States Decrease Their Required Secondary Transition Planning Age: Federal Policy Must Change

Abstract

Individuals With Disabilities Education Act 2004 mandates transition planning for students with disabilities begin by the age of 16 years. Currently, no study exists describing when states and territories require transition planning to begin; we conducted a methodical review to determine this age. We found over half (52%) the U.S. states and territories (29 of 56) require transition planning begin prior to the federal age 16 mandate. To argue the age 16 federal mandate is too old and needs to be lowered to at least age 14, we review special education law, provide a summary of influential position statements, cite relevant data-based studies, and provide an overview of research-based transition models.

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Discussion Article
Special education teachers with numerous years of experi-
ence often talk about the “swinging pendulum” of educa-
tion practice and process. Senior educators often reminisce
of procedures swinging in response to a catalyst that years
later return to the original position, only to be thrust into
another swing shortly thereafter (Jenkins, 2012). This swing
also appears evident in federal special education laws,
establishing and changing the required age of transition
planning. To date, no published study has examined when
states and territories mandate the starting transition age and
if this differs from the federal age.
Transition Age Policy Evolution
The Education for All Handicapped Children Act of 1975
(EHA, PL 94-142) is a highlighted milestone within the spe-
cial education community as it provided an initial focus point
in special education’s progressive evolution. It guaranteed
youths with disabilities the right to a free appropriate public
education within the least restrictive environment. The fed-
eral legislature amended EHA in 1983 and 1986 to respond to
identified gaps. In 1983, amendments to the act provided
funding for school-to-work transition services to support
model transition demonstration programs, research, and per-
sonnel preparation projects. These ventures documented the
need for transition planning and services while identifying
important transition components. In 1986, the EHA amend-
ments maintained funding to continue model transition dem-
onstrations, research, and personnel preparation.
Federal policy makers debated the mandated transition
planning age as federal special education transition legisla-
tion evolved. In 1990, the Education of the Handicapped
Act Amendments recommended that the revision to
Individuals With Disabilities Education Act (IDEA) 1990
special education law includes starting the secondary transi-
tion planning process at age 14. The U.S. House Committee
on Education and Labor (Hawkins, 1990) noted implement-
ing transition services prior to 16 years old is critical
because starting at the age of 16 may be too late for many
students. However, when the IDEA of 1990 was imple-
mented, the mandate required secondary transition planning
to start at the age of 16 and not the hoped-for age of 14. The
reason for not following the 1990 House Report recommen-
dation is unclear, but consequentially, this missed opportu-
nity meant states eliminated 2 years of essential transition
planning and services from students’ education.
IDEA 1990 clarified transition planning expectations,
which included (a) an outcome-oriented process; (b)
915157DPSXXX10.1177/1044207320915157Journal of Disability Policy StudiesSuk et al.
research-article2020
1The University of Oklahoma, Norman, USA
2Amplify, Tulsa, USA
3Lawton Public Schools, Lawton, USA
Corresponding Author:
Andrea L. Suk, Zarrow Center for Learning Enrichment, The University
of Oklahoma, 338 Cate Center Drive Room 190, Norman, OK 73019,
USA.
Email: andrea.suk@ou.edu
States Decrease Their Required
Secondary Transition Planning Age:
Federal Policy Must Change
Andrea L. Suk, MS Ed1, James E. Martin, PhD1, Amber E. McConnell, PhD2,
and Tiffany L. Biles, MEd3
Abstract
Individuals With Disabilities Education Act 2004 mandates transition planning for students with disabilities begin by the
age of 16 years. Currently, no study exists describing when states and territories require transition planning to begin; we
conducted a methodical review to determine this age. We found over half (52%) the U.S. states and territories (29 of
56) require transition planning begin prior to the federal age 16 mandate. To argue the age 16 federal mandate is too old
and needs to be lowered to at least age 14, we review special education law, provide a summary of influential position
statements, cite relevant data-based studies, and provide an overview of research-based transition models.
