U.S. DEPARTMENT OF EDUCATION

2020 DETERMINATION LETTERS ON 

STATE IMPLEMENTATION OF 

IDEA

REVISED NOVEMBER 25, 2020

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 2018. 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 7.5 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, 2018, 2019, and 2020, 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 2018, 2019, 

and 2020, 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, and again in 

2019 and 2020, 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, 
2020 DETERMINATION LETTERS ON STATE IMPLEMENTATION OF IDEA 2

with a 60% weight and 40% weight 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.
2020 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

Arkansas

Florida

Georgia

Illinois

Kansas

Kentucky

Maine

Massachusetts 

Minnesota

Missouri

New Hampshire

New Jersey

North Carolina

North Dakota

Oklahoma

Pennsylvania

Republic of the 

Marshall Islands

South Dakota

Virginia

West Virginia

Wisconsin

Wyoming

NEEDS ASSISTANCE (one year)

Arizona

Commonwealth of

Northern Mariana 

Islands

Connecticut

Indiana

Montana

Nebraska

Ohio

NEEDS ASSISTANCE (two or more consecutive years)

Alabama

Alaska

American Samoa

District of Columbia

California

Colorado

Delaware

Federated States of

Micronesia

Guam

Hawaii

Iowa

Idaho

Louisiana

Maryland

Michigan

Mississippi

New Mexico

Nevada

Oregon

Puerto Rico

Rhode Island

South Carolina

Tennessee 

Texas

Utah

Washington

NEEDS INTERVENTION (one year)

New York

Virgin Islands

Vermont

NEEDS INTERVENTION (three years)

Palau

NEEDS INTERVENTION (nine consecutive years)

Bureau of Indian Education
2020 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

Alabama

Arkansas

Arizona

District of Columbia

Georgia

Idaho

Kansas

Kentucky

Louisiana

Maryland

Minnesota

North Carolina

North Dakota

New Mexico

Ohio

Oklahoma

Oregon

Pennsylvania

Puerto Rico

Rhode Island

South Dakota

Tennessee

Texas

Utah

Washington

West Virginia

Wyoming 

NEEDS ASSISTANCE (one year)

Alaska

Connecticut

Missouri

Montana

Nevada

New York

Virginia

Wisconsin

NEEDS ASSISTANCE (two or more consecutive years)

American Samoa

California

Colorado

Commonwealth of

Northern Mariana 

Islands

Delaware

Florida

Guam

Hawaii

Iowa 

Illinois

Indiana

Massachusetts

Mississippi

Maine

Michigan

New Hampshire

New Jersey

South Carolina

Vermont

Virgin Islands

NEEDS INTERVENTION (one year)

Nebraska