IEP Progress Monitoring in Texas: What the ARD Must Report and How to Track It

The quarterly progress report arrived. It says "making progress" for every goal. You have no idea what that means, whether it is accurate, or whether your child is actually on track to meet their annual goals. This is one of the most common frustrations Texas parents experience — and it is also a situation where the law is on your side.

What Texas Requires for IEP Progress Reporting

Under IDEA (34 CFR §300.320(a)(3)) and TAC §89.1055, every IEP must:

1. Describe how progress toward annual goals will be measured — not just "teacher observation" but what specific data will be collected (curriculum-based reading probes, behavior frequency data, work samples scored with a rubric)

2. Specify when progress reports will be provided to parents — at minimum as frequently as parents of non-disabled students receive grade reports. In most Texas districts, this means quarterly.

This means you are entitled to progress reports four times per year, and those reports must reflect actual measurement data against each IEP goal — not anecdotal summaries.

What a Compliant Progress Report Contains

A compliant Texas IEP progress report for each goal includes:

• The goal statement
• The current performance data (a score, a percentage, a rate — not just a word or phrase)
• Whether the student is on track to meet the goal by the annual review date
• If the student is not on track, a brief explanation of what the team plans to do about it

"Making progress" with no data is not a compliant progress report. "Student continues to work on this goal" is not a progress report. These phrases appear frequently in Texas IEP progress reports and they tell you nothing about whether the student will meet the goal.

Reading Progress Data: What to Look For

When you receive a progress report with actual data, here is how to interpret it:

Is the starting baseline in the IEP? Every goal should have a baseline — where the student was performing at the start of the year. Without a baseline, you cannot determine whether the current data represents progress.

Is the current data meaningful relative to the goal criterion? If the goal is 90 correct words per minute and the student is currently at 55 words per minute with one quarter left in the year, the student is not on track. If they were at 40 at the start of the year, they have made significant progress — but still will not meet the goal.

Is the data frequency sufficient? Progress toward reading fluency goals should be tracked with regular probes (ideally every two weeks). Behavior goals should be tracked with weekly frequency data. A single data point reported quarterly is not adequate progress monitoring for most IEP goals.

Is the data the right type for the goal? If the goal measures reading fluency in words per minute and the progress report discusses the student's reading comprehension instead, the data does not address the goal.

When Progress Is Not Being Monitored

If the district is not collecting data on IEP goals — or is collecting inadequate data — address it in writing before the annual ARD:

"I have reviewed the quarterly progress reports for [child's name] and I am concerned that the data provided does not reflect actual measurement of the IEP goals. Specifically, [Goal X] requires measurement by [stated method], but the progress reports have not included [the specific data type]. Please provide me with the raw data collected on each IEP goal over the past quarter before our annual ARD meeting on [date]."

You have the right to access the data being used to report progress. Ask for it.

Progress Monitoring for Different Goal Types

Reading Goals (curriculum-based reading probes): Data should include: grade level of the passage, words read correctly per minute, number of errors, and date of each probe. A progress graph showing probe scores over time is ideal and makes trends easy to see.

Math Goals (curriculum-based math probes): Number of problems correct out of total, or percentage accuracy, with the date and specific skill area tested.

Behavior Goals (frequency, duration, or intensity data): A log showing the number of occurrences per observation period (per hour, per day, per week), the duration of the observation, and who collected the data.

Social Skills Goals (observation data): Percentage of opportunities the student demonstrated the target skill, with the number of opportunities observed and the setting.

Communication Goals (SLP session data): Number of correct responses out of total opportunities in the target skill area, across sessions.

Building Your Own Progress Tracker

While the district is required to report progress, you do not have to rely solely on their reports. Consider keeping a simple log that tracks:

• Date of each quarterly progress report
• Goal-by-goal summary of reported data
• Your observations at home of related skills
• Notes from teacher communications about progress

This log gives you a longitudinal record that is useful at the annual ARD when you are evaluating whether goals were met and whether new goals are ambitious enough.

What to Do When Progress Is Insufficient

If the quarterly data shows a student is not making adequate progress toward an IEP goal, the ARD committee should review the IEP and consider whether:

• The goal was unrealistic given the starting baseline (in which case the goal may need to be adjusted)
• The services and instruction are not adequately matched to the skill gap (in which case services may need to change)
• There is a factor not reflected in the IEP affecting progress (health, attendance, family circumstances)

You can request an ARD meeting at any time to address insufficient progress. You do not have to wait for the annual review. If progress data shows a student has been working on the same goal for two consecutive years with minimal movement, that is a signal that the instructional approach or intensity needs to change.

Under the Endrew F. v. Douglas County School District (2017) standard, an IEP must be "reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances." Stagnant progress over multiple years is evidence that the IEP is not meeting this standard.

The Connection Between Progress Monitoring and Compensatory Education

If progress monitoring data shows that a student made no progress or regressed during a period when services were not being delivered, that data supports a compensatory education claim. The gap between where the student should be and where they are — documented through progress data — is the basis for calculating how many compensatory service hours are owed.

See texas-compensatory-education for the full compensatory education process.

The Texas IEP & 504 Blueprint includes a progress monitoring log template, questions for reviewing progress data at ARD meetings, and sample language for requesting additional data when progress reports are inadequate.

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