Using Artificial Intelligence (AI) to Assist in Writing IEP Goals: 50 Critical Questions Districts and IEP Teams Must Address

AI Is Changing IEP Development. Accountability Hasn't Changed.

Artificial intelligence is rapidly making its way into special education practice.

For educators and administrators managing growing caseloads, staffing challenges, and significant documentation requirements, the appeal is understandable. AI tools can help generate language quickly, organize information, and provide a starting point for present levels of academic achievement and functional performance (PLAAFP) statements, annual goals, accommodations, and recommendations.

At the same time, districts are operating in an environment of heightened scrutiny around special education compliance and an increase in complaints and disputes. That makes the quality, individualization, and defensibility of an IEP more important—not less.

AI may make drafting faster. It does not change who is responsible for the final product.

Used thoughtfully, AI can serve as a brainstorming tool or provide a starting point for drafting language. However, AI cannot replace professional judgment, individualized decision-making, or the collaborative responsibilities of an IEP team.

The use of AI in special education raises significant legal, educational, and ethical questions. AI-generated statements may appear professional and educationally sound while failing to meet IDEA requirements. Goals may not be measurable, may not align with present levels, may omit essential components, or may fail to address the student’s disability-related needs. Similarly, AI-generated recommendations may conflict with federal requirements, state regulations, district policies, or evidence-based instructional practices.

Equally important, AI systems lack the ability to truly know a student. They do not observe the student’s performance in classrooms, understand the student’s strengths and interests, appreciate family priorities, or recognize the nuances of the student’s cultural and linguistic background. AI cannot determine whether a particular service, accommodation, or instructional strategy is appropriate for an individual child.

For these reasons, AI should never be used to make educational decisions. Decisions regarding eligibility, placement, services, supports, accommodations, and annual goals must always be made by qualified professionals and the IEP team based upon evaluation data, present levels of performance, professional judgment, and meaningful team discussion.

The use of AI also raises significant privacy concerns. Teachers may inadvertently enter personally identifiable information into publicly available AI platforms that retain user prompts and uploaded information. Districts must ensure any use of AI complies with the requirements of the Family Educational Rights and Privacy Act (FERPA), IDEA confidentiality provisions, state student privacy laws, and local district policies governing student data.

Perhaps most importantly, the existence of AI-generated content does not transfer responsibility away from educators.

The school district and IEP team remain fully responsible for every statement contained in the IEP. If challenged in mediation, a state complaint, or a due process hearing, educators—not the algorithm—must be prepared to explain and defend every goal, service, and decision contained in the student’s program.

Accordingly, whenever AI is used to assist in drafting IEP components, districts should carefully consider the following principles and questions.

Guiding Principles for the Use of AI in IEP Development

1. AI may assist with drafting language but may not replace professional judgment.
2. AI-generated content must be reviewed, revised, and individualized by the IEP team.
3. All PLAAFP statements, goals, services, and accommodations must comply with federal law, state regulations, and district policies.
4. Educational decisions must be made by people, not algorithms.
5. Personally identifiable student information should never be entered into an AI platform unless the district has verified that the platform complies with applicable privacy requirements.
6. The district remains fully accountable for the contents of every IEP, regardless of whether AI assisted in drafting portions of the document.

The Defensibility Test

There is one simple question IEP teams can use to pressure-test AI-assisted goals:

If the student’s name were removed from the IEP, would an experienced educator be able to determine that this goal was written specifically for this student and no other?

If the answer is no, the team should reconsider whether the goal is sufficiently individualized, educationally meaningful, and legally defensible.

50 Questions Districts and IEP Teams Should Ask When Using AI to Assist in Writing IEP Goals

AI may assist in drafting language, but it cannot exercise professional judgment, determine educational need, make eligibility or placement decisions, select services, or replace the individualized decision-making responsibilities of the IEP team.

The district remains fully responsible for every statement, goal, service, and decision contained in the IEP.

Student Data and Individualization

1. What information was entered into the AI tool?
2. Were current evaluations, observations, and progress-monitoring data considered?
3. Were the student’s strengths, interests, and parent concerns considered?
4. Did the AI-generated language accurately reflect the student’s unique needs?
5. Could this same goal have been generated for many other students?
6. Does the goal address a disability-related educational need?
7. Is the goal necessary for the student to make appropriate educational progress?
8. Would a parent recognize this goal as being written specifically for their child?

