Montana IEP Exit Summary and Summary of Performance

What Triggers the Exit Summary Requirement

When a Montana student's eligibility for special education ends — whether they graduate with a regular diploma or age out at 22 — the school district is federally required to provide a Summary of Performance (SOP). This isn't optional. It's mandated under 20 U.S.C. § 1414(c)(5)(B)(ii) and 34 CFR § 300.305(e)(3).

The SOP doesn't apply when a student simply transfers to another district (they get their records forwarded instead). It kicks in at two specific exit points: graduation with a standard diploma, or reaching the end of FAPE eligibility. After the 2025 federal court ruling extending Montana's FAPE endpoint to a student's 22nd birthday, that second trigger now happens later than it used to for students on the alternate credential track.

What the Summary of Performance Must Include

Federal law specifies three components:

1. Academic Achievement Summary — A clear statement of the student's current academic performance levels, including any standardized assessment results, grade-level performance data, and areas of strength.

2. Functional Performance Summary — An assessment of the student's daily living skills, social behaviors, communication abilities, and vocational competencies. This is where transition-relevant skills like money management, transportation navigation, and self-care get documented.

3. Recommendations for Postsecondary Goals — Specific, actionable recommendations on how to help the student meet their postsecondary education, employment, and independent living goals. These aren't vague platitudes. They should name specific accommodations, assistive technology, or support strategies that postsecondary institutions or employers can actually implement.

Why the SOP Matters More Than Most Districts Let On

A well-written SOP is the bridge document between public education and everything that comes after. College disability service offices use it to determine what accommodations a student qualifies for. VRBS counselors reference it when building an Individualized Plan for Employment. Adult service providers use it to understand the student's current functional baseline.

A weak SOP — one that's filled with generic language, missing functional data, or light on specific recommendations — forces the student to start from scratch with every new provider. That means new evaluations, new intake processes, and weeks or months of delay.

How Montana OPI Exit Codes Work

Montana's Office of Public Instruction tracks how students leave special education using a set of exit codes. The ones relevant to transition:

• Code 23 (Regular diploma): Student met all state and local graduation requirements under ARM 10.55.905. FAPE terminates. SOP is required.
• Code 32 (Certificate or alternate credential): Student received a certificate, modified diploma, or credential based on IEP goals. Under the 2025 ruling, this does not terminate FAPE — the student can remain enrolled through their 22nd birthday.

If your child is being exited under code 23, the SOP must be provided before the exit date. Don't let it arrive as an afterthought in the mail — request it during the final IEP meeting and review it before the student's last day.

How to Audit Your Child's SOP

Before you accept the SOP, check for these common problems:

Generic recommendations. "Student would benefit from continued support" tells a college disability office nothing. Push for specifics: "Student requires extended test time (1.5x), a distraction-reduced testing environment, and access to text-to-speech software for all reading-intensive assignments."

Missing functional data. If the student has been receiving occupational therapy, speech therapy, or behavioral supports, the SOP should document current functional levels in those areas — not just academics.

No mention of assistive technology. If the student uses AT in school, the SOP should list every device, software, and accommodation so the next provider knows what's been working.

Outdated assessment data. The SOP should reflect the student's most recent evaluation, not data from three years ago. If the most recent reevaluation is stale, you may want to request a final round of transition assessments before the exit date.

Vague postsecondary goal language. The recommendations section should align with the student's actual postsecondary plans, not boilerplate. A student heading to a community college needs different documentation than one entering supported employment.

What to Do If the SOP Is Inadequate

If the SOP you receive is thin or generic, you have options:

1. Request revisions in writing before the student's exit date. Reference the federal requirement and specify what's missing.
2. Bring your own documentation to the final IEP meeting — transition assessment results, therapy progress reports, AT inventories — and ask the team to incorporate them.
3. Contact OPI's Early Assistance Program at (406) 444-2046 if the district refuses to provide a compliant SOP.

The Montana IEP Transition to Adulthood Guide includes an SOP audit checklist and a template for requesting revisions — plus the broader exit planning framework that connects the SOP to your child's VRBS referral, DDP application, and benefits coordination.

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