Keywords
transition, policy

2 Journal of Disability Policy Studies 00(0)
promoting movement from school to postschool activities;
(c) postsecondary education, vocational training, integrated
employment, continuing and adult education, adult ser-
vices, independent living, and community participation; (d)
based on the individual student’s needs . . . preferences and
interests; (e) development of employment and adult living
objectives; and (f) daily living skills and functional voca-
tional evaluation (Flexer et al., 2012). In addition, IDEA
1990 required students with disabilities be invited to attend
their own planning for transition services during individual-
ized education program (IEP) meetings.
In 1997, IDEA was reauthorized, retaining a similar defi-
nition of transition services as depicted in IDEA 1990. A
revolutionary revision changed the age transition planning
must begin. IDEA 1997 mandated transition services and
planning begin when the student turns 14 years old. IDEA
1997 provided students with an IEP the opportunity to plan
and explore postsecondary environments and develop goals
with more time to receive supports from the public-school
system. Uncharacteristically, instead of progressing and
lowering the mandatory transition planning age, the 2004
IDEA reauthorization reverted the federal transition plan-
ning age back to age 16 years or earlier when appropriate.
This reversal equated to a large swing in the educational
pendulum, previously unseen with federal special education
legislation.
Transformational Research and Policy
Suggestions
Emerging research has begun to examine postschool out-
comes based on the age states begin required secondary
transition planning. Cimera et al. (2013) and Cimera et al.
(2014) analyzed national postschool rehabilitation outcome
data and found individuals with autism or an intellectual
disability who exited high school more likely to be employed
when they lived in states requiring transition planning ear-
lier than the federal age of 16. These researchers concluded
transition planning must begin by age 14 to increase the
likelihood of meaningful transition outcomes.
Numerous transition models (Halpern, 1985; Kohler
et al., 2016; Wehman et al., 1985; Will, 1984) and the
research indicate the plethora of skills needed to achieve
successful postschool outcomes (Barnard-Brak & Fearon,
2012; Carter et al., 2011, 2012; Chiang et al., 2012; Karpur
et al., 2014; McConnell et al., 2015; Milsom & Glanville,
2010; Shogren et al., 2016; Shogren & Plotner, 2012). The
vast amount of additional skills to be taught suggests a need
for schools to expand the scope of their transition support
and practices, which axiomatically supports extra time for
students to learn, practice, and generalize essential transi-
tion skills.
Parallel to the legislative evolution the Council for
Exceptional Children’s Division on Career Development
and Transition (DCDT) published numerous transition
position papers, summarizing research to direct best tran-
sition education practice. DCDT strongly believed,
“Transition planning should begin no later than age 14 . . .”
(Halpern, 1994, p. 117) and reiterated this position in sub-
sequent DCDT position papers. Benz and Kochhar (1996)
noted youth with disabilities would benefit from transition
programs with “sufficient breadth, intensity, and duration
to meet participants’ individual needs” (p. 44). Sitlington
et al. (1997) reaffirmed Halpern’s (1994) position by indi-
cating transition stakeholders need to plan longitudinally
by the age of 14. Field et al. (1998) postulated starting
transition planning by age 14 provided schools time to
teach essential self-determination skills. Blalock et al.
(2003) stated transition planning must begin at least by
age 14 to prepare students for a successful transition from
high school to adult life. Finally, Neubert and Leconte
(2013) acknowledged the need for development and usage
of age-appropriate transition assessments for 14-year-old
students with disabilities.
Clearly, federal policy makers and secondary transition
leaders differ on the age transition planning must begin.
Federal legislation first established the mandatory transition
planning age at 16, revised it to age 14, then reversed the
transition planning age back to 16. Transition education
leaders’ consensus is that transition planning must begin at
least by age 14 (Blalock et al., 2003; Halpern, 1994;
Sitlington et al., 1997), and states may, at their discretion,
implement more rigorous special education laws than those
established by federal law (Rosen, 2018).
Purpose
With alternating age mandates from federal legislation and
best practice guidelines in conflict with federal require-
ments, what should states and territories do? Should these
governmental entities follow the minimum federal require-
ments, or do they demand educators follow best practice by
beginning transition at an earlier age? How many and which
states and territories mandate transition planning at age 16?
How many and which states and territories enforce a more
rigorous, lower transition starting age? Should states and
territories comply with the federal mandate or should they
continue to follow the federal age mandate? If this study
determines many states and territories mandate transition
planning earlier than the federal age, then we will use these
findings to advocate for state and federal policy change to
lower the required transition age.
