U.S. DEPARTMENT OF EDUCATION

2018 DETERMINATION LETTERS ON

STATE IMPLEMENTATION OF

IDEA

REVISED JULY 24, 2018

The U.S. Department of Education’s Office of Special Education and Rehabilitative Services 

released State determinations on implementation of the Individuals with Disabilities Education 

Act (IDEA) for Part B and Part C for fiscal year 2016. The 2004 Amendments to the IDEA 

require each State to develop a State Performance Plan (SPP) and Annual Performance Report 

(APR) that evaluates the State’s efforts to implement the requirements and purposes of the 

IDEA, and describes how the State will improve its implementation. The Part B SPP/APR and 

Part C SPP/APR include Indicators that measure child and family results, and other indicators 

that measure compliance with the requirements of the IDEA. Since 2015, the Part B SPP/APR 

and Part C SPP/APR have included a State Systemic Improvement Plan through which each 

State focuses its efforts on improving a State-selected child or family outcome. 

The IDEA also requires each State to report annually to the Secretary on its performance under 

the SPP. Specifically, the State must report in its APR, the progress it has made in meeting the 

measurable and rigorous targets established in its SPP. The Secretary is required to issue an 

annual determination to each State on its progress in meeting the requirements of the statute. 

The determinations are part of the ongoing efforts to improve education for America’s 7 million 

children with disabilities. 

IDEA details four categories for the Secretary’s determinations. A State’s determination may be:

 Meets the requirements and purposes of IDEA;

 Needs assistance in implementing the requirements of IDEA;

 Needs intervention in implementing the requirements of IDEA; or

 Needs substantial intervention in implementing the requirements of IDEA.

For the first time in 2014, and again in 2015, 2016, 2017 and 2018, the Department made Part B 

determinations using both compliance and results data, giving each equal weight in making a 

State’s determination. For the first time in 2015 and again in 2016, 2017 and 2018, the 

Department made Part C determinations using both compliance and results data, giving each 

equal weight in making a State’s determination. For the first time in 2018, the Department made 

Part B determinations for the outlying areas, freely associated States, and the Bureau of Indian 

Education using both compliance and results data, with a 60% weight and 40% weight 
2018 DETERMINATION LETTERS ON STATE IMPLEMENTATION OF IDEA 2

respectively. OSEP’s accountability framework, called Results Driven Accountability (RDA), 

brings into focus the educational results and functional outcomes for children with disabilities while 

balancing those results with the compliance requirements of IDEA. Protecting the rights of 

children with disabilities and their families is a key responsibility of State educational agencies 

(SEAs) and local educational agencies (LEAs) for Part B, and Lead Agencies and early 

intervention service programs for Part C, but it is not sufficient if children are not attaining the 

knowledge and skills necessary to accomplish the ideals of IDEA: equality of opportunity, full 

participation, independent living, and economic self-sufficiency.

IDEA identifies specific technical assistance or enforcement actions that the Department must 

take under specific circumstances for States that are not determined to “meet requirements.” If a 

State “needs assistance” for two consecutive years, the Department must take one or more 

enforcement actions, including, among others, requiring the State to access technical 

assistance, designating the State as a high-risk grantee, or directing the use of State set-aside 

funds to the area(s) where the State needs assistance. If a State “needs intervention” for three 

consecutive years, the Department must take one or more enforcement actions, including 

among others, requiring a corrective action plan or compliance agreement, or withholding

further payments to the State. Any time a State “needs substantial intervention” the Department 

must take immediate enforcement action, such as withholding funds or referring the matter to 

the Department’s inspector general or to the Department of Justice.
2018 DETERMINATION LETTERS ON STATE IMPLEMENTATION OF IDEA 3

IDEA PART B DETERMINATIONS

Following is a list of each State’s performance in meeting the requirements of IDEA Part B, 

which serves students with disabilities, ages 3 through 21: 

MEETS REQUIREMENTS

Connecticut

Georgia

Indiana

Kansas

Kentucky

Massachusetts

Minnesota

Missouri

North Carolina

North Dakota

Nebraska

New Hampshire

Ohio

Oklahoma

Pennsylvania

Republic of the 

Marshall Islands

South Dakota

Virginia

Vermont

Wisconsin

West Virginia

Wyoming

NEEDS ASSISTANCE (one year)

Alabama

Delaware

Federal States of 

Micronesia

Iowa

Montana

New Jersey

Tennessee

NEEDS ASSISTANCE (two or more consecutive years)

Alaska

Arkansas

American Samoa

Arizona

California

Colorado

Florida

Guam

Hawaii

Idaho

Illinois

Louisiana

Maryland

Maine

Mississippi

New Mexico

Nevada

New York

Oregon

Puerto Rico

Rhode Island

South Carolina

Texas

Utah

Virgin Islands

Washington 

NEEDS INTERVENTION (one year)

District of Columbia

Michigan

Palau Commonwealth of the 

Northern Mariana 

Islands

NEEDS INTERVENTION (seven consecutive years)

Bureau of Indian Education
2018 DETERMINATION LETTERS ON STATE IMPLEMENTATION OF IDEA 4

IDEA PART C DETERMINATIONS

Following is a list of each State’s performance in meeting the requirements of IDEA Part C, 

which serves infants and toddlers birth through age 2:

MEETS REQUIREMENTS

Alaska

Alabama

Arkansas

Connecticut

District of Columbia

Georgia

Idaho

Kansas

Kentucky

Maryland

Maine

Michigan

Minnesota

North Carolina

North Dakota

New Hampshire

New Jersey

New Mexico

Nevada

Ohio

Oregon

Pennsylvania

Puerto Rico

Rhode Island

South Dakota

Tennessee

Texas

Utah

Virginia

Washington

West Virginia

NEEDS ASSISTANCE (one year)

California

Iowa

Indiana

Mississippi

Missouri

New York

Wisconsin

Wyoming

NEEDS ASSISTANCE (two or more consecutive years)

American Samoa

Arizona

Commonwealth of the 

Northern Mariana

Islands

Colorado

Delaware

Florida

Guam

Hawaii

Illinois

Louisiana

Massachusetts

Montana

Nebraska

Oklahoma

South Carolina

Virgin Islands

Vermont