IRLP Individual Remote Learning Plan
Yesterday a blog reader asked if I could further explain IRLP. IRLP stands for Individual Remote Learning Plan. It’s a new concept and document as a result of the pandemic. And, I am going to explain what an IRLP is, however, I do so with great hesitation.
And that is because, an IRLP is a state thing. There is no mention of it anywhere in IDEA. Also, because IRLP is such a new concept, there is no case law supporting any enforcement around it. There are so many what-ifs that could happen around an Individual Remote Learning Plan. It makes me nervous to discuss them. Please, check your state regs about this! I will include my spreadsheet to all the states at the end of this post.
IEPs vs. IRLPs : What’s the Difference?
What is an IEP?
An IEP is the Individualized Education Program for a student with a disability, ages 3-21. I have discussed IEPs ad nauseum on this blog so pretty much anything you want to know, use the search bar.
Are IEPs valid during school closures?
Yes, per the US Dept of Ed memo from March, 2020, there are no waivers to IDEA. However, some states developed Individual Remote Learning Plans to identify and document the instruction and services that will be provided during school closures. It is a separate document that is based on the IEP but is responsive to the unique circumstances of remote learning. It may be different from the IEP.
From the memo:
“If an LEA continues to provide educational opportunities to the general student population during a school closure, the school must ensure that students with disabilities also have equal access to the same opportunities, including the provision of FAPE. ( (34 CFR §§ 104.4, 104.33 (Section 504) and 28 CFR § 35.130 (Title II of the ADA)). SEAs, LEAs, and schools must
ensure that, to the greatest extent possible, each student with a disability can be provided the special education and related services identified in the student’s IEP developed under IDEA, or a plan developed under Section 504. (34 CFR §§ 300.101 and 300.201 (IDEA), and 34 CFR § 104.33 (Section 504)).”
Are IEPs changed when Individual Remote Learning Plans are created?
Yes and no. I don’t like the word changed. I prefer to think of an IRLP as a temporary IEP. Due to logistics of the pandemic and distance learning, some parts of an IEP will need to be paused, for some students. However, it should be clearly documented that those goals, supports and services will be taken up again when learning returns to normal.
An example of this would be my son and his CBI Community Based Instruction goals and supports. Obviously he is not going on CBI outings with his instructors during distance learning. But I expect new baselines and goals for CBI related activities when he returns to in-person learning.
Do not agree to or sign a PWN for an IRLP unless it clearly states that your child goes back to what they had after the pandemic.
What is an Individual Remote Learning Plan?
An Individual Remote Learning Plan is an alternative plan for providing FAPE while schools are not offering in-person learning. An IRLP is defined state by state, and not all states have defined one. Please check your state’s regs (below).
Different names for these plans:
- IRLP Individual Remote Learning Plan
- RLP Remote Learning Plan
- Form G (thanks Missouri!)
- RLS Remote Learning Schedule
- SERLP Special Education Remote Learning Plan
Just what we needed, more special education acronyms to learn.
An Attorney’s Take on Remote Learning Plans
An attorney contacted me after reading this. Note, I am not a lawyer nor do I play one on the internet. This is intended as general guidance and not legal advice.
My Thoughts on the Legal Side. Any way you slice the IDLP/IRLP dynamic, it is nothing more than an amendment to the IEP. By agreeing, the parents are consenting to whatever is in the document. If this reduces services, then parents may lose the ability to remedy the situation when the school isn’t eager to reinstate the prior IEP plan. I suspect there are thousands of parents who unknowingly reduced or eliminated services for their children. Time will tell, but I believe we will see a significant increase in IEP plan issues in the near future when people begin to realize what has occurred. I would strongly advise anyone that has agreed to a IDLP/IRLP plan to immediately call another IEP meeting and request (demand) that the file include something from the parent explaining they did not understand what was happening and listing the reasons why (i.e. “The district called these IRLP meetings without explaining they sought to amend the IEP plan…”)
Why are Individual Remote Learning Plans necessary?
They are not unless a state has specifically said that it is. IDEA and the March Memo say that all students with disabilities from ages 3-21 must have equal access to the same educational opportunities provided to all students during school closures. This means that special education and related services must continue to be provided to the greatest extent possible.
Why I’m leery of IRLPs
I’m always nervous about removing supports and services from an IEP, particularly when no evaluations or assessments have been done. We are going to be in some tough financial times in the coming years. I fear that we are going to have a flood of IEP parents who agreed to not have a 1:1 while doing distance learning, agreed to pause CBI, agreed to reduce the amount of related services, and then will have trouble getting them back on the IEP.
All I can say to parents is document, document, document. Your adequate paper trail is what is going to make your life easier when kids return to the classrooms.
Shameless Plug: The IEP Planner has a dozen pages created just for monitoring your child during the pandemic!
Who creates a Individual Remote Learning Plan?
Again, this is not an IDEA thing. As such, you will not find a defined IRLP team as you do with an IEP team. Personally, I would expect it to reasonably resemble the IEP team.
Can my child’s Special Education Remote Learning Plan be changed?
Yes, IEPs are always a living document that changes as your child’s needs change. You should still receive progress monitoring and provide feedback to your team as far as what is working and what isn’t. If the learning environment has changed, as it has for most remote learning students, needs may change.
Is an Individual Remote Learning Plan written at an IEP meeting?
The IEP team may create a IRLP following or during an IEP meeting, but an IEP meeting isn’t required to create a Remote Learning Plan. Again, this is not defined by IDEA and there is no case law around it, yet.
From the Dept of Ed:
The IEP team may, but is not required to, create an IRLP plan for a student that could be implemented during disruptions to in-person instruction due to the pandemic. “Such contingent provisions may include the provision of special education and related services at an alternate location or the provision of online or virtual instruction, instructional telephone calls, and other curriculum-based instructional activities, and may identify which
special education and related services, if any, could be provided at the child’s home.”
My school isn’t offering a separate plan. Can I still ask for one?
Yes, absolutely. Any time a parent wants to discuss the IEP or suggest changes to the IEP, you are permitted to do so. You either formally request an IEP meeting in writing, or write up your proposed IEP changes and submit them as an IEP no-meet addendum.
Your IEP doesn’t necessarily have to change due to the pandemic. However, if needs and learning environment has changed, it’s probably necessary.
My school sent me a Remote Learning Plan and I don’t agree with it.
Your options are (pretty much) the same as always. I say pretty much and put it in parentheses, because not all things are going to be possible during the pandemic.
For example, COVID restrictions may prohibit some small group gatherings, like a social skills group or lunch bunch. You cannot demand, during a pandemic, that a school provide other kids for yours to socialize with.
Or, hands-on physical therapy, things like that.
If removing services is a concern for you, make sure that is clearly noted on both the IEP and PWN. “Only agreeing to implement this IEP for the duration of distance/hybrid learning and COVID restrictions. I will be asking to return to the most recently agreed-upon IEP, dated x/x/xx when in-person schooling returns.”
How can I be my child’s best advocate during the IRLP process?
- Stay involved and in the loop. Monitor your email, phone messages, and mail. Be responsive.
- Document, document, document. Keep notes and dates of therapy sessions and online learning. Discuss any concerns with teachers and therapists. Ask for progress reports.
- Engage your child in the process. Seek their feedback. Ask them what is working, what isn’t, what could be changed.
- Read your state regs about this as well as your IEP Procedural Safeguards.
- Remember, IDEA is not waived. All principles apply.
- Go with your gut. Parental instincts are rarely wrong. When challenged with a “well, we have to…” put the onus on them. “Can you show me where it says that?”
What States are doing IRLP?
Here are the state regs for Special Education for every state.