Method
To determine the age transition planning must begin in
states and territories, we conducted a content analysis to
produce a descriptive review through an iterative process to

Suk et al. 3
examine online state department of education (SDE) pub-
lished materials. When online published materials were
incomplete or could not be found, we called or emailed
SDE to identify the transition age requirement.
Data Source
We initially identified 57 states, territories (including Guam,
Northern Mariana Islands, Puerto Rico, American Samoa,
U.S. Virgin Islands), and other entities (Washington DC,
and the Bureau of Indian Education [BIA]) to include in this
study. American Samoa was removed from this study due to
inability to access the information from their website and
our attempts to contact representatives from the department
of education elicited no response. We utilized the expertise
of a Spanish translator experienced with secondary transi-
tion education to study Puerto Rican information. Therefore,
we examined the published or department of education offi-
cials’ confirmed information from 56 entities, which
included all 50 states, Washington DC, Bureau of Indian
Education, Guam, Northern Mariana Islands, Puerto Rico,
and the U.S. Virgin Islands.
Procedure
We utilized an iterative data collection process to com-
plete this study. Iterative refers to a systematic, repetitive,
and recursive process to collect data. Reviewers exam-
ined and mutually understood the data collection proce-
dure, including searching for a transition tab on each
department of education’s website, using the search func-
tion on the departments’ website, and searching for a par-
ent manual on transition. When this procedure did not
yield the information of focus, reviewers utilized the con-
tact information on the department of education’s website
to email or call employees at the department. While col-
lecting data, researchers met weekly to review the data
collection protocol, report progress, and problem solve.
We identified and included 50 states, District of Columbia,
Bureau of Indian Affairs, and the five inhabited territories
(Puerto Rico, Guam, American Samoa, U.S. Virgin
Islands, and Northern Mariana Islands) which had depart-
ment of education websites and reviewed the websites to
identify the mandated age which transition planning must
begin. We excluded American Samoa because we could
not locate a department of education website, nor contact
information for department of education representatives.
Primarily, we were able to access this information by
retrieving each entity’s parent procedures handbook. As a
procedural safeguard for parents, this resource often
reported the age the state or territory mandated transition
planning to begin. Some SDE websites also outlined
teacher responsibilities, including when to begin transi-
tion planning.
Conversion of grade to age data. Alabama, Delaware, Geor-
gia, Kentucky, Minnesota, and Oklahoma have mandated a
grade level to start transition. Specifically, Alabama and
Minnesota require transition planning to start by ninth
grade. Georgia and Oklahoma require transition planning to
begin by age 16 years or ninth grade, whichever comes first.
Kentucky and Delaware require transition planning to begin
by age 14 years or eighth grade. To convert to an under-
standable metric, we converted grades to ages typically
associated with each grade. The U.S. Department of Educa-
tion, National Center for Education Statistics (2013) noted
students typically enter eighth grade by age 13. Therefore,
researchers deducted that students typically enter ninth
grade by age 14. When grade requirements are converted to
an age, researchers determined all six states require plan-
ning for students prior to the age of 16.
Data agreement. Three reviewers independently examined
SDE websites to glean the starting transition age for each
state-level government education agency. Sequentially, the
second reviewer examined the first reviewer’s data by com-
paring results with original website documentation and cor-
rections were resolved. Repeating the same verification
process, the third reviewer independently reviewed the sec-
ond reviewer’s results. About 10% of the entities had dis-
crepant starting ages, which researchers resolved by
examining and agreeing on the starting transition age found
in the most recent SDE published documentation or by
direct contact with an SDE representative.
Results
As depicted in Table 1, last updated in April 2019, results
from the website document review revealed almost half
(27) of the 56 SDE entities mandated starting transition
planning at age 16, which equals the federal minimum
requirement. Of the 56 states and territories, 23 specifi-
cally required educators to implement transition planning
prior to students turning 16 years. When researchers con-
verted grade-level requirements to an age, 29 of the 56
states and territories required educators to begin transition
planning prior to the age of 16. New York and South
Carolina had the earliest transition planning age with the
requirement to begin at age 12 and 13, respectively.
