The Texas Education Agency is ordering Houston ISD to make sweeping changes to its special education program after concerns surrounding the district’s Student Success Program, warning that failure to comply could result in additional state interventions and the withholding of funding.
KPRC 2 News obtained an action plan sent to the district in September by the TEA to HISD outlining a series of corrective measures the district must complete over the next six months.
The TEA action plan comes after months of concern from parents and special education advocates over HISD’s restructuring of special education services.
The plan calls for the district to correct violations affecting 6,723 students, review at least 650 student records, improve special education services and establish stronger oversight of how students’ Individualized Education Programs, or IEPs, are being implemented.
The consequences could be significant if HISD fails to meet the requirements.
“Failure to comply will result in additional interventions and sanctions, including the possibility of placing the district in high-risk grantee status and withholding of funds,” the September report states.
The agency also warns that if HISD does not demonstrate timely correction, reliable implementation or sustained compliance, TEA could require additional evidence, extend monitoring, modify the action plan or impose additional corrective actions.
TEA calls for review of students impacted by Success Program
The action plan specifically addresses HISD’s Student Success Program, which the district introduced during the previous academic year as part of a restructuring of some special education services.
HISD said the program is designed to centralize specialized programs at designated campuses across the district. As part of the plan, some students were required to change campuses.
The agency also requires TEA staff and the appointed conservators to review at least 650 student records.
That review will compare each student’s written IEP with the actual instruction, services, schedule, placement, instructional arrangement, transportation and implementation provided by the district.
TEA established a threshold that could trigger an even broader review.
If reviewers find that 325 or more of the 650 records indicate students’ IEPs should have been revised through an Admission, Review and Dismissal (ARD) committee meeting or an agreed-upon IEP amendment, or that the district failed to properly address related factors, TEA says that would indicate a high likelihood of systemwide noncompliance.
In that case, HISD would be ordered to develop and implement a plan to hold ARD committee meetings for every student impacted by the Success Program by the end of January 2027.
The action plan also makes clear that HISD leadership will be responsible for ensuring the requirements are carried out.
TEA specifically directs Superintendent Mike Miles to “remove barriers, direct staff, and assign resources” necessary to complete the plan.
The plan emphasizes that simply adopting new policies or providing staff training will not be enough.
As part of the corrective measures, TEA is also directing HISD to create a parent advisory group to get feedback on developments.
According to the report, the group must be facilitated with the special education conservators and include district leadership overseeing curriculum and special education.
The advisory group must meet at least twice before the end of the six-month action plan.
TEA will ultimately determine whether the district has met the requirements.
“Submission of documentation alone does not constitute completion,” the report states. The agency says it will evaluate credible, relevant and verifiable evidence of correction, implementation and sustained compliance.
HISD says it is working with TEA
In a statement to KPRC 2 News, HISD said it is working with the TEA to meet the requirements.
“Houston ISD is working closely with the Texas Education Agency (TEA) and the District’s appointed Special Education Conservators to meet the requirements of the action plan. Additional information and opportunities for community engagement will be shared in the coming weeks.”
District leaders have defended the initiative, saying it is designed to strengthen services by creating smaller classrooms, increasing classroom staffing, reducing age ranges within self-contained classrooms, providing additional specialized staff training and expanding opportunities for inclusive learning.
The district also maintained that a change in school location alone does not require an ARD meeting if a student’s IEP and services remain unchanged.
“The Student Success Program is designed to provide students with stronger instructional supports, additional resources, and learning environments that better meet their needs,” Deputy Superintendent Kristen Hole said in a previous district news release. “We will continue implementing these improvements while completing the reviews directed by TEA.”
However, parents and advocates questioned whether some campus reassignment decisions were made without the required individualized ARD discussions.
Some families have also raised concerns about transportation, classroom staffing, access to general education settings and whether students with disabilities will continue to have opportunities to learn alongside their non-disabled peers.
HISD parent Mireille Patman previously told KPRC 2 that she was concerned about her son’s anticipated campus reassignment and the lack of an ARD meeting.
“There are safeguards parents receive at every ARD meeting,” Patman said. “And the fact that that meeting did not take place and yet I received a phone call is in violation of that.”
Earlier this year, the U.S. Department of Education’s Office for Civil Rights also opened an investigation into whether HISD’s proposed changes comply with Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act.
While the district says it is working with TEA and its conservators, the agency makes clear that progress will be measured by whether students actually receive the services and protections required under federal and state law.
The potential consequences extend beyond additional monitoring.
If HISD fails to demonstrate compliance, TEA could impose further sanctions, including placing the district in high-risk grantee status and withholding state funds.
For families whose children receive special education services, the coming months could bring additional reviews of student records, possible ARD meetings and renewed opportunities to provide feedback about the district’s changes.
