Vermont Assigned Status of “Needs Intervention” in Serving Children with Disabilities

The US Department of Education (USED) has assigned Vermont the status of "Needs Intervention" to comply with the federal Individuals with Disabilities Education Act (IDEA) based on data from the 2023-2024 school year.

The Office of Special Education Programs (OSEP) at USED performs annual reviews of each state's compliance with IDEA and assigns a status based primarily on student outcomes for children with disabilities as well as other compliance indicators. Reading and math proficiency along with graduation and dropout rates among children with disabilities in 2023-2024 contributed significantly to USED's determination of "Needs Intervention" for Vermont in 2026. Validity of data and longstanding noncompliance in select indicators also contributed to the determination.

There are four categories of USED determinations for states under IDEA: "Meets Requirements," "Needs Assistance," "Needs Intervention," and "Needs Substantial Intervention." Prior to this year's determination, USED assigned Vermont a status of "Needs Assistance" for five consecutive years, following a status of "Needs Intervention" in 2020. The last time USED assigned Vermont a status of "Meets Requirements" was 2018, based on data from the 2015-2016 school year.

If Vermont remains in this status for three or more consecutive years, USED may take enforcement action, including the withholding of a certain percentage of IDEA B funding for Vermont schools.

Vermont's Commitment to Serving Children with Disabilities

Prior to receiving the federal determination, the Agency of Education initiated comprehensive, systemic reforms aimed at overhauling special education delivery across Vermont. These extensive improvement efforts were launched proactively, driven by an internal commitment to elevate the quality of services and outcomes for students with disabilities rather than in response to federal regulatory pressure.

"The federal determination underscores the urgency of the work the Agency had already chosen to confront months ago," stated Vermont Secretary of Education Zoie Saunders. "The Agency has initiated a comprehensive review of decade-long compliance issues and elevated special education as a core priority to strengthen how we support students with disabilities. The structural reforms currently underway reflect that commitment."

Significant progress has been achieved through these self-initiated measures:

• Proactive Systemic Assessment: In September 2025, the Agency conducted a rigorous internal review, publishing the Current State of Special Education Delivery report to transparently identify system strengths, challenges, and opportunities. This was followed in December 2025 by the publication of the Special Education Strategic Plan, a comprehensive framework designed to exceed baseline compliance and secure academic excellence for all learners.
• Instructional Enhancement via Act 173: To ensure immediate classroom-level impact, the Agency established a dedicated working group in partnership with local practitioners. This collaborative effort launched a renewed focus on the implementation of Act 173, with a particular emphasis on strengthening core instruction.
• Rigorous Local Oversight: The Agency proactively enhanced its oversight of longstanding noncompliance at the local level. Supervisory unions and school districts with unresolved compliance issues regarding IDEA indicators 11 and 13 were required to engage in mandatory root-cause analyses and structured corrective action planning.
• Methodological Correction for Equity: Recognizing limitations in legacy monitoring systems, the Agency took the initiative to update Vermont's Significant Disproportionality methodology under the Individuals with Disabilities Education Act (IDEA). Following a public comment period, the Agency issued a directive to replace a flawed methodology utilized since 2020. This correction ensures a more accurate, equitable evaluation of whether students from specific racial or ethnic groups are disproportionately identified for special education, placed in restrictive settings, or disciplined.

Additionally, the Agency has continued to deepen its strategic partnerships with key special education organizations throughout the state to ensure local administrators and educators are fully supported during this transition.

"The efforts launched by the Agency prior to this determination provide a clear and necessary path forward," said Mary Lundeen, Executive Director of the Vermont Council of Special Education Administrators (VCSEA). "By proactively addressing systemic challenges and correcting historical methodologies, the state is establishing a more reliable framework for equity and accountability. VCSEA will continue to work hand-in-hand with the Agency to support local leadership as these critical, ongoing reforms are executed across our school districts."

While the federal determination highlights ongoing challenges, the Agency remains fully engaged in the execution of these pre-established reforms to ensure sustainable, high-quality support for all eligible Vermont students.

Federal Uncertainty

The determination by USED comes at a time of significant uncertainty at the federal level. Last year, USED temporarily withheld a series of federal funding allocations and initiated efforts to dismantle USED by laying off staff and shifting management of education programs to other federal agencies. Last month, USED announced an "interagency agreement" (IAA) between USED and the Department of Health and Human Services (HHS) to shift administration of some special education programs from USED to HHS.

USED has stated that the IAA will not impact oversight of compliance with IDEA. However, the Vermont Agency of Education recognizes that this decision contributes to a culture of uncertainty, including questions about support for children with disabilities.

Vermont's commitment to serving students with disabilities will endure any actions by the federal administration. Regardless of actions at the federal level, the Agency will continue to uphold state and federal law as well as our moral and constitutional obligation to meet the individual educational needs of every student in Vermont.

At a time of significant uncertainty at the federal level, Vermonters should know that state leaders remain committed to championing educational quality in every classroom and providing the stability that schools, educators, and families deserve. The Agency will continue to closely follow developments at the federal level and will remain in close coordination with our congressional delegation and national partners to support the interests of Vermont's students.