Summary of Bureau of Special Education Appeals Data for Fiscal Year 2025
The Bureau of Special Education Appeals ("BSEA"), an independent subdivision of the Division of Administrative Law Appeals, conducts mediations and due process hearings to resolve disputes among parents, school districts, private schools and state agencies.[1] The BSEA derives its authority from both federal law and regulations (the Individuals with Disabilities Education Act, "IDEA") and Massachusetts law and regulations. (MGL ch.71B).
A parent or a school district may request mediation and/or a due process hearing on any matter concerning the eligibility, evaluation, placement, individualized education program (IEP), provision of special education, or procedural protections for students with disabilities, in accordance with state and federal law. [2]
In addition, a parent may request a hearing on any issue involving the denial of a free appropriate public education guaranteed by Section 504 of the Rehabilitation Act of 1973. https://www.ed.gov/sites/ed/files/policy/rights/reg/ocr/34cfr104.pdf
Mediations and hearings are conducted by impartial mediators and hearing officers who do not have personal or professional interests that would conflict with their objectivity in the proceeding. The BSEA comprises six hearing officers (all of whom are attorneys), six mediators, a coordinator of mediation, a scheduling coordinator, administrative staff and a director.
What follows is a summary of BSEA data for fiscal year 2025 (covering the period July 1, 2024 through June 30, 2025).
Rejected IEPs
There were approximately 14,345 notifications ofrejected IEPs received by the BSEA during FY 2025, representing a slight increase from the 14,326 received in the prior year.
Facilitated IEP TEAM Meetings
This year the BSEA received 272 requests for facilitated Team Meetings, a decrease from the 310 received last year. Of those requests, 47 were declined by parents, 25 were declined by school districts, and 41 requests had to be declined by the BSEA owing to staff unavailability. The BSEA conducted 151 facilitated IEP Team meetings, an increase from the 138 conducted during the previous year. Eight (8) of the requests that were received in FY 25 were conducted in FY 26.
Mediation
The BSEA received 1,099 requests for mediation in FY 2025, representing a decrease from the 1,275 received the previous year. BSEA mediators conducted a total of 670 mediations in FY 2025, a decrease from the 703 conducted during the prior year. Of the 670 mediations conducted in FY 2025, 122 were mediations that were requested in FY 2024 and 548 were requested in FY 2025. The agreement rate for FY 2025 was 83%.
Of the 1,099 requests for mediation, 419 were withdrawn or not held due to one party declining to mediate and 132 cases were open/pending as of 7/1/25.
Due Process Hearings
TThe BSEA received 426 hearing requests during FY 2025, a slight increase from the 417 requests received in the prior year. BSEA hearing officers conducted full hearings resulting in the issuance of 29 decisions, a significant increase from 12 issued in the previous year. In addition, 100 substantive written rulings were issued, a slight increase from the 98 issued in FY 2024.
Prevailing Party: parents; public school district; other
Of the 29 decisions noted above, parents fully prevailed in 5, school districts fully prevailed in 17, and mixed relief was granted in 7.
Representation
Statistics with respect to outcome in relation to representation are as follows:
Of the 5 cases in which parents fully prevailed: parents were represented by counsel in 4 and appeared pro se in 1.The school district was represented by counsel in 5;
Of the 17 cases in which school districts fully prevailed: parents were represented by counsel in 4, by an advocate for a portion of 1 matter, and appeared pro se in 12 full matters and a portion of 1 matter. The school district was represented by counsel in all 17 matters;
Of the 7 cases which involved mixed relief, parents had counsel in 2, were represented by an advocate in 3, and appeared pro se in 2 . The school district was represented by counsel in all matters.
Settlement Conferences
As of the date of this report, settlement conferences were held in 39 of the cases that were filed for hearing in FY 2025 (as compared to 42 held in FY 2024 cases). Of these, 31 were settled in whole or in part.
[1]In addition to mediation and due process hearings (both of which must be offered pursuant to federal law), the BSEA offers alternative dispute resolution processes including IEP Team meeting facilitations and settlement conferences.
[2]A school district may not, however, request a hearing on a parent's failure or refusal to consent to initial evaluation or initial placement of a child in a special education program, or to written revocation of parental consent for further provision of special education and related services.