DRY RUN — Findings Memo, Completed (FICTIONAL)
Prepared: October 20, 2026 · Operator: Andrew Peal, Intervention Specialist · Record window: November 6, 2025 – October 9, 2026 Family's stated goal (their words): "We want the reading help he was promised, and we want the removals to stop. We don't want to blow up his school." Record build: 14 documents (9 district/school-issued, 5 family) · Vault tags: DOC-IEP, DOC-PWN, DOC-EVAL, DOC-SVC, DOC-DISC, DOC-PROG, NOTE-MTG, LOG-REM, CORR
The current and prior IEPs, the November 2025 reevaluation, the December 2025 Prior Written Notice, school service logs for August 17 – October 9, 2026, three progress reports, the family's and the district's notes for the meetings of November 13, 2025 and September 30, 2026 and the February 9, 2026 annual review, the family's November 6, 2025 email requesting a functional behavior assessment, four suspension notices, and the family's removal messages and calendar. (Full inventory: record build, §1.)
Not provided / not available: delivery records before September 2026 (delivery before this fall cannot be measured from this record) · any manifestation determination review document · any documentation of recess or lunch arrangements. The options brief addresses how each gap can be closed.
Scores are Severity · Evidence · Deadline (each 1–3, from the record). The product sets the order the analysis works in — not importance to your family. All three findings scored 18; they are ordered below by your stated goal, and F-2 carries a date (November 13, 2026) that the options brief treats as urgent even though it appears second.
| ID | Module | Finding (facts only) | S | E | D | Score | Evidence |
|---|---|---|---|---|---|---|---|
| F-1 | Promised vs Delivered | Over 8 weeks (Aug 17–Oct 9, 2026), reading was delivered at 1,200 of 1,800 written minutes (66.7%) and speech at 360 of 480 (75%) — a combined shortfall of 720 minutes (12 hours) | 3 | 3 | 2 | 18 | DOC-SVC #5 + DOC-IEP #1 |
| F-2 | Notice Gap | 3 decisions are logged; a Prior Written Notice is in the file for 1. The two refusals (Nov 13, 2025; Sep 30, 2026) have no Notice in the file, and the one issued Notice does not mention 1 of the 7 elements the rule lists | 2 | 3 | 3 | 18 | DOC-PWN #4; NOTE-MTG #7–#10; CORR #11 |
| F-3 | DayCount | 12 removal events this school year total 10.0 day-equivalents (9.0 documented in notices and messages, 1.0 from family recollection); the total reached 10.0 on Oct 15, 2026; no manifestation determination review document is in the record | 3 | 3 | 2 | 18 | DOC-DISC #12; LOG-REM #13 |
What the record shows. Your IEP (February 9, 2026) lists direct specialized reading instruction at 225 minutes per week and speech-language at 60 minutes per week. The school's own service log for the eight school weeks from August 17 to October 9, 2026 shows reading delivered at 150, 165, 135, 150, 180, 120, 150, and 150 minutes — 1,200 of the 1,800 written minutes, a shortfall of 600 minutes (10 hours), at a delivery rate of 66.7%. Speech was delivered at 360 of 480 written minutes — a shortfall of 120 minutes (2 hours), at 75%. Both figures come from two independent sources that agree: the IEP's service grid and the school's delivery log.
The general rule. Federal rules require that special education and related services be made available in accordance with the child's IEP (34 CFR 300.323(c)(2)). · Confidence: Verified rule (federal core pack, verified October 1, 2026).
Side by side. The IEP promises 225 reading minutes a week; the school's log shows an average of 150 delivered across the eight measured weeks. At the September 30, 2026 meeting, the team attributed the gap to a specialist vacancy and offered to revisit in January (both note sets agree). This may conflict with 34 CFR 300.323(c)(2).
What this finding is not. Whether missed minutes call for any particular remedy is a determination this memo does not make — it is for you, your advocate, or your attorney. The memo also cannot say anything about delivery before August 17, 2026: no log for that period is in the record.
What the record shows. Three decisions are documented in your file. (1) On November 6, 2025 you requested a functional behavior assessment in writing; at the November 13, 2025 meeting the district declined — your notes and the district's own meeting summary both record the request and the refusal. No Prior Written Notice for that refusal is in your file. (2) On December 8, 2025 the district proposed reducing speech from 90 to 60 minutes per week and did issue a Notice; measured against the elements the rule lists, that Notice states the action, the reasons, and the data relied on, and does not mention the options the district considered and why they were rejected. (3) On September 30, 2026 you requested make-up reading minutes; the team declined, citing the vacancy — again recorded in both note sets. No Prior Written Notice for that refusal is in your file.
The general rule. Federal rules require a Prior Written Notice whenever a district proposes or refuses to initiate or change the identification, evaluation, placement, or the provision of a free appropriate public education to a child, and they list what the Notice must contain — including a description of other options the team considered and the reasons those options were rejected (34 CFR 300.503(a)–(b)). · Confidence: Verified rule (federal core pack, verified October 1, 2026).
Side by side. Your file shows two refusals and no Notice for either; the one Notice in the file addresses six of the seven listed elements and does not mention the options-considered element. As documented, these gaps may conflict with 34 CFR 300.503(a)–(b).
The date attached to this finding. The state-complaint rule covers issues from within one year of filing (34 CFR 300.153(c)). The November 13, 2025 refusal reaches that one-year line on November 13, 2026 — 24 days after this memo. The options brief treats that date as the most urgent fact in your case. An attorney can confirm what filing by that date preserves.
What the record shows. Twelve removal events between August 27 and October 15, 2026: six early pickups initiated by the school, two days sent home, and four suspensions totaling 5.0 days, including a two-day suspension on October 8. Counted the way the record-keeping module counts partial days, the year totals 10.0 day-equivalents — 9.0 supported by notices and messages, 1.0 (two September pickups) resting on your calendar recollection. The total reached 10.0 with the October 15 suspension. No manifestation determination review document is in the record for any removal, including that one.
The general rule. Federal rules treat a series of removals totaling more than 10 school days in a school year as a disciplinary change of placement when the removals form a pattern, and they require a manifestation determination review within 10 school days of a decision that results in such a change (34 CFR 300.536; 34 CFR 300.530(e)). · Confidence: Verified rule (federal core pack, verified October 1, 2026).
Side by side. Your log shows 10.0 removal day-equivalents this year and no manifestation review document in your file. Whether the pattern and review requirements apply to these removals is a determination this memo does not make; what the record supports is the count, the dates, and the absence — and those may conflict with 34 CFR 300.536 and 300.530(e) as documented.
Where the record supports two readings. Your reading, in your words: "The October calls and suspensions came right after we pushed back on September 30 — it feels like pushback." This memo's reading of the same facts: the removal rate was elevated all fall (events 1–9 precede and follow no single meeting), and the record shows sequence, not motive. Both readings are recorded here because the record cannot settle between them. If new facts support yours, the options brief's escalation section is written to change.
Your options brief (separate document, October 21, 2026) lays out the paths this record supports and carries my signed recommendation — including why the November 13 date changes the usual order of steps. The Evidence Packet delivered with this memo is your complete record, yours to hand to any advocate, attorney, or mediator — including, as the brief recommends, an attorney before November 13.
General information, not legal advice. This document organizes your own records and states general rules with citations. It does not determine your child's legal position. For advice about your child's situation, consult a special education advocate or attorney. Rules cited as verified on the dates shown with each citation. Federal rules verified October 1, 2026 · Ohio rules verified October 15, 2026.