Written State Complaints: New and Improved with Ai!
Jan 07, 2025This month, I’m all about written state complaints. I’m publishing a series of articles on state complaints in my weekly column, IDEAs on Education, on the Jolt. I’m also providing free training for the Benton-Frankly Special Education PTA on state complaints, and I have a 3 part workshop on complaints (aaaaand work groups for those that complete the workshops). It is a busy month!
In every article in The Jolt, I encourage intentional, careful and responsible Ai use to better understand special education. In my blog posts this month, I’m going to demonstrate how Ai can assist you in 1) understanding special education state complaint decisions and 2) preparing a written state complaint.
In my January 9 article, SECC Part 2: You Always Win, I encouraged my readers to use Ai to teach them to write complaints. The first step is to find complaints that are similar to their own issues, and download the decisions as PDF documents. Then, upload those PDFs to an Ai. I provided my readers with the following prompt:
Act as an analyst investigating trends in special education issues. The goal is to glean insights from the complaint I have uploaded to teach me to write a strong complaint. This is a three step request. Use only the attached PDF for the first and second steps. Step 1: Using the attached PDF, list the issues, legal standard, and WAC code. Step 2: Using the attached PDF, provide examples of evidence that the complainant used to support their allegations. Step 3: Give examples of documents that should have been included, or documents that would have supported the claims.
I’ve used this prompt to analyze two complaints that list “IEP Implementation” as an issue. While many of the complaints list other problems, I’ll detail those in future posts. Here is a table of the Ai response:
SECC |
Issues |
Legal Standard |
WAC Code |
Evidence Provided in the Complaint |
Suggestions for More Evidence |
Did the Student's IEP team appropriately document transportation and related nursing services in the May 2023 IEP? |
IEP must contain a statement of special education services, related services, and supplementary aids |
WAC 392-172A-03090 |
- May 2023 IEP stating "access to nurse enroute to/from school and at school" as an accommodation - May 2023 IEP listing 575 minutes a week of nursing services in the general education setting - May 2023 IEP stating the Student required general transportation |
- Previous IEPs for comparison - Medical documentation detailing the Student's specific transportation needs - Written communication between parents and school discussing transportation needs - Minutes from IEP meetings discussing transportation needs - District policies on special transportation services - Documentation of the air-conditioned bus requirement |
Lessons Learned: Types of Documentation
Families tell me that they have no idea where to begin when writing a state complaint. I agree: It’s daunting. I find that mapping the problems helps get the ball rolling… and then the ball kinda hits a brick wall called, “Documentation.” What documents help? What does the district have that a parent doesn’t know about? How can parents locate or develop more evidence? Ai, here, is a lifesaver.
Think of it as a checklist in progress - you should be checking off the items you have, as well as adding new items to the checklist. According to Ai’s analysis of these two community complaints, the document checklist would look something like this:
- Current IEP
- Previous IEPs
- Medical/therapist/outside provider documentation detailing the Student's specific __________________need
- Updated IEP clearly stating _____ need
- Documentation of IEP team discussions about _______________________
- Written communication between parents and school discussing ______________ need
- Minutes from IEP meetings discussing ________ need
- District policies on _______________________
- Documentation of other, related requirement
Now ask yourself: Do you have documents for each of these 9 areas? If not, you can obtain most. Send an email - boom! Take notes at IEP meetings, and share those with the school - boom! And school district policies should be in your binder. If not, go through the district and school websites. Done! Three sets of documents.
And, um, by the way, do you notice a pattern here? Each set of documents represents communication with the school, understanding school policies and procedures, collaborating with the team, and connecting the school with outside services. There is a reason for that: State complaints are a dispute resolution option. When you file a complaint, your documentation demonstrates that you have tried very hard to resolve this disagreement with the IEP team, school and district. Many times, generating and collecting this information resolves the dispute along the way!