The Center for Appropriate Dispute Resolution in Special Education (CADRE) has released its October 2026 report, Trends in Dispute Resolution Under the IDEA: 2024–25 (SY 2024). Drawing on data released by the U.S. Department of Education’s Office of Special Education Programs (OSEP) in September 2026, the report provides an important examination of how parents, school districts, and states are resolving disagreements under the Individuals with Disabilities Education Act (IDEA).

The central finding is clear: Special education dispute resolution activity is increasing, although the patterns differ significantly depending on the dispute resolution process being used. CADRE documents substantial increases in written state complaints and mediation requests, while also identifying an important statistical change in New York that dramatically affected national due process complaint totals.

For school administrators, special education directors, attorneys, advocates, and parents, the findings deserve attention.

Written State Complaints Continue to Rise

Perhaps the most striking finding in CADRE’s report is the continued increase in written state complaints.

During the 2024–25 school year, states received 10,610 written state complaints, an increase of 6.9% over the previous year and more than double the number filed in 2014. CADRE reports that filings were 76% higher than the previous 10-year average.

The increase has been particularly pronounced since the 2020–21 school year. After declining to 4,186 complaints in 2020, filings increased to 6,160 in 2021, 8,154 in 2022, 9,927 in 2023, and 10,610 in 2024.

CADRE also reports that 59% of written state complaint reports issued included findings of noncompliance, a decrease from the previous year. The percentage itself is not necessarily concerning, as substantiated complaints demonstrate that the complaint investigation process is identifying violations of IDEA requirements. What deserves closer examination is the decline. Does it reflect improved district compliance, or does it suggest an increase in complaints that lack sufficient factual or legal support? CADRE’s data do not answer that question, but the distinction is important. A strong complaint resolution system should identify genuine violations while also ensuring that allegations without merit are appropriately dismissed.

Another concerning statistic involves timeliness. According to CADRE, only 78% of state complaints were resolved within the 60-day timeline, compared with an average of 92% between 2014 and 2022.

These findings raise important questions about state complaint investigation capacity, district implementation of IDEA requirements, and the effectiveness of existing compliance monitoring systems. However, increased filings alone do not establish that schools are becoming less compliant. They may also reflect greater awareness of complaint procedures, changes in reporting, or other factors.

Mediation Requests Reach Record Levels

CADRE reports that mediation requests reached an all-time high of 13,197 during the 2024–25 school year. The number of mediations actually held also reached a record high of 7,336.

However, the agreement rates tell a more complicated story.

Overall, 47% of mediations resulted in agreements, compared with an average of 66% between 2014 and 2019.

The most interesting distinction involves whether mediation was associated with a due process complaint.

According to CADRE:

• 67% of mediations unrelated to due process resulted in agreements.
• 32% of mediations associated with due process resulted in agreements.

This difference is significant. CADRE’s data suggest that mediation may be more successful when families and districts attempt to resolve disagreements before they become part of formal due process litigation.

That does not mean early mediation will resolve every disagreement. Some disputes involve fundamental differences over evaluations, placement, services, or compensatory education that cannot easily be resolved through negotiation.

Nevertheless, CADRE’s findings reinforce the potential value of providing meaningful opportunities for early dispute resolution.

Due Process Complaints: The New York Effect

At first glance, CADRE’s report appears to document a dramatic national decline in due process complaints.

Nationally, reported due process filings decreased by 38.6%, representing 15,496 fewer complaints than the previous year.

However, CADRE explains that this decline was largely the result of a procedural change in New York, not necessarily a reduction in special education disagreements.

New York established a separate Enhanced Rate Equitable Services (ERES) unit and moved designated cases out of its state IDEA due process system. This change contributed to a decrease of 16,389 reported New York due process filings between 2023 and 2024.

Previously, New York accounted for more than 62% of national due process filings since 2020, including more than 68% in 2023.

When New York is excluded, CADRE reports that due process complaints actually increased by 6.7% nationally between 2023 and 2024.

This distinction is essential. Without understanding the New York reporting change, readers could incorrectly conclude that IDEA due process litigation is declining dramatically across the country.

CADRE’s analysis demonstrates why national dispute resolution statistics must be interpreted carefully, particularly when a single state accounts for such a substantial percentage of filings.

Most Due Process Complaints Never Reach a Hearing

Another important finding involves what happens after a due process complaint is filed.

