Speech Therapy and Occupational Therapy on an IEP in Pennsylvania

Your child's IEP lists 60 minutes per week of speech-language therapy. By mid-year, they've received perhaps a third of that. The school says the therapist is out, the schedule is full, or they're "working on it." You're watching your child fall behind on goals they should be hitting.

This is one of the most common IEP violations in Pennsylvania — and it has a name: failure to implement. Here's what you should know about related services on an IEP, and what you can do when they aren't being delivered.

Related Services Are Legally Mandated, Not Optional

Under Chapter 14, related services are developmental, corrective, and supportive services required to assist a child with a disability to benefit from special education. They are listed in the IEP because the IEP team determined they are necessary for the student to receive FAPE.

Speech-language pathology and occupational therapy are the two most common related services on Pennsylvania IEPs. Other related services include:

• Physical therapy
• Psychological counseling and social work services
• Audiology
• Assistive technology services
• Orientation and mobility services
• Transportation (when needed as a related service)

Once these services are written into the IEP with a specified frequency and duration, they are a legal obligation. A district cannot reduce them without convening the IEP team, providing Prior Written Notice via a NOREP, and giving the parent the opportunity to approve or disapprove the change.

Why Sessions Get Missed — And Why That Doesn't Matter Legally

Pennsylvania is in the middle of an acute special education staffing shortage. According to the Pennsylvania School Boards Association's 2025 State of Education report, the special education population has surged nearly 20% over 15 years while the workforce has contracted. Districts routinely report vacancies in specialized roles, including speech-language pathologists and occupational therapists, along with heavy reliance on emergency-certified personnel.

The legal reality is unambiguous: a staffing shortage does not suspend the district's obligation to provide FAPE. An administrative failure to hire does not give the district legal cover to miss mandated sessions. When a district cannot deliver IEP services due to staffing, it is liable to provide compensatory services — makeup hours to replace what was missed.

This matters because schools often tell parents "we don't have a therapist right now" in a way that implies nothing can be done. That framing is incorrect. The parent's response should be: "My child's IEP requires these services. How is the district providing them, and when will missed sessions be made up?"

Requesting Compensatory Services for Missed Sessions

Compensatory education is the remedy for failed IEP implementation. The calculation is straightforward: count the sessions specified in the IEP, count the sessions actually delivered, and the difference is the compensatory obligation.

For example, if the IEP requires 30-minute speech therapy sessions twice per week, that's approximately 60 sessions in a school year (based on 30 weeks of instruction). If the student received 35 sessions, the district owes 25 sessions of compensatory speech therapy.

To pursue this:

1. Request session logs from the school. Send a written request for records of all speech therapy and OT sessions delivered to your child, with dates and duration. This is an educational records request under FERPA and must be fulfilled promptly.

2. Compare logs against the IEP. Calculate the shortfall based on the frequency written in the document.

3. Make a formal written request for compensatory services. Address the letter to the special education director. State the number of missed sessions, reference the IEP, and request a specific number of compensatory sessions before the end of the school year or at the start of the next.

4. Escalate if the district refuses. A refusal to provide compensatory education for documented missed sessions is grounds for a state complaint with the Bureau of Special Education.

Getting Speech Therapy or OT Added to the IEP

If your child does not currently have related services on their IEP but you believe they need them, there are two paths:

Through the IEP team. Request an IEP team meeting and specifically ask the team to consider adding speech-language pathology or OT as a related service. Come prepared with documentation: teacher observations, your own observations at home, any outside evaluations or clinical records from a speech pathologist or OT your child sees privately.

Through the evaluation process. If your child has never been evaluated for speech or OT needs within the school context, request that the district's next evaluation (or the current one, if an evaluation is underway) include assessment by a speech-language pathologist and/or occupational therapist. The evaluation report must include data about whether the student's functioning in these areas requires specially designed instruction or related services.

If the district evaluates and concludes your child does not need speech or OT services, but you disagree, you can request an Independent Educational Evaluation at public expense from a qualified outside professional.

The IEP Goal Question: Is the Service Actually Working?

The IEP should include measurable goals that relate directly to the related services your child receives. If your child receives speech-language services, the IEP should have goals targeting the specific areas of deficit — articulation, language processing, pragmatics, fluency — not just a notation that "speech services are provided."

Progress monitoring data, reported at least as often as report cards, should show whether your child is making progress toward those goals. If sessions are being delivered but goals are not being met after a reasonable period, that's a signal to request an IEP team meeting to review whether the service model, frequency, or approach needs to change.

The Pennsylvania IEP & 504 Advocacy Playbook includes service tracking worksheets, compensatory education request templates, and letter templates for demanding IEP implementation when sessions are being missed. Get the complete toolkit at /us/pennsylvania/advocacy/.

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