Indicator 13 in West Virginia: How to Tell If Your Child's Transition IEP Is Compliant

What Indicator 13 Measures

Indicator 13 is a federal compliance metric that every state must report to the U.S. Department of Education. It measures the percentage of students with IEPs who have transition plans that meet specific legal requirements. In West Virginia, the WVDE Office of Special Education audits local school districts against this indicator annually.

The audit is pass/fail at the student level. A transition plan that fails any single one of the monitored items is flagged as entirely noncompliant — there is no partial credit.

Parents should understand what this means practically: the state already has a checklist for what a legally compliant transition plan looks like. If your child's IEP fails to meet these standards, the transition plan is noncompliant with the monitored requirements.

The Ten Items West Virginia Audits

West Virginia's Indicator 13 monitoring process reviews each student's IEP against ten specific requirements. A plan must satisfy all ten to be marked compliant:

1. Age-appropriate transition assessments were conducted and documented
2. Measurable postsecondary goals are present for education or training
3. Measurable postsecondary goals are present for employment
4. Measurable postsecondary goals for independent living are included when appropriate (the IEP team determines appropriateness)
5. Postsecondary goals are updated annually based on current assessment data
6. Transition services in the IEP directly align with and support the postsecondary goals
7. Courses of study align with the postsecondary goals and the student's career pathway
8. Annual IEP goals explicitly connect to the postsecondary transition goals
9. The student was invited to the IEP meeting where transition was discussed
10. Outside agency representatives were invited to the meeting (with appropriate parent consent) when they were likely to provide or pay for transition services

What Noncompliance Looks Like in Practice

The most common failures parents encounter fall into predictable patterns:

Generic goals that are not measurable. A postsecondary goal like "Student will be employed after graduation" fails the test. A compliant goal specifies the type of employment, the timeline, and how progress will be assessed. For example: "After graduation, the student will obtain competitive integrated employment in the food service industry within six months."

Missing independent living goals. Many IEP teams skip independent living goals entirely, assuming they are optional. They are optional only when the IEP team has explicitly determined they are not needed for that student — and that determination must be documented.

Transition services that do not connect to postsecondary goals. If the student's postsecondary goal is employment in automotive repair, but the transition services section lists only "attend weekly social skills group," the plan fails alignment.

No outside agency invitation. If the student is 16 or older and would benefit from DRS services, the school must invite DRS to the meeting (with parent consent). If nobody was invited, the plan is noncompliant.

How Parents Can Use Indicator 13

Indicator 13 gives parents a concrete, state-defined standard to hold schools accountable. Before the next IEP meeting, parents can:

Audit the current IEP against the ten items. Go through each requirement and check whether the current plan satisfies it. If you find gaps, bring them to the meeting in writing.

Request that the IEP team address each item explicitly. Rather than a general "let's discuss transition," ask the team to walk through each of the ten requirements and document how the plan meets them.

Reference the monitoring standard in disputes. If the school pushes back on adding transition services or inviting outside agencies, parents can point to Indicator 13 as the state's own compliance standard. A plan that fails the state's audit criteria is not defensible.

File a state complaint if the plan is noncompliant. If the school refuses to correct a plan that fails Indicator 13 requirements, a formal state complaint to the WVDE Office of Federal Programs triggers a 60-day investigation. Districts found noncompliant must implement corrective actions or face financial sanctions.

Why Compliance Alone Is Not Enough

Indicator 13 audits focus on whether the paperwork meets minimum legal standards. A plan can be technically compliant — all ten boxes checked — while still being functionally useless to the student.

A compliant goal written in measurable terms does not guarantee the school is actually implementing the services. A compliant outside agency invitation does not mean the DRS counselor showed up. Parents need to look beyond the paperwork to verify that the plan is being carried out.

The West Virginia IEP Transition to Adulthood Guide includes a parent-facing Indicator 13 audit checklist, examples of compliant vs. noncompliant goals, and strategies for escalating when the school's plan looks good on paper but falls short in practice.

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