CADRE reports that, excluding New York, approximately 74% of due process complaints were withdrawn, dismissed, or resolved without a hearing during the 2024–25 reporting period.

Only 8.57% were fully adjudicated, although that percentage represented an increase over the preceding year.

Resolution meetings also increased. CADRE reports that 5,313 resolution meetings were held, representing approximately 40% of due process complaints filed when New York is excluded.

Settlement agreements during the resolution period increased to 33%, although that remains below the 44% reported in 2015.

These statistics reinforce an important point: Filing a due process complaint does not necessarily mean that a case will proceed to a full administrative hearing.

Many disputes are resolved, withdrawn, or dismissed before reaching that stage. However, CADRE’s data do not establish whether families obtained the educational remedies they sought or whether negotiated agreements produced better outcomes for students.

More Students, More Disputes?

CADRE also examined the relationship between increasing dispute resolution activity and the growing number of students receiving special education services.

The report identifies a parallel increase in IDEA Part B child counts and dispute resolution activity between 2020 and 2024, after accounting for New York’s procedural change.

CADRE appropriately cautions that this relationship does not establish causation.

More students receiving services may contribute to a greater number of disputes, but other factors could also be involved, including increased awareness of IDEA rights, disagreements over service delivery, or changes in administrative practices.

An important next step would be to examine dispute resolution activity relative to the number of students served, rather than relying exclusively on raw complaint totals.

CADRE’s Emphasis on Early Dispute Resolution

CADRE concludes its report by emphasizing the importance of collaborative dispute resolution approaches.

In particular, CADRE highlights IEP facilitation, mediation unrelated to due process, and other locally developed practices that help parents and educators address disagreements before they escalate.

CADRE also recognizes the work of state educational agencies, school districts, and parent training and information centers in developing and implementing early conflict resolution strategies.

This is a particularly important message for school administrators.

Too often, disagreements are allowed to develop into formal complaints because communication has broken down, concerns have not been addressed promptly, or families believe they have no meaningful opportunity to resolve problems at the local level.

CADRE’s report supports continued investment in collaborative approaches that can resolve disagreements more efficiently while preserving productive family-school relationships.

The organization also offers practical resources through its website, including the CADRE Continuum, resources on early dispute resolution practices, and national and state dispute resolution data dashboards.

What Should School Districts Take Away?

CADRE’s findings suggest several priorities for school districts.

First, districts should examine patterns in complaints and disagreements, not simply count the number of formal hearings they experience. Repeated disputes over evaluation timelines, IEP implementation, related services, progress monitoring, or placement decisions may indicate systemic concerns requiring administrative attention.

Second, meaningful early dispute resolution should become a routine part of special education administration rather than an option considered only after conflict escalates.

Third, districts should recognize that resolving a dispute is not necessarily the same as correcting the underlying problem. Agreements must be implemented, services must be delivered, and student progress must be monitored.

Finally, state agencies should pay particular attention to the timeliness of written state complaint investigations. CADRE’s finding that only 78% were resolved within the 60-day timeline deserves serious attention.

Final Thoughts

CADRE’s October 2026 report offers an important reminder that IDEA dispute resolution is not simply about litigation. It is about whether parents and schools have effective mechanisms for identifying disagreements, addressing concerns, ensuring compliance, and protecting students’ educational rights.

The increase in written state complaints, record levels of mediation requests, and continued growth in due process filings outside New York suggest that demand for formal dispute resolution mechanisms remains substantial.

At the same time, CADRE’s findings regarding mediation demonstrate the potential benefits of addressing disputes before they become adversarial.

For school leaders, the lesson is straightforward: The best dispute resolution system is not necessarily the one that produces the fewest complaints. It is the one that identifies problems early, addresses them effectively, and results in better educational services for students with disabilities.

CADRE’s latest data provide a valuable starting point for evaluating whether our current systems are accomplishing that goal.

Source: Center for Appropriate Dispute Resolution in Special Education (CADRE). (2026, October). Trends in dispute resolution (DR) under the IDEA: 2024–25 (SY 2024). 

https://cadreworks.org/files/2026-dispute-resolution-data-trends

Readers interested in examining state-specific patterns can consult CADRE’s National Data Summary and National and State Dispute Resolution Data Dashboard at 

https://cadreworks.org/national-state-dr-data-dashboard