Information Update Bulletin 26.01

Introduction

Transition planning is the process that supports students with disabilities and their families to think about and prepare for life after high school. The process helps students identify long-range goals, designing the high school experience to ensure that students gain the skills and connections they need to achieve these goals after high school. In Wisconsin, transition planning requirements begin in the first individualized education program (IEP) that will be in effect when the child is 14 (or sooner if appropriate) and are updated annually thereafter. The transition requirements are found in Wisconsin Statute 115.787(2)(g)1 and IDEA 34 CFR § 300.320(b) .

The Individuals with Disabilities Education Act (IDEA) and Chapter 115 of the Wisconsin State Statutes provide students with IEPs the right to a free and appropriate public education (FAPE) until the student either earns a regular high school diploma or reaches maximum age. Transition planning and the services delivered to students as a part of this planning are critical in supporting a student’s progress towards graduation and life after high school. This information bulletin is written to provide additional information about the LEA’s responsibilities in transition planning and should be considered in complement to DPI Information Bulletin 10.08:  High School Graduation and Students with Disabilities.

Section B of this bulletin focuses on providing transition services to students with IEPs who stay in school beyond age 18. IEP teams need to carefully design individualized programming during this phase of education to ensure a student continues to make adequate progress. The Transition Improvement Grant (TIG) provides extensive guidance to support IEP teams in designing effective beyond age 18 programming. Additionally a November 2025 TIG webinar addresses the most common beyond age 18 questions, solutions, and best practices for IEP teams.

For the purposes of this document the following definitions of parent, adult student and legal decision maker are utilized.

Parent

Wisconsin State Statute defines a parent as:

1. A biological parent.
2. A husband who has consented to the artificial insemination of his wife under § 891.40.
3. A male who is presumed to be the child’s father under § 891.41.
4. A male who has been adjudicated the child’s father under subch. VIII of Ch. 48, under subch. IX of Ch. 767, by final order or judgment of an Indian tribal court or competent jurisdiction or by final order or judgment of a court of competent jurisdiction in another state.
5. An adoptive parent.
6. A legal guardian.
7. A person acting as a parent of a child.
8. A person assigned as a surrogate parent under § 115.792(1)(a)2.
9. A foster parent, if the right and responsibility of all of the persons specified in subds. 1. to 5. to make educational decisions concerning a child have been extinguished by termination of parental rights, by transfer of guardianship or legal custody or by other court order, and if the foster parent has an ongoing, long-term parental relationship with the child, is willing to make the educational decisions that are required of a parent under this subchapter and has no interests that would conflict with the interests of the child. [Wis. Stat. § 115.76(12)(a), Wis. Stats.]

Additional details on how state and federal laws define a “parent” can be found in the

Adult Student

 A student who has reached the age of majority (age 18 in Wisconsin), who has not been found by a court to be incompetent, and who now has the rights given to the parent(s) under state and federal special education law. Wis. Stat. § 115.807(3).

Legal Decision Maker

An individual who has been appointed as responsible for making legal decisions for a student that has reached the age of majority (18 in Wisconsin). This may include an individual appointed as a guardian or may be included as part of a supported decision-making agreement. There is a spectrum of decision-making options that support adult students in making legal decisions. More information on decision making options can be found on the Wisconsin Board for People with Developmental Disabilities website.

Bulletin sections:

1. Transition Planning and Services
2. Making Beyond Age 18 Transition Planning and Service Decisions
3. Dropout Considerations

Section A: Transition Planning and Services

1. What is a Postsecondary Transition Plan (PTP)?

A Postsecondary Transition Plan (PTP) is a required component of an Individualized Education Program (IEP) and is developed during an IEP team meeting for students with disabilities. Postsecondary transition goals are based on age-appropriate transition assessments and written in the areas of education and training, employment, and, where appropriate, independent living skills. An age-appropriate transition assessment must be used to develop goals in the initial transition plan. Additional transition assessments can inform future updates to a student’s transition plan; however, they are not required.  The PTP must also include the transition services and a rigorous course of study needed to assist the child in reaching those goals.

In developing the transition plan the IEP team should also consider the information collected as a part of the Academic and Career Planning (ACP) process. The ACP process begins in 6th grade for all students and therefore provides a critical opportunity for students with disabilities to explore options for life after high school prior to the initiation of the transition planning process at age 14. The 

provides further details on how the ACP and transition planning processes are connected.

2. How are PTPs written in Wisconsin?

Wisconsin state statute requires Postsecondary Transition planning to begin for students with IEPs during the IEP year in which the student turns 14. PTPs are updated at least annually using DPI’s Postsecondary Transition Plan (PTP) online application. Local Education Agencies submit annual PTPs to DPI within 30 days of the student’s IEP meeting. The PTP application includes several reports and resources that enable LEAs not only to comply with federal transition planning requirements but also to improve the quality of transition services delivered to students locally.   PTPs are developed by the IEP team through discussion that includes the student and the parents or legal decision maker as well as outside agencies when applicable.

