There is no federal rule that a school SLP must make up every missed speech therapy session. IDEA requires that services be made available “in accordance with the child's IEP,” and the IEP states the anticipated frequency and duration of speech services. Whether missed sessions deny a student a free appropriate public education (FAPE) is decided case by case, and the IEP team must consider their impact on the student's progress, according to ASHA's account of federal guidance. Make-up rules come from states and districts, and they are common: in ASHA's 2024 Schools Survey, 79% of school SLPs who provide services had to make up missed sessions at least in some circumstances.
This is general information, not legal advice. Your state education agency and your district policy decide the details. Sources were checked on 1 November 2026.
What does IDEA require for speech therapy minutes?
Speech-language pathology is a related service under IDEA (34 CFR 300.34). Two parts of the regulations matter for minutes:
The IEP must state “the projected date for the beginning of the services and modifications … and the anticipated frequency, location, and duration of those services and modifications” (34 CFR 300.320(a)(7)). Note the word anticipated.
Services must be made available “in accordance with the child's IEP” (34 CFR 300.323(c)(2)).
Neither section mentions make-up sessions or compensatory services. That is why the answer to “do I have to make it up?” lives in federal guidance, state guidance and district policy.
What has the U.S. Department of Education said about missed sessions?
ASHA asked the Office of Special Education Programs (OSEP) about missed speech sessions. As ASHA reports OSEP's answer:
“The IDEA Part B Regulations do not address this issue.”
Whether missed sessions deny FAPE must be decided on a case-by-case basis, and “each child's IEP team must consider the impact of the missed sessions on the child's progress and performance.”
“States and districts should not be establishing a general policy for making up missed sessions.”
“It should not be the responsibility of the speech-language pathologist (SLP) to find their own substitute.” Districts are responsible for obtaining qualified professionals.
OSEP's 2021 Return to School Roadmap, written for pandemic disruptions, adds a point about compensatory services: “Neither IDEA nor its implementing regulations expressly address who must make the determination of whether—and if so, what—compensatory services are necessary.” It then points to the same kind of individualized discussion an IEP team would hold.
Do you have to make up a session when the student or the SLP is absent?
It depends on why the session was missed. The Wisconsin Department of Public Instruction published one of the clearest cause-by-cause breakdowns in October 2024. Other states differ, so treat it as an example, not your rule:
Why the session was missed | Wisconsin guidance (2024) |
|---|---|
Student absent, occasionally | “No compensatory services required for occasional student absences.” If the district made the service available at the scheduled time, it generally does not have to arrange another time. |
SLP absent, occasionally (illness, IEP meeting, conference) | “Generally, the service provider should be expected to schedule make-up service.” One missed session made up on another day “is not likely a denial of FAPE.” |
Repeated SLP absences | “Compensatory services may be required if a combination of events or absences of school personnel lead to chronic interruptions resulting in a denial of FAPE.” If patterns emerge, the IEP team should meet. |
SLP position vacant | “Compensatory services must be considered.” Parents must be notified when a vacancy affects services. |
Student taking state-mandated tests | “No makeup sessions or compensatory services are required.” |
School closed (weather, breaks, holidays) | “Generally, no compensatory services are required.” |
New York is stricter for one group. Its policy for preschool special education itinerant services (SEIS), effective September 1, 2015, says providers “must arrange to provide students with make-up sessions when the missed sessions were missed due to staff absence,” and “may, but is not required to, make up sessions for unexcused student absences.” Make-ups should start “within the same week as the missed session” when possible. It covers preschool itinerant services, not school-age therapy.
How common are make-up rules for school SLPs?
ASHA's 2024 Schools Survey asked school SLPs who provide services whether they had to make up missed sessions:
42% had to make them up, but only in a few circumstances.
37% always or almost always had to make them up.
20% never or almost never had to.
The same survey puts the median caseload at 50 students, against a median of 40 that SLPs called manageable, and reports an average of 23 hours a week in direct intervention and 6 hours on documentation. Make-ups come out of that same week. More numbers on the workload are in our SLP statistics.
