Has the student made adequate progress with the services currently in place?
Does the amount of direct service time seem adequate to help the student achieve the IEP goals in one IEP year?
What setting or location will be the most appropriate for providing direct services: a regular education classroom or a special education room?
If the student will receive direct special education instruction with other students, how many children will be in the group? Do they have similar needs?
How much indirect service time should be set aside to collaborate with other providers and team members?
IDEA makes no reference to direct or indirect services, but it does state that the IEP "must include a statement of the special education and related services … to be provided to the child or on behalf of the child..." 300.320(a)(4)(i). Direct Service and In Direct time is defined by Minnesota Rule 3525.0220.
During the IEP meeting, the team agrees on goals a child is expected to achieve in one IEP year, and the team then determines how much and what kinds of services are needed. Both direct and indirect services are outlined in the student’s IEP, with specific details about frequency, duration, and type of support provided. Ensuring compliance with these laws is essential to protecting student rights and providing equitable access to education.
Direct Service time is defined by Minnesota Rule 3525.0220 Subp. 14 as the special education services provided by a teacher or professional that are focused on teaching, including cooperative teaching. These services are given directly to a student by a special education teacher or related service professional. They can be provided to one child or a small group of children with similar needs. The purpose of direct services is to help the student meet the goals in their Individualized Education Program (IEP). These services are designed to support students with disabilities, helping them learn, build important life skills, and make progress in their education.
Indirect services are an ongoing part of a student’s support system, provided by special education teachers or related service professionals to those who work directly with the student, such as teachers, specialists, and parents. These services involve planning, coordination, and monitoring to create an effective learning environment and ensure the student’s IEP is successfully implemented. It is essential to clearly define who provides the services and the specific support they offer. However, indirect services do not include MA billing, progress reporting, due process paperwork, meeting material preparation, instructional material preparation, student transportation or transitions, or evaluations.
For both direct and indirect services, the IEP will state the beginning date, frequency per week or month, minutes per session, location, and anticipated duration of the service. The information is used to calculate the amount of special education service time the child will receive, as well as the amount of time the child will not participate in the general education setting. For both direct and indirect services, the IEP states the beginning date; frequency per week or month; minutes per session; location; and anticipated duration of the service.
For indirect service, the IEP should specifically list what the services will be, not just the number of minutes the service will be provided. This information should be included in the Least Restrictive Environment section of the IEP.
Early Childhood Special Education Services
Special Education Reading and Social Skills Services
DAPE District Services
DAPE ELC Services
Speech Services
Occupational Therapy Services
Physical Therapy Services
The information below is provided as general guidance when planning for students with disabilities. Individual planning teams will determine specific plans based on unique student needs. The IEP team will need to discuss how the individual student accesses technology and how the student will access the curriculum on E-Learning Days. The services to be provided to the student, including a description of how the student will access the technology and curriculum, should be included in the service narrative of IEPs as appropriate. Related services that fall on E-Learning Days should also be considered. The following language may be a guide for documenting in the IEP the E-Learning program and the specific modification that will be applied:
Include List of Specific IEP accommodations, modifications, assistive technology, etc... to be considered by IEP team.
Example Language: (Marshall High School) may utilize virtual learning opportunities when making up cancelled school days. In these instances, work will be modified to meet IEP goals. Instruction will be provided to ___________ through __________ (online materials, paper and pencil assignments, projects, extended time...).
Special Education case managers will add an IEP agenda item to discuss E-Learning Days at each meeting.
Direct and indirect services listed in the IEP must correspond to the student's annual IEP goals. For example, if the student has an annual IEP goal in the area of reading fluency, reading services should be listed on the services table. Conversely, if DAPE services are listed on the services table, the connection between that service and an annual IEP goal must be explained in the PLAAFP and/or LRE.
Yes. If the IEP team determines that the student needs additional service time due to unique needs that result from the student's disability. This is more common in secondary buildings when students encounter more content-focused curriculum. Because study skills minutes may not correspond directly with academic IEP goals, the linkage should be explained in the PLAAFP using a statement such as:
"In addition to direct instruction in [academic IEP goal area(s)], XXX needs additional time with support to work on his/her daily work and assignments within a smaller class size and with more frequent one-on-one assistance from staff. XXX will need a daily study skills class in order for him/her to keep up with the pace of his/her [math, science, social studies, etc.] classes."
There is no hard and fast rule; however, what you will typically encounter in the districts is "Social Skills Instruction" being used to describe explicit didactic instruction such as a social skills class or group taught by a special education teacher or related services professional (e.g., school psychologist). "Behavioral Skills Instruction" is more often used for direct minutes in self-contained Setting III or Setting IV social-behavior programs to describe the minutes when the student is receiving explicit instruction in other curriculum areas (e.g., social studies) but is in the special education setting and is receiving frequent behavioral feedback via behavior specific praise and corrective teaching.
The short answer is that the start date on the services grid must be at least 14 calendar days after the date listed on the Prior Written Notice. That is what auditors will verify during a compliance audit. Read on for a more thorough explanation of important dates on the IEP timeline:
IEP Meeting Date: The meeting date is considered the annual date of the IEP. If there are multiple meetings, the first date is considered the annual date. The next year’s IEP meeting must occur within one year of the prior year’s IEP meeting.
IEP Sent Date: The IEP must be written and sent home within 10 calendar days of the last IEP meeting. This date is found on the Prior Written Notice form that accompanies the IEP.
IEP Effective Date: If this is the first IEP for a student, it will not become effective until the parent signs consent. If the IEP is an annual IEP, the parent/guardian must be given at least 14 calendar days to respond. If the parent has not objected in writing within the 14 day time period, the IEP is implemented. This is the IEP effective date.
IEP Service Date: This is the start date of the IEP that is recorded on the services table. It is always the same date as the IEP effective date, 14 calendar days from the IEP PWN date.
Example: The student has had an IEP for the past two years. The IEP meeting occurred on May 3, 2025. The IEP meeting date is 5/3/2025. The IEP was written and sent home on May 17, 2025. The IEP sent date is 5/17/2025. The fourteenth calendar day for the form to be returned, the IEP effective date, and the IEP service date all fall on 5/31/2025.
Per MDE, when parental consent is received prior to the proposed start date, services can be started on the date the district received consent. There is no need to change the start date of services on the IEP.
SpEd Forms does include a field for the end date of services, and it needs to be completed in order to finalize the IEP. However, the end date is not visible on the printed version of the IEP. Because the printed version is what MDE would review for state monitoring, the end date is not a compliance concern.
If you are writing an IEP following an annual IEP meeting, listed services begin 14 days after the date the PWN is sent to the parent and they typically run for a duration of one year. Case managers typically indicate the end date of services as either (A) one calendar year after the IEP meeting date or (B) one calendar year after the listed start date of services. We suggest that one calendar year after the listed start date of services is most appropriate, but again there is no compliance concern here because the end date does not print.