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Ask the Advocate LIVE: Your Biggest IEP and 504 Questions, Answered

by | Jun 4, 2026 | Epic Educator Academy, IEP, IEP Help for Parents, Karen Mayer Cunningham, Parent Rights, Special Education Academy

Prefer to watch? The full Ask the Advocate session is on the Special Education Boss® YouTube channel — subscribe and watch here. New episodes post every week.

Were you ever actually trained on what you are expected to do at the IEP and 504 table? Most of us were not. We were handed responsibilities — documents to read, services to deliver, decisions to make — without the training to match. That is not your fault. But students still need what they need, which is exactly why we sit at the table prepared.

On June 1, we went live for an hour of Ask the Advocate and took more than 50 questions from parents, advocates, and educators. Below are the answers that came up most — the short version first, then the detail.

Quick answers from this session

  • Special education minutes must be delivered by a credentialed special educator — being below grade level does not change that.
  • Accommodations are written from a student’s characteristics, not their disability label.
  • Missed services are remedied by calculating the minutes and asking the district how it will make them right.
  • Extended School Year (ESY) rests on two prongs: documented regression and risk of losing critical skills.
  • Inclusion means participating — not just sitting near the activity.

What should parents do over the summer to prepare for next year?

Email the school about any unaddressed needs now, then review the year’s progress reports before the next year starts. Most administrators and directors work year-round, and your IEP is, at best, our best informed guess — kids change, staff change, settings change, so adjustments are normal. Pull your final progress reports and check them against what the team predicted your child would reach after specially designed instruction.

Then prepare for day one with what Karen calls the Zach Pack: a one-page profile for your child — photo, strengths, struggles (her two favorite words), and parent contact info — plus a full copy of the IEP for every educator who will work with your child. Not just the homeroom teacher. The art, music, PE, and elective teachers too, along with any in-class support staff. A disability that rises to an IEP usually affects a student across settings, so everyone teaching your child should be informed. Karen breaks this down in depth in The Epic IEP™.

Who is allowed to deliver a student’s special education minutes?

Specially designed instruction must be delivered by a credentialed, highly qualified special educator. Paraprofessionals support under direct supervision, close proximity, and frequent contact — but an aide cannot deliver initial instruction, and a special educator who drops in a few times a month does not meet that bar. This holds true even when a student is only a year or two below grade level.

So when the school year starts, get the names of everyone teaching your child and ask a simple, non-personal question: is this person certified for the role they were assigned? It is not personal. It is business. The paraprofessional’s role is covered start to finish in The Epic IEP™: PARA.

Should accommodations be based on a student’s disability label?

No. Accommodations are written from the characteristics of a student’s unique circumstances — not the name of their eligibility category. Schools sometimes work from a menu tied to a label, but that is backwards. Once accommodations are written, they have to be implemented with fidelity and monitored. If you are new to a role, start by knowing each student’s accommodations and their intent, then build a simple, consistent way to log delivery. We are never looking for perfection — we are looking for forward progress.

What can you do when IEP services or minutes are missing?

Document it, calculate it, and ask the district how it would like to remedy it. That single move answered a surprising number of questions.

Missed minutes. If agreed-upon services were not delivered, calculate the frequency, duration, and location, put the number in writing, and ask how the district will make it right. If a student missed a month of speech, that is real time a disabled child now has to make up — so ask whether replacing it is meaningful, and how.

Prior written notice. If a PWN does not reflect what happened or is missing required components, ask for the correction in writing. If you do not get it, add your own written description of the meeting to the record so your experience is captured.

Independent educational evaluations. An IEE essentially tells the school its evaluation fell short, and the district’s obligation is narrow: pay for it, receive a copy, and convene a meeting to consider it. Often a more productive path is to ask the original evaluator to open an addendum and complete what was missing — for example, two of the Gs like GA (auditory processing) or GLR (long-term retrieval). When you review any evaluation, look for three things: data, summary, and conclusion. Naming exactly which one you disagree with is far stronger than “I disagree with your evaluation.”

How do retention, ESY, and transition planning fit together?

