Special Education: Improved Allocation of Resources Could Help DOD Education Activity Better Meet Students' Needs
Fast Facts
Military families can find it hard to get special education services for their children with disabilities—especially in overseas locations.
Students' individualized education programs outline how many minutes of specialized instruction they are legally required to receive. But Department of Defense schools don't consider this information for special education staffing. This may contribute to not having staff available to deliver enough specialized instruction, or to delays in services.
Our recommendations address this and other issues we found.
Highlights
What GAO Found
The Department of Defense Education Activity (DODEA) operates DOD's school system and provides special education and related services for about 15 percent of its students worldwide. However, GAO found that related services provided by the military branches for students in overseas locations—such as physical therapy—were often limited or unavailable, resulting in service delays or disruptions. These services are required by students' individualized education programs—legally binding written plans describing the services students are to receive. GAO found delays in service delivery for students in 44 of DODEA's 114 overseas schools for 2022–2023 (see figure). Further, from school years 2018–2019 through 2022–2023, at least six cases took more than a year to resolve. Service delays and disruptions can negatively affect students' academic progress, according to related service providers and parents GAO interviewed.
Days Taken to Resolve Services Delays for DODEA Students' Physical and Occupational Services, School Year 2022–2023
GAO also found that DODEA's staffing formulas for special education teachers are based on student headcounts and do not consider the required service minutes (i.e., minutes of specialized instruction) specified in students' individualized education programs. Because required service minutes can vary widely among students, allocating staff without considering them may contribute to staffing shortages and to delays in delivering required services.
DODEA school staff and parents at the schools GAO visited identified several key obstacles to providing special education, including insufficient training and guidance. First, at 12 of 14 schools, paraeducators (staff providing extra help to students) reported receiving little to no onboarding training for special education. For example, paraeducators across all three DODEA regions told GAO they had not received DODEA-required crisis training, despite working with students with behaviors needing crisis response. Further, all regional officials and DODEA staff in 13 of 14 schools described insufficient procedural guidance on how to implement DOD's special education policies. School staff at seven schools said that without clear guidance, service delivery is inconsistent across schools. DODEA officials said they will update procedural guidance by school year 2025–2026, and staff should refer to DOD policy in the interim. Communicating which resources staff should currently use to interpret DOD policy—consistent with DODEA's goals for internal communication—would help promote a shared understanding of how to comply with DOD special education policy.
Why GAO Did This Study
Meeting the educational needs of children with disabilities attending DODEA schools poses unique challenges. For example, children in military families often relocate frequently, which requires finding appropriate special education and related services each time.
Senate Report 118-58 includes provisions for GAO to examine special education and related services at DODEA schools. GAO examined (1) the extent to which DOD makes these resources available to meet the needs of DODEA students and (2) key obstacles to providing these resources to DODEA students that were reported by DOD staff and families.
GAO analyzed DODEA data on student enrollment, staffing, and service provision. GAO also visited 14 DODEA schools in seven military communities worldwide, selected for variation in number of students with disabilities and location. Across the visits, GAO held 98 group interviews with DODEA teachers, principals, and other stakeholders. GAO also reviewed relevant federal laws and policies and interviewed DOD and DODEA officials.