3. What are transition services?

Transition services are a coordinated set of activities for students with IEPs, designed to improve academic and functional achievement to facilitate the transition from school to post-school life. Transition services are coordinated to provide experiences, build skills, and connect to appropriate supports that will allow the student to meet their postsecondary goals upon exit from school. The determination of specific transition service needs is based on the individual results of age-appropriate transition assessments and the IEP team planning process.

 The 

requires school districts and the Department of Workforce Development’s Division of Vocational Rehabilitation (DWD-DVR) to collaborate to provide Pre-Employment Transition Services. Transition services and pre-employment transition services (Pre-ETS) are interchangeable terms in regards to WIOA. IEP teams are encouraged to support students with IEPs and their families to engage with DVR about two years prior to the student leaving school. DVR can serve students with IEPs earlier when appropriate and the student is ready to work.

WIOA defines six categories of transition services including:

• Job Exploration Counseling Services
• Work Based Learning Experiences
• Postsecondary and Higher Education Related Services
• Social and Independent Living Skills for Home
• Social and Independent Living Skills for Community
• Instruction in Self Advocacy

4. What is a Local Education Agency’s (LEA’s) responsibility for providing transition services?

A Local Education Agency has a responsibility to develop and implement a student’s transition plan as well as to prepare students to meet postsecondary goals when they leave high school. This responsibility includes providing at least one transition service annually, coordinating with outside agencies, and developing a rigorous course of study that will enable students to meet their individual postsecondary goals.

5. Does the student’s parent or legal decision maker need to be made aware of what is in the PTP?

Yes, the student’s parent/legal decision maker needs to be made aware of what is in the PTP under both federal law (IDEA) and Wisconsin state law. In addition, students and parents are an integral part of developing a student’s PTP. A copy of the PTP must be provided to the parents or the adult student with each annual IEP plan.  Each public agency must invite the student and parent to an IEP meeting in which transition will be discussed. If the student does not attend the IEP meeting, the IEP team must document how the student’s interests and preferences were used to inform the transition plan.  The role of parents or legal decision makers in the transition planning process is further defined in the Transition Action Guide.

An adult student who is their own guardian, may express in writing when they no longer wish to include parents in the IEP process. In this instance, the educational rights transfer to the student and a copy of the PTP should be provided directly to the adult student.

6. How are PTPs updated annually?

PTPs are required to be updated annually as part of the IEP review process. PTP updates are determined through the gathering of information from IEP team meetings, review of the existing IEP plan, gathering information from key transition partners including: the student, parents, teachers, and other stakeholders. Using that information, IEP teams adjust goals and services based on the student’s progress, and document changes in the revised PTP. LEAs must submit each transition-aged student’s PTP in the online PTP application within 30 days of the annual IEP meeting.

7. What is the LEA’s responsibility for ensuring a student with an IEP meets their postsecondary transition goals?

The LEA is responsible for ensuring a student with an IEP is prepared to meet their postsecondary goals upon exit from high school. Preparing a student to be ready to exit high school requires a coordinated set of activities and support from the LEA, outside agencies, parents, legal decision makers, and other transition partners. The LEA has a responsibility to initiate the transition planning process and facilitate that process until the student exits high school while other transition partners may be a part of providing and or funding transition services while the student is still in high school.

8. Do outside agencies have a responsibility to provide transition services?

Yes, outside agencies have a responsibility to provide transition services, if a student is found eligible, in coordination with the LEA. Including outside agencies and transition partners in the transition planning process promotes effective long-term planning.

An IEP team can list an outside agency as responsible for providing a transition service in a student’s PTP; however, it is up to the LEA to ensure that service has been provided.  If a transition service will be funded by an outside agency during an IEP year, a representative from the outside agency must be invited to the IEP meeting with written consent from the parent, legal decision maker, or adult student. The Transition Action Guide further defines the roles and responsibilities of outside agencies in the transition process.

Section B: Making Beyond Age 18 Transition Planning and Service Decisions

9. Does a student remain eligible for special education past age 18 or 12th grade?

Yes, a student with an IEP can stay in school past age 18 or their senior year if the IEP team determines it is appropriate. The IDEA allows students with disabilities to remain in school until they reach maximum age or graduate with a regular high school diploma, whichever comes first.  Wisconsin State Statute 115.76(3) defines maximum age as the end of a school term during which the student turns 21 years old. If a student turns 21 prior to the beginning of a school term, the student’s maximum age will be reached in the previous school year. School term means the time commencing with the first school day and ending with the last school day that the schools of a school district are in operation for attendance of pupils in a school year, other than for operation of summer school. Wis. Stat. § 115.001(12). A regular high school diploma is defined as the standard high school diploma awarded to the preponderance of students and does not include a general equivalency diploma, certificate of completion, certificate of attendance, or similar types of documents. 34 CFR 300.102(a)(3)(iv).