Alignment with Present Levels

9. Is there a direct line from the present levels to the proposed goal?
10. What information in the PLAAFP statement supports the need for this goal?
11. Does the goal address an identified educational need rather than simply improve a test score?
12. Does the goal focus on an observable and teachable skill?
13. Does the goal support participation and progress in the general education curriculum?
14. If this goal were removed, what important need would remain unaddressed?

Compliance with IDEA Requirements

15. Is the goal measurable?
16. Does the goal contain observable behavior?
17. Does the goal specify the conditions under which the skill will occur?
18. Does the goal contain objective criteria for mastery?
19. Could an independent observer determine whether the student met the goal?
20. Does the goal avoid vague terms such as “understand,” “improve,” or “demonstrate awareness”?
21. Is the goal ambitious in light of the student’s circumstances, consistent with Endrew F.?
22. Would the district be comfortable defending this goal during mediation or due process?

Specially Designed Instruction

23. What specially designed instruction is necessary for the student to achieve the goal?
24. Does the goal assume interventions that are not documented elsewhere in the IEP?
25. Is there alignment among the student’s need, the goal, and the specially designed instruction?
26. Has the team identified who will provide the instruction and how often?
27. Could another educator implement the instructional plan based solely on the information in the IEP?

Progress Monitoring

28. How will progress toward the goal be measured?
29. What specific data will be collected?
30. Who will collect the data and how often?
31. How often will progress be reported to parents?
32. What decision rules will be used if the student is not making expected progress?
33. Could another educator collect the data and reach similar conclusions?

Professional Judgment and Verification

34. Who reviewed the AI-generated output before it was included in the IEP?
35. What edits were made to the AI-generated language?
36. Can the teacher explain why each component of the goal was retained or changed?
37. Was professional judgment exercised, or was the AI output accepted without sufficient analysis?
38. Would the teacher be comfortable explaining and defending the goal under oath?
39. If the AI system generated a different recommendation tomorrow, would the team’s decision change?

Equity and Bias

40. Could the AI-generated goal inadvertently lower expectations for certain groups of students?
41. Does the goal reflect high expectations and access to grade-level standards whenever appropriate?
42. Were the student’s cultural and linguistic characteristics appropriately considered?

Confidentiality and Privacy

43. Was personally identifiable information entered into the AI system?
44. Does the AI platform retain prompts or uploaded information?
45. Is the use of the AI platform consistent with district policy and applicable privacy laws, including IDEA and FERPA?
46. Have staff received guidance regarding what information may and may not be entered into AI systems?

Documentation and Accountability

47. Does the district have a policy governing AI use in IEP development?
48. Who is ultimately responsible for the contents of the IEP?
49. How will administrators review AI-assisted goals for quality and compliance?

The Ultimate Question

50. If the student’s name were removed from the IEP, would an experienced educator be able to tell that this goal was written specifically for this student and no other?

AI will almost certainly continue to become part of educators’ workflows. The goal should not be to ignore tools that may help educators work more efficiently, nor should districts treat AI-generated language as a substitute for the expertise of the professionals who know and serve their students.

The distinction is important: AI can help draft an IEP. It cannot develop an IEP for a student.

That responsibility remains with the IEP team.

For district leaders, this creates an opportunity to establish clear expectations now—before informal AI use becomes embedded in practice. Policies, professional development, privacy safeguards, review processes, and clear standards for individualization can help educators use emerging technology while maintaining the professional judgment, collaboration, and accountability at the heart of IDEA.

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By Dr. David F. Bateman, Parallel Advisor

Dr. David F. Bateman is a nationally recognized expert in special education law, IDEA compliance, dispute resolution, IEP development, and systems improvement. A longtime advisor to Parallel Learning, Dr. Bateman brings extensive experience as a special education teacher, professor, hearing officer, investigator, mediator, author, and consultant to school districts across the country.

At Parallel Learning, we believe technology is most powerful when it expands the capacity of educators and specialists without replacing the human expertise students depend on. As AI becomes more prevalent in special education, the standard should remain the same: Is this individualized, educationally meaningful, measurable, and appropriate for this student?