How to Lead IEP Placement Decisions
Use a two-part test that focuses on student needs and portability of services.
Topics: Equity and Diversity, Special Education
When a principal leads an IEP meeting, no decision carries more weight than the student’s placement. Placement is a not a choice to be made casually, and it should never be based on what’s easiest for adults. Placement must be rooted in law, driven by the student’s needs, and anchored in the promise of a free appropriate public education (FAPE) in the least restrictive environment (LRE) as much as possible.
One critical legal tool for principals is the portability test established in Roncker v. Walter (1983): If a student’s services can be delivered in a less restrictive environment, the services must be delivered there. Services should travel to the student—not the other way around.
Since Roncker, other LRE cases have emerged, and courts have changed how they interpret the LRE mandate. Originally, there was deference to more restrictive placements with auxiliary services, but over time, courts have placed a greater burden on districts to maximize inclusion while still ensuring an appropriate education. But the basics of this test are still one of the best guides for principals making placement decisions.
Step 1: Focus on Needs, Not Location
When leading a team, the principal must ensure the conversation starts by outlining the student’s specific academic, behavioral, social, and functional needs. Labels such as “learning disability” or “autism” should not lead the discussion, nor should existing program names or setting options. It’s needs first, location second. If the team can’t clearly articulate what the student needs and why, they’re not ready to talk about placement—period.
Step 2: Apply the Portability Test
After the team identifies needs and services, the principal must guide the team through the portability analysis: Can each service be provided in general education with appropriate supports? This requires real, serious consideration and discussion, not a box-checking exercise. Teams must think through:
- Supplemental aids and services
- Assistive technologies
- Modifications or accommodations
- Positive behavior supports
- Adult assistance
The team must exhaust efforts to make a general education setting work before considering more restrictive options. Defaulting to “it would be easier somewhere else” is illegal.
When a More Restrictive Placement Is Needed
Sometimes, after an honest and thorough conversation, the team might conclude that a student’s needs can’t be met in general education classes even with extensive supports. If that’s the case, the decision must be based on specific, documented evidence—not assumptions, stereotypes, or fear.
If a student’s self-injurious behavior can’t be dealt with safely in a general education classroom despite multiple interventions, for example, that’s a reason. But it has to be documented in detail instead of being couched in phrases such as “best fit” or “more appropriate.” Teams must show what supplemental aids and supports were considered and why they were insufficient.
Discuss the full continuum. It’s not enough to discuss two options: general education or separate program. The full continuum of placement options from full inclusion to separate setting must be considered and documented. Skipping steps or assuming placements because “that’s what we always do” is a fast track to a legal complaint.
Avoid predetermination. Predetermination is another legal land mine. If a district walks into the meeting with a placement already decided (even mentally), a parent can and often will file a complaint. Placement is an IEP team decision that’s made at the meeting following discussion of the student’s needs, services, and the full continuum of possibilities.
Document everything. Once a decision is made, the prior written notice document must be thorough and detailed. It needs to spell out:
- What placement is proposed and why;
- What other options were considered and rejected, and why; and
- What data and information were used in making the decision.
Phrases such as “the team agreed” or “this setting is best” are meaningless and legally insufficient. Details matter; if it’s not written, it didn’t happen.
Why the Portability Test Matters
The portability test forces schools to avoid trying to fit students into existing programs and encourages them to instead redesign programs to fit students. Principals who lead teams through the process aren’t just complying with IDEA; they’re building schools that value every learner’s right to belong.
David F. Bateman is a professor emeritus at Shippensburg University in the Department of Educational Leadership and Special Education and a researcher at the American Institutes for Research.