Recommendations
GAO is making five recommendations to DOD, including to (1) incorporate students' required service minutes into special education staffing formulas, (2) ensure paraeducators receive required crisis training, and (3) communicate the resources staff should currently use to interpret DOD special education policy. DOD partially agreed with all five recommendations, as discussed in the report.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to revise its special education staffing formulas to incorporate students' service minute requirements specified in IEPs among the factors it considers. (Recommendation 1) |
In March 2025, DOD partially concurred with this recommendation. In July 2025, DOD stated that it no longer concurs with this recommendation. Specifically, it said that DODEA reviewed its staff-to-student ratios in special education classrooms and found them to be lower than national averages. The agency also said that basing staffing allocations on a "simple tally" of IEP service minutes is operationally unfeasible and maintained this position as of March 2026. We agree that only using IEP service minutes to determine staffing allocations would not be appropriate, and we did not recommend doing so. However, required IEP service minutes provide critical information on the frequency and duration of services required to meet individual student's' needs. Further, they can vary widely among students. Moreover, at 13 of the 14 DODEA schools we visited-located in the three largest DODEA school districts, which collectively educate 50 percent of all DODEA students receiving special education services-school staff told us that basing staffing formulas solely on student headcounts does not allow staff to provide the required number of service outlined in students' IEPs. This is particularly significant, given that at all 14 schools we visited, DODEA school staff cited special education staffing shortages-and resulting heavy workloads-as an obstacle to educating students with disabilities. Moreover, they told us that staffing shortages impact the quality and frequency of services for students receiving special education. By allocating staff in a way that considers students' legally required IEP minutes, DODEA could better ensure that students receive the support to which they are entitled to make progress towards their educational goals.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to ensure that any special education paraeducators who work with students who may need behavioral supports receive crisis training. (Recommendation 2) |
As of July 2025, DODEA expanded its crisis training contract for all staff, beginning in school year 2025-2026. In February 2026, DODEA distributed a memorandum agency-wide to inform staff about the crisis training and where to access the training modules. Additionally, as of May 2026, DODEA implemented a centralized training completion tracking system to ensure consistent, agency-wide compliance and support for students and staff.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to provide supplemental instructional materials to special education teachers agencywide to help them adapt the general education curriculum for students with IEPs. (Recommendation 3) |
DOD partially concurred with this recommendation. In school year 2025-2026, DODEA launched professional learning modules focused on designing Specially Designed Instruction (SDI) and evidence-based strategies in reading and math. Additionally, in September 2025, DODEA issued a memorandum to communicate the allocation of dedicated training time for special educators and related service providers, and to outline access to training resources. These efforts are encouraging and demonstrate progress toward helping teachers modify the general education curriculum for students with IEPs. Still, as of May 2026, DODEA maintained that it would not pursue any singular, centralized purchases of supplemental instructional materials, because doing so may not account for the individualized nature of student needs and would require significant investment. However, there are other ways that access to supplemental materials could be made available agencywide. For example, teachers suggested having a specialist dedicated to helping them find instructional tools to meet individual student needs. The fact remains that DODEA regional, district, and school-level staff representing the majority of DODEA students expressed significant concerns about the lack of access agencywide to instructional materials for tailoring special education to students' needs, noting that staff in some districts and regions had access while others did not. Further, many special education teachers told us that the general curriculum materials they have do not meet their students' needs. We maintain that agencywide access to appropriate supplemental instructional materials would better help DODEA teachers to support their students while allowing them to tailor instructional materials to students' unique needs. Additionally, not having to constantly "reinvent the wheel", as some educators described it, it could allow teachers more time to teach and may improve the quality of support students receive. We will continue to monitor DODEA's efforts in this area.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to make more specialized reading interventions accessible across all DODEA locations to students with specific learning disabilities, including dyslexia, that impact their ability to read. (Recommendation 4) |
In November 2025, DODEA issued a memorandum agency-wide announcing that it is strategically investing in a targeted reading intervention called Read 180 for grades 3-5 to address critical literacy development needs. As of May 2026, DODEA implemented Read 180 during the 2025-2026 school year. Additionally, DODEA provided access to other reading interventions during the same school year to support DODEA students across all grade levels. These efforts will help ensure that students with reading-related disabilities, including dyslexia, receive the same opportunities to learn to read, regardless of which DODEA school they attend.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to communicate its timeframes for its new procedural guidance on special education and what resources staff should use to interpret the DOD policy while that guidance is being developed. (Recommendation 5) |
As of March 2026, DODEA launched a three-phased rollout of special education policies starting in school year 2025-26 to improve clarity, consistency, and compliance. As part of this rollout, in April 2026, DODEA issued Administrative Instruction (AI) 2500.15, effective July 2026, on special education compliance. AI 2500.15 establishes policy, assigns responsibilities, and implements procedures for the provision of special education services to DODEA students. This instruction provides key procedural guidance that teachers told us they needed.
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