Twenty-five entities required transition planning to begin
between the ages of 14 and 14.5 years (including states
researchers converted). Colorado required secondary tran-
sition planning to begin at age 15.
Rather than focus on age, Georgia and Oklahoma
required secondary transition planning to begin by age 16
years or ninth grade, whichever comes first. Although not
yet in SDE online materials, Oklahoma SDE verbally
advised special educators to begin transition planning at
age 14 (Deardorff & Suk, 2017). Delaware and Kentucky

4 Journal of Disability Policy Studies 00(0)
Table 1. State and Territory Age Requirements for Transition Planning as of April 2019.
Entity By age 13 By age 14 By age 15 By age 16 Grade/age requirement
Alabamaa b Ninth grade
Alaska 
Arizona 
Arkansas 
California 
Coloradoa
Connecticut 
Delawarea b 14 or eighth grade
Whichever comes firsta
District of Columbia 
Floridaa
Georgiaa b 16 or ninth grade
Whichever comes firsta
Hawaiia
Idaho 
Illinoisa
Indianaa
Iowaa
Kansasa
Kentuckya b 14 or eighth grade
Whichever comes firsta
Louisiana 
Maine 
Marylanda
Massachusettsa
Michigan 
Minnesotaa b Ninth grade
Mississippia
Missouri 
Montana 
Nebraska 
Nevadaa
New Hampshire 
New Jerseya
New Mexicoa
New Yorka (12)
North Carolinaa
North Dakota 
Ohioa
Oklahomaa b 16 or ninth grade
Whichever comes firsta
Oregon 
Pennsylvaniaa
Rhode Islanda
South Carolinaa
South Dakota 
Tennesseea
Texas 
Utah 
Vermont 
Virginiaa
(continued)

Suk et al. 5
required secondary transition planning to begin by age 14
or eighth grade, whichever comes first. Alabama and
Minnesota eliminated the secondary age requirement and
instead required planning and services to begin when stu-
dents enter ninth grade. Most districts planned on students
entering ninth grade prior to their 16th birthday, with the
exception of some students with significant disabilities,
medical conditions, or other reasons for not generally
keeping up with their same-aged peers. With the addi-
tional six entities previous listed, it can be stated that 29
states and territories, more than half, require teams to pre-
pare transition plans as youths enter high school, typically
prior to age 16.
Discussion
The purpose of this study was to investigate and specifically
identify states and territories that follow the minimum fed-
eral mandate to start transition planning at the age of 16 and
those that follow the research findings and recommenda-
tions of leaders in the field to start transition planning at
earlier ages. If the results found many states (approximately
40% or more) required beginning transition planning at an
age lower than the current federal requirement, we wanted
to use these results to advocate policy change to lower the
beginning transition age to align with the current states’ and
territories’ policies and best practice as described in the lit-
erature. We reviewed state departments of education web-
sites and contacted SDE officials to detail the required
transition age. Although most entities posted this informa-
tion within parental safeguards, some entities did not pro-
vide this information on their website, requiring us to
contact SDE employees to obtain the information. After
converting grade to age data, we determined the percentage
of states and territories that require transition planning to
begin at age 16 and those that begin earlier. Results indi-
cated 23 of the 56 (41%) states and territories require transi-
tion planning to begin prior to age 16. Although six states
encompass a grade-level or an age and grade, each of these
states can be counted as requiring transition prior to age 16
for the majority of their students (29 of 56, 52%). With the
exception of Puerto Rico, all nonstate entities (Washington
DC, Bureau of Indian Education, Guam, Northern Mariana
Islands, and U.S. Virgin Islands) require transition planning
to begin at the age of 16.
The fact that 52% of states (and Puerto Rico) require
transition education practices to begin earlier than the fed-
eral 16-year-old mandate suggests educators and policy
makers value expert opinions and research by requiring
more stringent transition age requirements for the better-
ment of their citizens with disabilities. These study results
will hopefully prompt meaningful discussion and encour-
age the next reauthorization of IDEA to align with states
already following best practice and lower the transition age
to 14 years.
