The confusion here is far more conceptual than legal.

Short answer: No. IDEA does not require that an “AT evaluation” or “AT assessment” be listed as a discrete item on a Permission to Evaluate (PTE) or Permission to Reevaluate (PTR) in every case. A district is not out of compliance simply because it uses a consultation-based, SETT-guided process instead of a standalone, test-based AT evaluation.

That conclusion isn’t a loophole. It’s how IDEA is designed to work.

What IDEA Actually Requires About Assistive Technology

IDEA imposes two related—but distinct—obligations regarding assistive technology.

1. AT must be considered for every student with a disability

34 CFR §300.324(a)(2)(v)

This is an IEP obligation, not an evaluation mandate. Every IEP team must consider whether AT is needed for the student to access instruction, participate, or make progress. That consideration can be brief or extensive, depending on the student.

2. Evaluations must address all areas of suspected disability

34 CFR §300.304(c)(4)

If there is reason to suspect that assistive technology needs affect the student’s access, participation, or progress, then AT becomes part of the evaluation picture.

What IDEA does not do is define, prescribe, or require a particular thing called an “AT evaluation.”

There is:

• No required label
• No required format
• No required test battery
• No requirement for standardized scores

That omission is intentional.

AT Is About Access—Not Eligibility

Assistive technology is fundamentally different from eligibility determinations. It is about functional access, not diagnostic classification.

Because of that, IDEA allows—and frankly expects—flexible, functional evaluation methods, such as:

• Observation across environments
• Task analysis
• Trials with tools and supports
• Data from instruction
• Team problem-solving
• Input from teachers, therapists, and families

Using the SETT framework (Student, Environment, Tasks, Tools) is entirely consistent with IDEA’s evaluation requirements. It is a recognized methodology grounded in functional analysis, not psychometric testing.

The absence of norm-referenced scores does not make the process legally deficient.

Where Teams Get Tripped Up

Most disputes in this area don’t come from IDEA violations. They come from faulty assumptions, especially these two:

Assumption #1:

“If it informs decision-making, it must be labeled an ‘evaluation.’”

Not true. IDEA does not require every source of information used by a team to be formally labeled as an evaluation component on a PTE or PTR.

Assumption #2:

“If it’s an evaluation, it must produce standardized scores.”

Also not true. IDEA requires evaluations to be sufficiently comprehensive, not standardized for standardization’s sake.

Neither assumption is supported by the statute or regulations.

What PTEs and PTRs Actually Do

PTEs and PTRs are procedural documentation tools. They exist to document what assessments the district proposes to conduct as part of an evaluation or reevaluation.

They do not have to:

• List every consultative activity
• Itemize every framework used
• Use labels preferred by parents or counsel
• Convert ongoing problem-solving into a formal “evaluation”

What does matter is whether the district can demonstrate that:

1. AT needs were considered when there was reason to suspect they mattered, and
2. The team can explain how those needs were examined and what information supported the decision.

If a district is addressing AT needs through an ongoing, documented, SETT-based consultative process—and that information is meaningfully used by the team—there is no legal requirement to relabel that work as an “AT evaluation” on a PTE or PTR.

Why This Keeps Coming Up Anyway

This issue arises frequently because parents and attorneys often equate “evaluation” with a very specific mental model:

• A discrete event
• A written report
• Formal conclusions
• Scores or standardized findings

When those expectations aren’t met, the conclusion is often—incorrectly—that the information is “not valid” or “doesn’t count.”

The fix is not to invent a test, mislabel consultative work, or force AT into a mold IDEA never required.

The fix is clear documentation and explanation that:

• AT was evaluated functionally
• Using an accepted framework
• With data tied directly to the student’s tasks, environments, and needs

A Word About Risk Management vs. Legal Requirements

Some districts choose to include language like:

“Assistive Technology consideration using SETT framework”

on PTEs or PTRs. That’s fine.

But understand what it is: a risk-management choice, not a legal mandate.

Including that language may reduce parent confusion or procedural arguments. It does not change the underlying legal standard—and its absence does not create noncompliance.

Confusing “what reduces friction” with “what IDEA requires” is how districts end up over-formalizing processes they don’t need.

Summary

• Teams are not out of compliance for not listing “AT evaluation” as a standalone item on PTEs or PTRs.
• IDEA allows—and expects—flexible, functional evaluation methods for AT.
• SETT-based consultation is legally defensible.
• Including “AT evaluation” language on paperwork is optional and strategic, not required.

If a district wants to reduce conflict, the right internal conversation is about clarity and communication, not fear of noncompliance.