I’m a self-professed weirdo, but I just love NOREPs. Love love love them. Early on when I first became an advocate, I only worked in Pennsylvania. The training I went to was Pennsylvania-based, so we learned about what a NOREP is and how to use it.
I mistakenly thought that every state has NOREPs. They don’t. It’s a Pennsylvania-specific thing. It is critical that every Pennsylvania parent learns about the NOREP and how to use it. Because, signing it or not signing it can have serious consequences!
By the time you read this, I hope that you are loving your NOREP too!
What is a NOREP?
NOREP is another special education acronym. It stands for Notice of Recommended Educational Placement.
It is our PWN or Prior Written Notice. PWN applies to all 50 states, and parents must educate themselves on this important document.
Again, this only applies to students in Pennsylvania. As a reminder, when it comes to IDEA vs state regulations, a state can do more than what IDEA calls for. But it cannot do less. In my opinion, the NOREP does offer more to parents than a PWN. I’m going to explain exactly what it is and why I feel that way.
First, here is a sample NOREP form. It’s from our state’s training and assistance agency, known as PATTAN. If you ever need a blank IEP or blank NOREP, any document really, check the PATTAN website.
Please note that as I go through this NOREP and explain it to you, you will see boxes with the word ANNOTATION in them. This is an annotated version from PATTAN.
A regular, blank NOREP will not be annotated. That is also on their website. I am using this version since I’m explaining it.
Parts of the NOREP
Let’s start with the top of the first page.
Both the blank and the annotated versions I have seen do say both NOREP and /Prior Written Notice on them. Prior written notice is something in IEP procedural safeguards that you want to read up on.
At the top, you see a box where the school is to record the date that they receive the signed NOREP back from you, the parent.
THIS IS CRITICAL. If you read and learn nothing else from this article, please read the next couple of blue paragraphs very carefully.
When a school sends you a NOREP, it is their final offer of FAPE. It’s the final draft of the IEP–the one that they want you to accept. The NOREP is the document that ‘seals the deal’ and you indicate agreement with the proposed IEP.
However….and this is Pennsylvania specific: IF YOU DO NOT SIGN A NOREP, IT AUTOMATICALLY GOES INTO EFFECT IN 10 DAYS.
Read that again. Yes, not signing a NOREP indicates agreement.
Over the years, I’ve worked with a lot of frustrated parents. Parents who feel defeated, beaten down, sad and powerless.
And as such, they sometimes want to withhold their signature, as sort of a way to reclaim power.
However, in Pennsylvania, this is dangerous. Withholding your signature actually means that you agree.
I don’t care how busy you get or how frustrated you are. You must pay attention to your mail and email, and look for that NOREP. For a busy mom, 10 days goes by in a flash. And all of a sudden, you learn that you’ve agreed to an IEP that you loathe.
What’s on a NOREP?
Ok, once we get past that, look at the first big section.
Per IDEA procedural safeguards, any change to FAPE, or a refusal to change FAPE, requires a PWN or NOREP.
So, anything that you’ve discussed with the school, things you’ve asked for, things they’ve asked to add or change on the IEP…..ANY change to FAPE, requires this form.
The fourth one from the bottom: “Refusal to change the identification, evaluation or a free appropriate education (FAPE)” is also very important.
If you, the parent, asked for a change to the IEP and it was refused, it must be documented via a NOREP.
Ok, let’s move on to the next two sections of a NOREP.
The annotation from PATTAN makes it pretty clear. Any change to FAPE or refusal to change FAPE, must be noted.
Next up, what else was considered?
It’s getting really good now, isn’t it?
Not only does the school have to document any changes to FAPE, they have to list what else they considered and why it wasn’t chosen.
So, if you, the parent, you ask for a 1:1 aide, or an out-of-district placement, and you’re told no, the school has to document all of it. What was discussed and why they refused to change FAPE per your request.
Why is this important? Because IEPs are data driven, and it’s all about the documentation. It’s really easy to just say “Let’s wait and see” to a parent in an IEP meeting. It’s much more difficult to document all of it on a NOREP.
Next up, how did the IEP team arrive at this decision?
In the next section, the LEA (school district) must list how they arrived at their decision.
They must also list other factors they considered in this decision. Examples given below.
Next they have to list placement.
NOREP Placement
Here is the next section, where the school district must document the child’s IEP placement.
Parent agreement is the next section.
Pay attention to the yellow circle that I made. That is the statement that the school will proceed in 10 days if they don’t hear from you!
Lastly, a few more tidbits about your rights and where to go for more information.
Ok, so now you know the parts of a NOREP. Maybe you have one in your possession right now that needs attention. Or, you’re getting one soon.
Here are the next steps.
NOREP Next Steps
Ok, agree or disagree….what are you next steps? What should you do with your NOREP? Do I have to sign it even if I agree?
Parent Agrees with a NOREP
A NOREP (the proposed change to FAPE) will automatically go into effect if you do not sign and return it.
So, technically, no, you do not have to sign and return it if you agree.