Implications for Policy
Emerging research suggests early transition planning
results in better postsecondary outcomes for employment
(Cimera et al., 2014) and education (Morningstar et al.,
2010). Although experts and practitioners alike agree stu-
dents with disabilities need as much time as possible to
prepare for postsecondary environments, federal legisla-
tion has decreased the time educators are required to focus
on transition planning. Prior to IDEA 1990, recommenda-
tions were made to require states and schools to start tran-
sition planning at the age of 14. As Hawkins (1990)
described, “for those students who will stay in school until
age 18, many will need more than two years of transitional
services” (p. 10).
Many state policy leaders must have believed, as sug-
gested by various transition models (Kohler et al., 2016),
transition planning must begin prior to the required age of
16 to enable students to participate in various transition
education practices to learn the variety of skills and arrange
needed supports for a successful transition to adult life. To
do this, we believe federal and state policy need to align
Entity By age 13 By age 14 By age 15 By age 16 Grade/age requirement
Washington 
West Virginia 
Wisconsina
Wyoming 
Bureau of Indian Education 
Guam 
Northern Mariana Islands 
Puerto Ricoa
U.S. Virgin Islands 
aEntity starts transition planning prior to the age of 16 years. bResearchers’ conversion of a grade level into an age based on U.S. Department of
Education, National Center for Education Statistics (2013).
Table 1. (continued)

6 Journal of Disability Policy Studies 00(0)
with the remarkable findings of Cimera et al. (2013) and
Cimera et al. (2014), who discovered that students who
graduated from states with earlier transition age require-
ments were more likely to be employed than their peers
from states requiring transition to begin at age 16. Thus, we
strongly suggest special educators and leaders advocate at
the state and federal level to require transition planning to
begin at least by the age of 14, if not earlier. Special efforts
must be given to encourage state special education direc-
tors and state superintendents of education to support
beginning transition planning by at least the age of 14, and
these leaders convey the need for this change to federal
policy makers.
Limitations and Future Research Needs
Four issues may limit the effect of the results of this study.
First, we relied extensively on information provided by
SDE websites, and we assumed this information was cor-
rect. Second, not all states provided transition age informa-
tion on SDE websites and we had to contact SDE employees
by email or phone. We relied on the officials’ knowledge
and ability to provide accurate information for the state.
Third, districts within states that follow the federal age of
16 may begin transition at a lower age, but these districts
are not included in this analysis as this study focused upon
state-level mandates. Fourth, conversion of mandated tran-
sition grade data into mandated transition age data may not
fully represent the intent of states, but we needed a common
metric to compare entities. To avoid overinterpretation, we
also provided results by age and grade.
Future research needs to expand this initial descriptive
research study by examining two issues. Beyond increasing
the federal transition age to 16, IDEA also included new and
potentially impactful transition education changes. These
included the required use of transition assessments, chang-
ing the focus of secondary IEPs to focus on students’
strengths and their interests, and the creation of a statement
of transition services. These additions may produce
improved school and postschool outcomes equal to or
greater than emerging research has found with lowering the
transition age. Second, a descriptive review of required tran-
sition planning procedures and how these vary across transi-
tion ages needs to be undertaken, followed by an examination
of the effects of these different procedures upon various state
postschool outcomes.
Conclusion
Numerous education researchers and policy makers advo-
cate transition planning begin at age 14. These extra 2
years, from age 14 to 16, provide valuable time to begin
the comprehensive planning process for youths who may
even still be in middle school (Cimera et al., 2013, 2014).
By starting transition planning prior to entering high
school, students have the opportunity to be evaluated with
transition assessments and identify potential career inter-
ests and postsecondary education opportunities (interests,
skills, and needs). The students then have an additional 2
years to learn prerequisite skills needed for their career
interests and/or prepare for desired postsecondary educa-
tion opportunities.
Over the years, federal transition legislation has men-
tioned the minimum starting age, but the exact age men-
tioned has vacillated through time from age 14 to 16. We
know from emerging research that youths who start transi-
tion planning and services earlier have better postschool
outcomes. The results from this study found the majority of
states and territories start transition planning earlier than
federally mandated, which implies these state leaders
believe it is beneficial to provide their students ample prep-
aration for successful transition to adult life.
Declaration of Conflicting Interests
The author(s) declared no potential conflicts of interest with
respect to the research, authorship, and/or publication of this
article.
Funding
The author(s) received no financial support for the research,
authorship, and/or publication of this article.
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