OSEP QA 21-06 - Return to School Roadmap: Development and Implementation of Individualized Education Programs in the Least Restrictive Environment

Oct 10, 2026

Return to School Roadmap guidance from the U.S. Department of Education’s Office of Special Education and Rehabilitative Services addresses how IDEA requirements should be interpreted as schools return to in-person services during COVID-19. It covers IEP timelines and team convening, special factors, measurable annual goals and compensatory services, ESY determinations, secondary transition, placement decisions, and resolving disputes. The roadmap emphasizes that regardless of instruction mode, students with disabilities receive FAPE, and infants and toddlers receive appropriate Part C services.

LanguageEnglish

CategoryHealthcare

FormatPDF

Pages41

Reading Time1 h 43 min

AccessFree to download

Introduction

A. Ensuring IEPs Are in Effect at the Start of the School Year

B. Convening the IEP Team

C. Consideration of Special Factors

Considering the Assistive Technology Needs of a Child with a Disability

Addressing the Social, Emotional, Behavioral, and Mental Health Needs of Children with Disabilities

Addressing the School-Related Health Needs of Children with Disabilities with Underlying Medical Conditions

D. Determining Appropriate Measurable Annual Goals & Considering the Child’s Need for Compensatory Services

E. Making Extended School Year (ESY) Services Determinations

F. Considering Secondary Transition Services

G. Making Educational Placement Decisions

H. Resolving Disagreements Regarding a Child’s Educational Program

UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICE OSEP QA 21-06 RETURN TO SCHOOL ROADMAP: DEVELOPMENT AND IMPLEMENTATION OF INDIVIDUALIZED EDUCATION PROGRAMS IN THE LEAST RESTRICTIVE ENVIRONMENT UNDER THE INDIVIDUALS WITH DISABILITIES EDUCATION ACT September 30, 2021 The U.S. Department of Education (Department), Office of Special Education and Rehabilitative Services (OSERS) has received requests from a diverse group of stakeholders asking that the Department issue new guidance interpreting requirements of the Individuals with Disabilities Education Act (IDEA) in light of the many challenges ofthe COVID-19 pandemic and as more schools and programs are returning to in-person services. Topics include meeting timelines, ensuring implementation of initial evaluation and reevaluation procedures, determining eligibility for special education and related services, and providing the full array of special education and related services that children with disabilities need in order to receive a free appropriate public education (FAPE) . 1 In addition, stakeholders have inquired about the implications of delayed evaluations and early intervention services to infants and toddlers with disabilities and their families served under IDEA Part C.2 The purpose of the Return to School Roadmap IDEA guidance documents, 3 which focus on school reopening efforts, is to support the full implementation of IDEA requirements. The documents also serve to clarify that, regardless of the COVID-19 pandemic, or the mode of instruction, children with disabilities are entitled to FAPE, and infants and toddlers with disabilities and their families to appropriate IDEA Part C services. The Department recognizes that some parents may have specific health and safety concerns about sending their children back to in-person instruction because of the health risk to the student, the student’s immediate family, and to other household members—even as parents are also concerned about their child missing the instructional and social and emotional opportunities 1 Free appropriate public education or FAPE means special education and related services that (1) are provided at public expense, under public supervision, and without charge; (2) meet the standards of the State educational agency (SEA), including the requirements of IDEA; (3) include an appropriate preschool, elementary school, or secondary school education in the State involved; and (4) are provided in conformity with an individualized education program that meets the requirements of 34 C.F.R. §§ 300.320 through 300.324. 34 C.F.R. § 300.17. 2 Additional guidance, including requirements of Part C of IDEA, will be forthcoming. 3 Other than statutory and regulatory requirements included in this Q&A document, the contents ofthis guidance do not have the force and effect of law and are not meant to bind the public. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. The questions and answers in this document are not intended to be a replacement for careful study of IDEA and its implementing regulations. The IDEA, its implementing regulations, and other important documents related to IDEA and the regulations are found at: [https://sites.ed.gov/idea/](https://sites.ed.gov/idea/) . that come with in-person learning.4 Therefore, reopening schools safely is of utmost importance. State educational agencies (SEAs) and local educational agencies (LEAs)5 should put in place layered prevention strategies, including promoting vaccination and universal and correct maskwearing in schools. The Centers for Disease Control and Prevention (CDC) recommends that everyone in K through 12 schools wear a mask indoors, including teachers, staff, students, and visitors, regardless of vaccination status.6 CONTENTS Introduction .........................................................................

FAQs

What is the purpose of the Return to School Roadmap guidance documents?

They support full implementation of IDEA requirements and clarify that students with disabilities are entitled to FAPE and infants and toddlers with disabilities are entitled to appropriate IDEA Part C services regardless of COVID-19 conditions or instruction mode.

What topics does the guidance cover for IEP implementation when schools reopen?

It addresses ensuring IEPs are in effect at the start of the school year, convening the IEP team, considering special factors, and determining measurable annual goals and compensatory services.

How does the guidance address health and safety concerns during reopening?

It notes that some parents have health and safety concerns and emphasizes safe reopening through layered prevention strategies, including vaccination promotion and universal and correct mask wearing, consistent with CDC recommendations for K through 12 schools.

Oct 10, 2026

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