IEP Services Not Started Yet? What to Do This September

The IEP was signed in the spring. It is now the second week of September, and the speech slot has not started, the aide named in the plan has not been hired, and the new teacher is still "getting up to speed." Nobody is being unkind. They are short-staffed. That is true, and it is also not your child's problem to absorb. IEP services not started on time are still services owed, and this post covers what to check and what to say.

Why this September is harder than most

Special education is the most widespread teacher shortage in the country. The Learning Policy Institute's 2026 update counts more than 425,000 teaching positions that are either vacant or filled by someone not fully certified for the job, roughly one in eight positions nationwide, and reports special education as a shortage area in 45 states.

The federal School Pulse Panel found that 74 percent of elementary and middle schools had difficulty filling a special education teaching vacancy with a fully certified teacher heading into the school year. Support staff are thinner still. A Chalkbeat investigation this summer counted roughly 1,600 open paraprofessional positions in New York City alone, with students whose IEPs require a one-to-one aide sent home or kept out of class until one could be found.

So if your child's services are late, you are not imagining a problem, and you are not alone in it.

IEP services not started: what the plan is still owed

Two lines in the federal regulations matter most right now. Section 300.323 says that at the beginning of each school year, the district must have an IEP in effect for every eligible child, and that every teacher and provider responsible for the plan must have access to it and be informed of their specific responsibilities, including the accommodations, modifications, and supports they must provide.

Staffing does not change that. In OSEP Memo 22-01, the U.S. Department of Education acknowledged the shortage directly and then said it does not alter the requirement that services be delivered by properly certified staff. Districts can contract outside providers, reassign staff, or adjust schedules. What they cannot do is leave a child without the services on a signed plan.

When services are missed, the remedy has a name. Compensatory services are make-up services owed when the school fails to implement the IEP as written. OSEP has recognized them as a proper way to provide FAPE since Letter to Kohn in 1990, and missed minutes due to staffing gaps are one of the most common reasons a child qualifies.

If you moved over the summer, the same section covers you. A child who transfers districts must receive services comparable to the old IEP from day one, until the new district adopts that plan or writes a new one. An evaluation is not a prerequisite for starting.

Five steps for the next two weeks

1. Ask for the service schedule in writing. Email the case manager and ask for the days, times, and provider for every service on the IEP. If a slot has no provider yet, ask for the start date and who is covering until then. Our guide to the first email to your child's teacher covers the tone.
2. Confirm the teachers have actually seen the plan. Ask the general education teacher directly which accommodations they are providing. The regulation requires that they be informed, and a vague answer tells you it has not happened.
3. Start a missed-minutes log today. Date, service, minutes owed, minutes delivered, and who told you. Two weeks of dates are the basis for a compensatory services request, and they are difficult to dismiss.
4. Request a meeting if nothing changes by the end of the month. You can request an IEP meeting any time. Name the purpose in one sentence: to review service delivery and agree on a make-up plan.
5. Keep home predictable while school is not. A child with a new teacher, a missing aide, and a shifting schedule is carrying a lot of uncertainty. The National Clearinghouse on Autism Evidence and Practice rates visual supports as an evidence-based practice across every school age, backed by more than 100 studies. A morning and after-school routine your child can see is the one part of the day you can hold steady.

What the log gives you

Advocacy is easier when the conversation is about numbers rather than feelings. A log of dates and minutes turns "my child is not getting speech" into "my child is owed 90 minutes from the last three weeks," and that is a sentence a team can act on. It also protects the relationship with the people in the building, because it points at a schedule, not at them. For the staff-side view, see why the staff handoff breaks down and give the new teacher a one-page profile so the plan has a face.

VizyPlan was built by an autism dad and a licensed speech-language pathologist so what happens at home is something you can show a team rather than something you have to describe.

Download VizyPlan and start your 7-day free trial today. Keep the home routine steady while the school one catches up. Just $6.99/month after your trial, no credit card required upfront.

VizyPlan was built by an autism dad and a licensed speech-language pathologist who needed something that did not exist. Start your free trial.