In most instances, students with IEPs will graduate in the four-year cohort much like their peers without disabilities. However, if the student has not met state and local requirements to earn a regular high school diploma or has not met their individualized IEP goals, the student remains entitled to a Free and Appropriate Public Education (FAPE).  For these students, there are important considerations for IEP teams to make to ensure a student’s right to FAPE is met, as well as to prepare the student to reach their postsecondary goals in the areas of education, training, employment, and as necessary, independent living.  More information on designing special education instruction and services beyond age 18 can be found in the TIG Transition Planning Beyond Age 18 resource. Additionally, information on graduation and diploma requirements for students with IEPs can be found in DPI Bulletin 10.08.

10. How do LEAs decide if a student with an IEP should stay in school beyond age 18?

IEP teams decide if a student with an IEP should stay in school beyond age 18 based on the student’s individualized needs, goals, and progress toward postsecondary goals. Students with disabilities are entitled to receive special education services until they receive a high school diploma or through the end of the school year in which they turn 21, whichever comes first. The IEP team consists of the student, the student’s parents, educators, and service providers. In making this determination, the IEP team should consider the student’s individual progress and preparedness to meet their postsecondary goals upon exiting school. This consideration should also include the connection to appropriate services that may support the adult student after leaving high school.

11. How does an IEP team decide if a student is ready to exit school?

An IEP team decides if a student is ready to exit school based on several factors including the student’s individual progress and connections to adult services and supports. The decision of when a student exits school should be individualized and consider input from all IEP team members including the student, if able. If the IEP team has data to support that the student is prepared to meet their postsecondary goals, is connected to the appropriate services and supports, and the LEA has established a gradual release of support, then the student may be ready for exit from high school.

12. What is the LEA’s responsibility for transition services beyond age 18?

A LEA has a responsibility to provide specially designed instruction and transition services that enable a student with an IEP to make adequate progress in their IEP and local graduation requirements. These services and instruction should coordinate with other outside agencies and transition partners to ensure a smooth transition from high school to adulthood. Services and instruction during this time should be individualized and address the student’s unique disability-related needs as well as post-secondary goals.

13. How is FAPE defined for students with IEPs receiving beyond age 18 services?

A student with an IEP has a right to a Free and Appropriate Public Education (FAPE) until they earn a regular high school diploma or reach age 21, whichever comes first. For students receiving special education after age 18, it is the responsibility of the IEP team to design programming that allows the student to make adequate progress in the IEP goals while also building skills towards reaching their postsecondary goals in the PTP. Determining services required in order to provide FAPE remains an individualized IEP team decision based on the needs of the particular student.

For students with IEPs who stay in high school beyond age 18, this time may be used to finish credits toward graduation with a regular high school diploma while others may build functional skills as they transition to life after high school. What their day looks like, including its length, may differ significantly from a traditional school day. DPI Bulletin 24.01 notes the shortened school day requirements do not apply to students with IEPs who stay in school beyond age 18.

14. Are outside agencies responsible for paying for transition services beyond age 18?

Yes, outside agencies may be responsible for paying for transition services beyond age 18 depending on the specific services required and each agency’s eligibility process. If an agreement is made with an outside agency to provide and pay for services and the outside agency fails to provide or pay for the services, then the LEA is responsible for providing the services, and the LEA may seek reimbursement from the outside agency for the cost of providing the services.

The Transition Action Guide notes that  all applicable agencies are responsible for providing transition services to students. This resource includes further information on how to provide transition services to jointly served students.

15. What options do parents or adult students have if they disagree with the IEP team decisions about transition services or school exit?

A parent or adult student who disagrees with an IEP team decision regarding transition or school exit may request mediation, file a state special education complaint, or request a due process hearing.  More information about each of these options is available on DPI’s Special Education Dispute Resolutions Webpage.

16. How does an IEP team determine the Educational Environment Code for students beyond age 18?

IEP teams should use the same process for determining the Environmental Code for students beyond age 18 as school age students with IEPs. Educational Environment reflects the extent to which students with disabilities attend educational programs with their peers without disabilities. When calculating the percentage of time a beyond age 18 student is in the regular classroom with nondisabled peers, it is also important to consider age-appropriate community-based settings. Educational time spent in age-appropriate, community-based settings that include individuals with and without disabilities, such as college campuses or vocational sites, should be counted as time spent inside the regular classroom. For example, a job placement at a fast-food restaurant would not be considered a removal because the restaurant employs people with and without disabilities. More information on determining educational environments can be found on the DPI Education Environment Webpage.

