Montana Early Intervention Part C and the Transition to Part B at Age 3

Your child is under three years old and you're concerned about their development. Maybe they aren't talking yet, aren't walking on schedule, or have a diagnosis that will likely affect how they learn. Montana's early intervention system — funded under IDEA Part C — provides services for infants and toddlers with disabilities or developmental delays, at no cost to families.

Understanding what Part C offers, who qualifies, and what happens when your child turns three is critical. The transition from early intervention to preschool special education can be seamless, or it can leave your child without services for months. This post explains what you need to know to navigate both.

What Montana Part C Early Intervention Covers

IDEA Part C funds a system of early intervention services for infants and toddlers from birth to age three who have developmental delays or established medical conditions likely to result in developmental delays. In Montana, this program is administered by the Department of Public Health and Human Services (DPHHS).

Eligible children receive services through an Individualized Family Service Plan (IFSP) — the early intervention equivalent of an IEP. The IFSP is family-centered: it includes goals for the child but also addresses the needs of the family in supporting the child's development.

Services available under Montana's Part C program include:

• Speech-language therapy
• Occupational therapy
• Physical therapy
• Developmental intervention
• Vision and hearing services
• Service coordination (a dedicated coordinator who helps families navigate the system)
• Assistive technology devices and services
• Psychological services
• Transportation when necessary to access services

A critical feature of Montana Part C services: they are typically provided in the child's natural environment — home, daycare, or community settings — rather than a clinic or school. This is by design. Early intervention is meant to be woven into the child's daily routines, not isolated to a weekly therapy session.

Who Qualifies for Part C Services in Montana

A child under age three qualifies for Part C services in Montana if they meet one of two criteria:

Developmental delay: The child shows a measurable delay in one or more developmental areas — cognitive development, physical development, communication, social-emotional development, or adaptive behavior. Montana defines developmental delay using standardized evaluation criteria.

Established condition: The child has a diagnosed physical or mental condition that has a high probability of resulting in developmental delay, such as Down syndrome, cerebral palsy, hearing loss, visual impairment, or a chromosomal abnormality.

Importantly, a formal diagnosis is not required to access an evaluation. If you suspect your child has a developmental delay, you can request an evaluation — it is free, and the evaluation itself will determine eligibility.

To request an evaluation, contact Montana's early intervention intake system. Your child's pediatrician can provide a referral, or you can contact DPHHS directly. In rural areas, evaluations are conducted by itinerant teams that travel to the family.

The Part C to Part B Transition: What Happens at Age Three

The most consequential moment in the early intervention process is the transition to the school-based special education system — IDEA Part B — which begins at age three. ARM 10.16.3122 establishes that the Local Educational Agency (LEA) where the child resides is responsible for ensuring FAPE beginning on the child's third birthday.

This is a hard deadline. Services do not continue past the third birthday under Part C. Your child's Part B IEP must be in effect on the day they turn three — not a week later, not after the school figures out the paperwork.

Montana's transition process requires coordination between the Part C provider and the school district. The transition planning meeting should occur well before the child's third birthday — typically by age two and a half. At this meeting, the family, Part C service providers, and school district representatives discuss the child's current functioning, potential eligibility for Part B services, and what the transition will look like.

Timeline for a Smooth Transition

By age 2.5 (at least 9 months before the third birthday): The Part C service coordinator must convene a transition conference including the family and, with parental consent, representatives from the school district. The goal is to discuss the transition process, share evaluation results, and begin planning.

At least 90 days before the third birthday: The school district must be notified of the child's potential eligibility for Part B preschool services. The Part C coordinator manages this notification with your consent.

Before the third birthday: The school district completes its own evaluation under IDEA Part B criteria (if the child may be eligible), the IEP team meets, and if the child is eligible, a Part B IEP is developed and ready to implement on the child's birthday.

On the third birthday: The IEP goes into effect. Services begin. The child transitions from DPHHS-administered Part C to OPI-governed Part B.

The Rural Gap: When the Timeline Slips

In rural and remote Montana, this timeline frequently slips. Special education evaluators may not have availability. Cooperative staff may not be able to schedule an IEP meeting in time. Families may not receive adequate notice of the upcoming transition.

When this happens, your child may turn three without a finalized IEP. Under ARM 10.16.3122, the district's obligation begins on the third birthday regardless of whether it has completed its process. A child without services on their third birthday due to district inaction or delay is potentially experiencing a FAPE violation from day one.

If the transition is not proceeding on schedule:

• Contact the school district's special education director in writing at least four months before your child's birthday, stating that you are aware of the transition timeline and requesting a meeting date
• Document all communications and their dates
• If the deadline passes without an IEP in place, contact the OPI Early Assistance Program at (406) 444-5664
• If the delay is significant, file a state complaint with OPI under ARM 10.16.3662

What If Your Child Doesn't Qualify for Part B?

Not every child who received Part C services will qualify for Part B. Part B eligibility requires meeting one of IDEA's 13 disability categories and demonstrating that the disability adversely affects educational performance. A three-year-old who received Part C services for a speech delay may no longer qualify for Part B if the delay has been substantially remediated.

If the school determines your child does not qualify for Part B, they must issue a Prior Written Notice (PWN) explaining the basis for the eligibility determination. You have the right to disagree with the evaluation, request an Independent Educational Evaluation (IEE) at public expense, and pursue dispute resolution if you believe the eligibility decision was incorrect.

Some children who do not qualify for Part B under IDEA may still qualify for a Section 504 plan if the condition substantially limits a major life activity.

Getting Help With the Transition

The Montana Empowerment Center (MEC) offers specific guidance for families navigating the Part C to Part B transition and provides webinars on early childhood intervention transitions. Reaching MEC early — well before your child's third birthday — can help you understand what to expect and advocate effectively during the transition planning conference.

The Montana IEP & 504 Advocacy Playbook includes guidance on the Part B evaluation request process, transition timeline documentation, and letter templates for when the school district is slow to initiate the transition process — practical tools for families managing one of the most time-sensitive advocacy moments in special education.

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