IEP Modifications in Washington: Accommodations vs. Modifications
What is the difference between accommodations and modifications in a Washington IEP?
In Washington State, modifications are changes to the curriculum, instruction, or assessments that alter the content or performance expectations for a student with a disability. Under WAC 392-172A-03090(1)(e), the IEP must include program modifications. Under WAC 392-172A-03090(1)(f), the IEP must include an explanation of the extent to which the student will not participate with nondisabled students in the general education class and in extracurricular and nonacademic activities. Students who have the most significant cognitive disabilities and cannot participate in the regular state assessment even with accommodations may take the WA-AIM alternate assessment; the IEP team must document this determination (WAC 392-172A-03090(1)(h)). Washington offers two diploma pathways relevant to students with disabilities: the Certificate of Academic Achievement (standard diploma) and the Certificate of Individual Achievement, which may be earned by students who complete their IEP goals but do not meet standard assessment requirements (RCW 28A.655.061). FAPE continues until the student graduates with a regular diploma, ages out at 21 (or 22 for certain students pursuant to the N.D. v. Reykdal settlement, 2023), or the IEP team determines ineligibility.
What Washington Requires
The IEP must document all program modifications and explain the extent to which the student will not participate with nondisabled peers in general education, extracurricular, and nonacademic activities (WAC 392-172A-03090(1)(e)-(f)).
For state assessments, if the student takes the WA-AIM alternate assessment, the IEP must explain why the student cannot participate in the regular assessment and why the alternate is appropriate (WAC 392-172A-03090(1)(h)).
The IEP team must consider LRE before recommending modifications that remove a student from general education (WAC 392-172A-02050).
Washington provides a Certificate of Individual Achievement for students who complete their IEP goals but do not meet standard diploma requirements; a separate Certificate of Academic Achievement is the standard diploma pathway (RCW 28A.655.061).
Modifications must be based on peer-reviewed research to the extent practicable (WAC 392-172A-03090(1)(e)).
Key Timelines
Modifications must be reviewed at least annually as part of the IEP review (WAC 392-172A-03110(2)).
FAPE ends upon graduation with a regular diploma, age 21 (or age 22 for certain students under the N.D. v. Reykdal settlement), or a determination of ineligibility (WAC 392-172A-02000(2)(b)).
For students with potential diploma pathway concerns, the IEP team should address this well in advance of the expected graduation date.