However, in IEP land, I play the long game. You never, ever want to have anything negative documented about you. I’m telling the other advocates and parents in my training to always keep their “eyes on that lighthouse in the distance.”
And that is, should you ever find yourself in Due Process….how is this going to look?
So, sign it and return it. It only takes a few minutes and is best practice. And, should you find yourself in legal proceedings with your school district in the future, they can’t say “And she’s not an engaged/interested parent, she never bothered to return the NOREPs.”
Disagree with the NOREP
Well, the options are pretty self-explanatory. You have some decisions to make.
I spend a great deal of time on this in my online training, so that you can make it very difficult for the school to say NO to your written request.
You’re going to have to decide what to do next. Read your parents rights booklet that they gave you. Visit attorneys. PA is one of the most IEP-litigious states in the country. If you go to due process, your school district will have attorneys. Very good attorneys, I might add.
There’s a very large, statewide firm that serves most districts in the state. All those lawyers do, all day every day, is fight parents over IEPs. You cannot do this without an attorney.
Incorrect or Incomplete NOREP
If you receive an incorrect or incomplete NOREP, you have a few options.
- Send an email to whoever sent you the NOREP. List the mistakes you see and ask them to send a revised version.
- Write on it yourself, making the additions or corrections. Then sign it and send it back. There is nothing in IDEA that says that only schools can write on NOREPs.
- File a state compliance complaint.
I also have used the annotated version from PATTAN as part of my rebuttal back to schools. After all, it’s our state’s special education technical assistance agency. It’s where the PA Department of Education wants you to go for information about special education.
Why would they put all that information on an annotated NOREP, if they didn’t intend for schools to utilize the document that way?
Sometimes I’ll just include a snippet, much like what I’ve included in this article. And a “I was looking at a NOREP on the PATTAN website, and their example shows “this” but the one I have does not.”
My NOREP is Late!
This comes up sometimes.
First, school mail can sometimes sit in mailrooms for several days. Then, it may sit at the post office for a day or two.
Add in a weekend or holiday….and before you know it, your 10 days is almost gone.
First, be proactive. As soon as you receive it, send an email to whoever sent it. A simple “I received the NOREP today. I will be taking the full 10 days to review it and send it back, which is {date.}”
I’ve never had a school fight a parent over that.
It’s 10 calendar days. What if you receive a NOREP on December 21? Send the email. Tell them you received it, and when you will return it. Even if that’s December 31. What if you don’t go back to school until January 4?
Well, seriously, what is to be gained by holding on to that NOREP from December 31 to January 4? If you’re thinking, “Well, school’s on break, why do I have to return it then?”
As your advocate, I would advise you to focus on the big picture. What is the school’s final offer of FAPE, and is it appropriate? Again, what is to be gained by holding on to that NOREP, unsigned, for a few extra days? Probably nothing.
But, let’s say you are in disagreement with their proposal of FAPE, and you’re late with your NOREP. You got busy or whatever.
You can email them and appeal to their good will.
If you are in a contentious relationship with your district, I would not expect them to oblige. They don’t have to, and if you’re already on shaky ground with them, they likely won’t.
So, you’re going to have to go the next step and file complaint options or request another meeting if applicable.
This is why it’s essential for parent to engage in every step of the process. Yep, life is hard sometimes and 10 days can go by in a flash. Again, I’ll ask you to look at that lighthouse ahead.
Should you find yourself in due process….what will it look like? Do you have documentation that you were actually going through chemotherapy or a family death during that time? Then a hearing officer might be sympathetic.
Otherwise, I would not expect it to be. It’s 10 days. Per the McAndrews Law firm website, they state it is 10 calendar days.
Writing on the NOREP
I write on NOREPs all the time.
Yes, it really wakes up IEP teams, lol. It will get their attention.
I always recommend that a parent do an After IEP Meeting Letter. You can read that article to see what I recommend you put in the letter.
On a NOREP, I put my “yeah, but….” information. I reserve it for situations where we’re (me or my client) are not in 100% agreement with the IEP, or, we probably want to pursue something in the future, just not right now.
For example, say we ask for a certain, specific intervention for a child. The school offered an alternative. We don’t love the idea, or aren’t convinced it will work. But we’re willing to try.
What we might write on a NOREP would look something like:
Dear school, I am signing that I agree with the NOREP and school district’s offer of FAPE at this time.
However, I have reservations about ABC intervention and its efficacy, and still want my child to get XYZ intervention. We’re willing to give ABC intervention a try.
I will check in with the teacher every 4 weeks to monitor progress. If we do not see meaningful progress with ABC in the next 3-4 months, I will ask the team to reconvene then to discuss XYZ again.
Sincerely, parent.
I Love NOREPs
So, after all that, yes, I love NOREPs.
I love that they are lengthy, specific documents with specific timelines.
Some states are able to wrap up the PWN with the IEP, which just gets messy. I love that a NOREP is separate and doesn’t leave anything open to misunderstanding.
I even love the 10-day timeline, because then things don’t drag on for weeks and weeks.
Special education in PA has a lot of faults. In my professional opinion, the NOREP isn’t one of them.