17. What learning standards and competencies apply to students with IEPs in beyond age 18 programming?

The same learning standards apply to students with IEPs beyond age 18 as school age students. In addition, the Wisconsin Career Readiness Standards (WCRS) are an important body of standards for LEAs when designing individualized beyond 18 services.  The WCRS provides a foundation on which the subject-specific standards are built. These employability or "future-ready" skills are founded on social-emotional learning, global competence, STEM skills, and digital literacy skills and include the following:

• Career ready: Career Awareness, Exploration, Planning, and Preparation; Postsecondary Education and Training Preparation
• Learning ready: Academic Skills; Critical Thinking and Problem-Solving; Innovation Mindset and Skills; Technology Skills
• Life ready: Self-Awareness, Management, and Responsibility; Interpersonal Communication and Collaboration; Global Competence; Responsive Leadership

The Wisconsin Social and Emotional Learning Competencies are another important resource for IEP teams when designing beyond age 18 instruction and programming. The competencies support the belief that Social and Emotional Learning (SEL) skills are best learned when all adults are teaching, providing opportunities to practice, learning and modeling, and reinforcing these skills throughout the day. Note that the competencies are provided in groups of grade level, as each competency includes the knowledge and skill development of the previous competencies.

Section C: Dropout Considerations for Students with IEPs

18. When is a student with an IEP considered a dropout?

A student with an IEP is considered a dropout if they are no longer enrolled in school, have not earned a high school completion credential, earned a HSED/GED, or aged out of eligibility (i.e., past the end of the school year in which they turn 21), and have not transferred to another school or to a recognized alternative education program. A student with an IEP who leaves school voluntarily or stops attending without officially completing their education or enrolling elsewhere is considered a dropout. Additional information on how IDEA defines a dropout can be found on the Indicator 2 webpage.

19. How does an LEA document a student with an IEP as a dropout?

An LEA documents a student with an IEP as a dropout by documenting the student’s exit date and exit type in the student’s Student Information System (SIS). The exit type describes the circumstances under which the student exited from a school, which would be “ODO” for a dropout. The LEA must then submit the exit data to WISEdata, which feeds into DPI’s accountability systems. The exit data in WISEdata includes a field for Disability Status. If a student with an IEP drops out, the DPI considers this as a dropout with a disability, which is included in Indicator 2 of the State Performance Plan for special education.

LEAs must also keep documentation in the student’s file such as IEP team meeting notes, attempts to re-engage the student, parent or student communications, and referrals to transition or alternative programs, if applicable. LEAs may choose to send a letter to the student describing their right to return to school and receive special education until they earn a regular high school diploma or reach age 21. A copy of this letter can be added to the student’s file.

20. Can a student with an IEP who has dropped out of school return?

Yes, a student with an IEP who has dropped out of school may return if the student has not yet turned 21 and has not graduated with a regular high school diploma. For a student with an IEP to return to school, the student or parent must first contact the school or district where they last attended or where they now live. The district or school can help to re-enroll the student. The school will review and possibly update the previous IEP. The IEP team may hold a new IEP team meeting to adjust services and support based on where the student is now. The school or district will likely focus on helping the student work toward goals outlined in their transition services.

21. Does an LEA need to hold an annual IEP meeting for a student with an IEP who has dropped out of school?

No, a LEA does not need to hold an annual IEP meeting for a student with an IEP who has formally dropped out of school and is no longer enrolled. This is because IEP requirements only apply to enrolled students. Both IDEA and Wisconsin law require an IEP to be in place for each eligible student receiving services. If the student is no longer enrolled, they are not receiving services, so there is no obligation for the LEA to hold an annual IEP meeting.

22. Do students with IEPs who drop out of school need to be included in the Indicator 14 Post School Outcome survey?

Yes, students with IEPs who drop out of school need to be included in the Indicator 14 Post School Outcome survey under Wisconsin law and federal IDEA guidelines. Indicator 14 assists the DPI in describing the further education and competitive employment experiences of youth with disabilities as they transition from high school to adult life. Indicator 14 requires that states report an unduplicated count of the percent of youth who are no longer in school, had IEPs in effect, and were enrolled in higher education, competitively employed, or enrolled in some other postsecondary education or training within one year of leaving high school.

DPI Resources:

• Transition planning
• Shortened Day Bulletin
• Graduation Bulletin
• Indicator 13 webpage
• WIOA guidance
• Exit types page
• Dispute resolution options
• Supported Decision Making Bulletin
• Assistive Technology

Other resources:

• TIG Transition Assessment Guide
• TIG Transition Programming Beyond Age 18
• Transition Action Guide
• DVR referral
• OSEP Coordinating Transition Services and Postsecondary Access