Unpacking Massachusetts Department of Elementary and Secondary Education's Letter of Finding for PRS 15836
Filed against Mount Greylock Regional School District. Six missed OT sessions. One acknowledged service gap. Three hours of compensatory OT. On paper, PRS 15836 looks straightforward. And yet . . .
June 12, 2026, Massachusetts Department of Elementary and Secondary Education’s Problem Resolution System (PRS) found Mount Greylock Regional School District (MGRSD) failed to implement a student’s IEP. MGRSD acknowledged the student missed six 30-minute OT sessions because no provider was available. PRS ordered three hours of compensatory OT.
That should have been the simple part.
However . . .
The trouble started when PRS decided what it would, and wouldn’t, investigate.
Let’s Start with the “Request for Local Response”
The parent’s complaint raised three overlapping allegations involving two points in time. The first concerned MGRSD’s decision to treat the student’s OT as suspended after the provider became unavailable. The second concerned MGRSD’s response after the parent learned of the suspension and requested an IEP Team meeting.
The parent alleged the following in her complaint:
“1. Failure to Implement the IEP
“(34 C.F.R. § 300.323; 603 CMR 28.03(3))
“The District failed to fully implement Morgan’s accepted IEP by suspending Occupational Therapy services.
“Under federal and Massachusetts law, the District must ensure that all services in the IEP are delivered as written. Staffing shortages or provider absences do not excuse non-implementation.
“2. Failure to Convene the IEP Team
“(34 C.F.R. § 300.324; 603 CMR 28.04(2))
“The District made a material change to [Student]’s service delivery—specifically, stopping OT services—without convening the IEP Team.
“Massachusetts regulations require that the Team, including the parent, determine any changes to services. The District also failed to respond to my request for a Team meeting, violating procedural requirements and my right to participate in educational decision-making.
“3. Failure to Provide Prior Written Notice (N1)
“(34 C.F.R. § 300.503; 603 CMR 28.05(1))
“The District failed to provide required Prior Written Notice (N1) regarding:
The suspension of OT services (a change in the provision of FAPE); and
Its refusal or failure to act on my request for an IEP Team meeting.
“Massachusetts requires districts to provide written notice whenever they propose or refuse to initiate or change the identification, evaluation, placement, or provision of FAPE.”
April 15, 2026, PRS issued its Request for Local Response (RFLR). It stated it would investigate the following:
“Whether the District provided the Student with occupational therapy (“OT”) services in accordance withs [sic] her Individualized Education Program (“IEP”) during the 2025-2026 school year between when the period without an OT provider began and April 13, 2026.”
PRS also stated it wouldn’t review the following:
“1. The Complainant alleged that the District failed to reconvene the IEP Team and did not provide prior written notice in response to the Complainant’s requests from March 2026 and April 2026.”
PRS explained:
“The Department will not investigate this matter further because there was no alleged noncompliance of state or federal education laws or regulations. There is no specific timeline required by state or federal regulation regarding reconvening the IEP Team upon parental request.”
Concern:
PRS reduced several distinct legal questions to one timing issue.
The parent didn’t just allege that MGRSD missed a fixed deadline for holding an IEP team meeting. The parent alleged that MGRSD first suspended a required IEP service without convening the IEP team or issuing prior written notice. The parent then requested an IEP team meeting, but MGRSD neither convened the meeting nor issued prior written notice stating that it was refusing the request.
The complaint therefore raised two sets of IEP team meeting and prior written notice questions.
First, was the OT suspension just a failure to implement an unchanged IEP, or was it also a service-delivery decision that required IEP team involvement or prior written notice?
Second, did MGRSD’s response amount to a refusal to reconvene the IEP team and, if so, did that refusal require prior written notice?
It’s correct that IDEA doesn’t prescribe one fixed number of days for every parent-requested IEP Team meeting.
However, U.S. Department of Education (ED) guidance states that a parent may request an IEP team meeting at any time. If the LEA refuses the request, it must provide written notice explaining why it believes a meeting isn’t necessary to ensure FAPE. IDEA also requires prior written notice a reasonable time before a public agency proposes or refuses to initiate or change the provision of FAPE.
IDEA also allows changes to an IEP after the annual meeting without reconvening the full IEP team when the parent and public agency agree to develop a written amendment. However, prior written notice is still required when an IEP is amended without an IEP meeting.
So . . .
The absence of a fixed meeting deadline didn’t dispose of the allegations.
PRS still needed to determine whether MGRSD’s suspension of OT was solely a failure to implement an unchanged IEP or also a service-delivery decision that triggered an IEP team meeting or prior written notice requirements.
It separately needed to determine whether MGRSD’s response to the parent amounted to a refusal to convene the IEP team and, if so, whether prior written notice was required.
It didn’t.
When the parent later submitted additional information explaining that the interruption occurred outside the IEP team process and without an N1, PRS responded:
“As a reminder, PRS is investigating the following issue in PRS 15836: Whether the District provided the Student with occupational therapy (‘OT’) services in accordance withs [sic] her Individualized Education Program (‘IEP’) during the 2025-2026 school year between when the period without an OT provider began and April 13, 2026.”
IDEA requires a state complaint to identify an alleged violation and provide the supporting facts. It doesn’t require a parent to identify every applicable regulation or draft a perfect legal brief.
The parent provided the facts.
PRS still had to apply the correct law to them.
Instead, it removed issues from the investigation.