Students watch a Veterans Day program at Sugar Mill Elementary in Fort Bend ISD in Sugar Land, Tuesday, Nov. 11, 2025.

Students watch a Veterans Day program at Sugar Mill Elementary in Fort Bend ISD in Sugar Land, Tuesday, Nov. 11, 2025.

Brett Coomer/Houston Chronicle

Before Houston ISD can consolidate its special education services, it has to review thousands of students’ individualized education programs and meet with their families. That’s the explicit order from the Texas Education Agency, which investigated the district’s plans.

But HISD said it is already reviewing student records and plans to meet with families as needed during the  school year — after it moves students with disabilities to new campuses.

The district’s response has concerned some families who still hope to block the district’s special education overhaul and remain at their original campuses when school starts in August. Experts say HISD’s plans seem to contradict the state’s order and could trigger further sanctions, even as the district remains under a state takeover and conservatorship.

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“TEA is not telling Houston, ‘You can’t do this.’ They can. … It’s just, ‘If you’re going to do this, here’s what has to happen first,” said Colleen Potts, supervising attorney for Disability Rights Texas. “It doesn’t seem to me in (HISD’s) guidance, that there’s any promise of holding an IEP meeting for all of these kids.”

Individualized education programs, or IEPs, are legally binding documents that outline services students with disabilities must receive.

The district’s new special education model, called the Student Success Program, will send students who spend at least half of their time in self-contained classrooms to new schools when school resumes on Aug. 10. It affects about 5,000 students with disabilities districtwide. The program has sparked multiple complaints from Houston families and advocates and a federal investigation into potential discrimination.

AFFECTED BY HISD’S SPECIAL EDUCATION CHANGES? We want to hear from you.

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The TEA investigation, launched in response to  a parent complaint, found HISD had violated two federal rules. The state ordered the district to review about 5,000 IEPs and meet with families before assigning them new campuses. The agency found that HISD “cannot unilaterally amend a student’s IEP.” 

The district maintains that its special education overhaul will not affect students’ individualized plans and will improve services by providing smaller class sizes, increased staffing and additional staff training.

“Every student will continue receiving the services outlined in his or her IEP,” HISD’s deputy superintendent Kristen Hole said in a release Monday. “The Student Success Program is designed to provide students with stronger instructional supports, additional resources, and learning environments that better meet their needs. We will continue implementing these improvements while completing the reviews directed by TEA.”

ALSO READ: Parents plead with HISD leaders to scrap changes to special education program, to little success

A ‘huge win’

Individual parent complaints rarely spark districtwide change, said Jane Friou, who is an HISD parent and longtime special education advocate. Friou said the TEA’s response marks a “huge win” for families, who launched a “pressure campaign” against the overhaul after it was announced in May. 

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Still, Friou said the investigation and response do not answer perhaps parents’ most pressing question: where will their child attend school in August? She said even if the district planned to fully comply with the state’s orders, she believes it would be unlikely for HISD to successfully meet with every family in the few weeks before the new school year begins Aug. 10. 

She said the conflicting guidance from TEA and HISD could leave students’ original and newly assigned campuses unprepared, potentially forcing many students to stay home.

“Parents feel like phase one was a win. The first day of school is phase two,” Friou said. “Our goal … is to empower as many parents to continue to keep fighting.”

PARENT PUSHBACK: HISD parents ask board to pause overhaul that would move thousands of special education students

Further state intervention

In its letter to HISD, the TEA threatened further state sanctions if HISD does not comply with its order for corrective action by Oct. 9.

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Potts said it is unclear what sanctions the state could impose on a district that is already under a state conservatorship and takeover.

HISD’s special education department has been under a state conservator since Dec. 2020 and the district’s state takeover began in 2023.

“I don’t think we’ve ever been here,” Potts said. “I think this would be the first time in the state’s history that I know of that conservatorship isn’t enough of a sanction.”