centered, natural-environment service delivery model of early intervention while adding an educational component focused on school readiness skills. Services continue to be delivered in home or community settings, coordinated by an IFSP service coordinator.

When the Extended IFSP makes sense:

• Your child is making strong progress in the home-based natural environment model and would be disrupted by a sudden transition to a school building
• Your child is not yet socially or emotionally ready for a group preschool setting
• The district's proposed preschool placement is in a more restrictive setting than the Extended IFSP would provide
• The transition would require significant travel or logistical disruption for your family

When transitioning to an IEP makes more sense:

• Your child would benefit significantly from peer interaction and an inclusive preschool setting
• The disability requires specialized instruction that is better delivered in a school-based setting with more specialized staff
• Your child is approaching 4 and will need to be in the IEP system soon regardless

The Extended IFSP is not available if the school district determines your child is not eligible for Part B services. It is only an option when your child meets Part B eligibility criteria and you, as the parent, choose it over the traditional IEP pathway.

If your service coordinator or the school district does not explain the Extended IFSP option to you, ask directly. Maryland law requires that families be informed of this choice.

The LRE Problem at the Preschool Level

Least Restrictive Environment is one of the most contested concepts in preschool special education. The IEP team is required to place your child in the setting that most closely approximates a general education environment while still meeting their needs — not the most convenient or cheapest setting for the district.

In the preschool years, this means that a self-contained special education classroom should not be the first option on the table unless there is specific, documented evidence that your child cannot make progress in a less restrictive setting with appropriate supports.

Maryland school districts must maintain a continuum of placement options for preschoolers. These range from inclusive community preschool programs with itinerant special education support, to co-taught classrooms, to specialized preschool classrooms, to specialized programs in separate schools. The Blueprint for Maryland's Future's expansion of Pre-K programs has increased the number of general education preschool settings available as potential inclusive placements.

If the IEP team recommends a fully self-contained preschool program, the written IEP document must include a specific justification explaining why the child cannot be educated in a less restrictive setting even with supplementary aids and services. Vague language about "the child's needs" is insufficient. Request the specific data that supports the recommended placement.

Protecting Services During the Transition Gap

One of the greatest risks in the Part C to Part B transition is a gap in services. This happens when the evaluation timeline is not managed carefully, paperwork is delayed, or the school district's process is slower than your child's third birthday.

If your child turns 3 and the IEP has not yet been finalized, the district is required to make a good-faith effort to implement services comparable to what was in the IFSP while the evaluation and eligibility process continues. The child's right to FAPE (Free Appropriate Public Education) begins at age 3 under Part B, regardless of whether the IEP document has been completed.

If you find yourself in a transition where your child's third birthday has passed and no services are being provided, put your concerns in writing immediately — to the school principal, the special education coordinator, and the district's special education director if necessary. Document the dates, reference the COMAR timelines, and request a written response with a specific date by which services will begin.

The Maryland IEP & 504 Blueprint includes the specific COMAR citations and letter templates for exactly this situation — where a transition gap puts your child's services at risk and you need to force the district to act quickly.

What Changes When You Move from IFSP to IEP

Parents who have been in the IFSP system often describe the shift to an IEP as jarring. Here is what changes:

Focus shifts from family to child. The IFSP is built around your family's concerns and priorities. The IEP focuses on the child's educational needs and measurable annual goals in an academic context.

Natural environment gives way to LRE. IFSP services happen where the child naturally spends time. IEP services are governed by LRE, which starts with the school setting and determines how much time will be spent in general education versus specialized environments.

Service coordinator is replaced by the IEP team. Your IFSP service coordinator, who managed communications and helped coordinate services, is replaced by the IEP team process. There is no single point of contact in the same way. Communication with the district runs through the IEP team, the special education coordinator, and the child's service providers — often separately.

Timelines become strictly procedural. The IFSP world is relatively flexible. The IEP world is governed by strict COMAR timelines, procedural safeguards, Prior Written Notices, and formal consent requirements. Missing a deadline or signing the wrong document can have real legal consequences.

Progress is measured differently. IEP progress is measured against specific, measurable annual goals. You receive progress reports at least as frequently as non-disabled students receive report cards. If your child is not making progress toward their goals, you can formally request that the IEP team reconvene to discuss changes.

How to Prepare for the Transition Conference

The transition conference is the formal meeting that kicks off the Part C to Part B handoff. Come prepared.

Bring all documentation of your child's current IFSP services — which therapies, how many hours per week, progress data, and any assessments that have been completed. Your IFSP service coordinator should prepare a transition summary, but do not assume it captures everything relevant.

Ask the following questions at the transition conference:

• What is the exact timeline for the district's evaluation? What date was written consent received, and what is the 60-day deadline?
• Who will be conducting the evaluations, and what domains will be assessed?
• What preschool placement options exist in this district, and what is the full continuum?
• Is my child eligible for the Extended IFSP option, and will it be explained in writing?
• If there is any gap between my child's third birthday and the start of IEP services, how will the district provide comparable services during that period?

Get answers in writing wherever possible. The transition conference often involves multiple parties from two different systems — early intervention and the school district — and verbal commitments get lost. A brief follow-up email summarizing what was discussed and agreed upon creates a paper trail that protects your child's rights.

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