Each one rewards thinking about the long arc, not just this year.

Retention. If your child may need transition services from 18 to 21, holding them back can cost a year on that end. Karen generally only considers retention in kindergarten or first grade — and an IEP that means a student is somewhat behind is not, by itself, a reason to retain. We do not promise to close gaps. We make gains, and we teach strategies to self-manage a disability.

ESY. Extended School Year rests on two prongs: documented regression on an IEP goal with a significant time to recoup the skill, and concern for the loss of critical skills. It is built on the specific goals a student needs to maintain — not a blanket service.

Transition. Transition belongs in the IEP by age 16 at the latest (some say earlier), and it should start with a parent interview. The goal is not to graduate a student and wave goodbye — it is a coordinated set of activities aimed at gainful employment, independent living, and further education. A great free resource is the Oregon Transition Resource Handbook.

What is the difference between inclusion and proximity?

Proximity is being near the activity; inclusion is being part of it. If two people sit at separate tables in the same restaurant, that is proximity — not inclusion. Inclusion means a student is experiencing, connecting, and participating, because we know kids learn the most from other kids. As Karen put it: everyone has a right to inclusion; inclusion is not right for everyone. The continuum of placements exists for exactly that reason, which is why moving a self-contained senior into all general education classes runs straight into the law.

The throughline

Almost every answer came back to the same idea: you cannot implement what you do not understand, and you do not know what you do not know — but you need to. Preparation beats panic. Clarity beats confusion. And documentation beats memory every time.

Frequently asked questions

Who is allowed to deliver a student’s special education minutes?

Specially designed instruction is delivered by a credentialed, highly qualified special educator. Paraprofessionals can support under the direct supervision, close proximity, and frequent contact of a special educator, but an aide cannot deliver initial instruction. A student being below grade level does not change this requirement.

What are the two prongs of Extended School Year (ESY)?

ESY is based on documented regression on an IEP goal with a significant amount of time needed to recoup the skill, and on concern for the loss of critical skills. It is determined by the specific goals a student needs to maintain, not offered as a blanket service.

How do I request compensatory services for missed minutes?

Calculate the missed services by frequency, duration, and location, put the total in writing, confirm with the district that the services were not delivered, and ask how the district would like to remedy it. If the district declines to remedy a clear failure, a state complaint may be a consideration.

What is the difference between inclusion and proximity?

Proximity is simply being near an activity. Inclusion means a student is experiencing, connecting, and participating in what the class is doing. A student seated in the back with a para is not automatically included. Everyone has a right to inclusion, but inclusion is not right for everyone, which is why a continuum of placements exists.

What should parents do over the summer to prepare for next year?

Email the school about any unaddressed needs, since administrators work year-round. Review all of the year’s IEP progress reports against the team’s predicted outcomes. Then prepare a one-page profile and a full copy of the IEP for every educator who will work with the child at the start of the new year.

This was educational training, not legal advice. We educate everyone at the IEP and 504 table to navigate and negotiate successful student outcomes.

Keep going

Parents and advocates — go deeper inside Special Education Academy, or get hands-on prep at The Epic IEP™ 2-Day Advocacy Intensive and the Mastermind.

Educators — The Epic Educator Academy™ is live training every Monday at 7:00 PM Central, built for school-based staff. $27/month, cancel anytime. Join at specialeducationacademy.com.

Get the books: The Epic IEP™, The Epic IEP™: PARA, and The Epic IEP™ Guide to Federal and State Law for Special Education — wherever books are sold.


About Karen Mayer Cunningham. Karen Mayer Cunningham is a nationally recognized special education advocate, educator, trainer, and bestselling author. She is the founder of Special Education Boss® and Special Education Academy™, and the author of The Epic IEP™, The Epic IEP™: PARA, and The Epic IEP™ Guide to Federal and State Law for Special Education. Drawing on years of advocacy in IEP meetings, mediations, and due process, she trains everyone at the IEP and 504 table — parents, educators, and professionals — to navigate and negotiate successful student outcomes.

“When we get it right for the child, we get it right for everyone.” — Karen Mayer Cunningham

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