Are compensatory services minute-for-minute?
Not necessarily. Wisconsin's guidance says compensatory services “are not necessarily provided minute-for minute but are based on what the IEP team determines is needed.” It also tells districts not to set a fixed number of missed sessions that counts as a denial of FAPE. Instead they weigh the number of missed sessions or minutes against the amount in the IEP, and the effect on the student's progress.
How do you write make-up language into the IEP?
ASHA's caseload and workload guidance offers two ideas:
“It may be helpful to clarify in the IEP document if, when, and how missed services may be made up.”
Write service time as “a quarterly, semester-based, or annual amount of time” instead of a fixed weekly slot, which leaves room to reschedule.
Illustrative wording to adapt to your district's forms: “Speech-language services: 360 minutes per quarter, individual or small group. Sessions missed because of provider absence or school activities will be rescheduled within the same quarter when possible.”
How do you track IEP service minutes?
Whatever your rule, you need a log. Wisconsin encourages districts to require that providers “maintain a log or schedule of when services are provided,” with the date and reason for any interruption. If your district bills Medicaid, CMS lists the minimum for each claim, including the date of service, the person providing it and the “nature, extent, or units of service,” and audits can ask for start and finish times and signed, dated notes.
A workable log has one row per scheduled session:
Date | Status | Minutes | Make-up | Note |
|---|---|---|---|---|
11/3 | Present | 30 | – | Group of 2 |
11/5 | Student absent | 0 | – | Illness |
11/10 | SLP unavailable | 0 | Owed | IEP meeting |
11/12 | Present | 30 | Makes up 11/10 | Individual |
Each month, total the minutes delivered against the IEP amount, and keep two counts apart: sessions you missed (usually owed) and sessions the student missed (usually not, unless absences become chronic). If minutes fall short, the IEP team needs both numbers. The session note for each date should match the log; our guide to SOAP notes for speech therapy shows a one-line note for an absent student.
How Ga-loo tracks minutes and make-ups
Disclosure: we build Ga-loo. When you finish a session on its Take data screen, you mark each student present, student absent, student unavailable, SLP unavailable or no school, enter the minutes, and flag make-up sessions. The student page adds up sessions and minutes by month and shows a count of make-ups owed: sessions you missed minus make-ups held. Student absences and no-school days are counted separately and are not treated as owed, because district rules differ. Attendance also goes into the session note, so the log and the note match.
Ga-loo also takes trial data live and builds a weekly practice pack for each speech-sound goal. Students are kept under a code, not a name. The free plan covers 3 students with no card; Pro is $79 a year. Start free.
Frequently asked questions
Do SLPs have to make up sessions missed for state testing?
Not under Wisconsin's guidance, which says no make-up sessions or compensatory services are required when a student misses services to take state-mandated tests. Other states and districts can set their own rules, so check yours.
Who finds a substitute when the SLP is out?
According to ASHA's account of OSEP guidance, it should not be the SLP's responsibility. Districts are responsible for obtaining qualified professionals.
How many missed sessions is a denial of FAPE?
There is no fixed number. OSEP treats it as a case-by-case question, and Wisconsin tells districts not to set a specific number. They look at the minutes missed compared with the IEP and at the effect on the student's progress.
Does the IEP have to say how missed sessions are made up?
No federal rule requires it. ASHA suggests stating in the IEP if, when and how missed services may be made up, which avoids arguments later.
Keep reading
Sources
IDEA regulations, 34 CFR 300.320 (content of the IEP): eCFR
IDEA regulations, 34 CFR 300.323 (when IEPs must be in effect): eCFR
IDEA regulations, 34 CFR 300.34 (related services): eCFR
ASHA, IDEA Part B Issue Brief: Missed Sessions: asha.org
OSEP, Return to School Roadmap: Development and Implementation of IEPs (QA 21-06), September 30, 2021: ed.gov (PDF)
Wisconsin Department of Public Instruction, Considerations for Interruptions in IEP Service Delivery, October 2024: dpi.wi.gov (PDF)
New York State Education Department, Policy on Make-Up Services of Missed SEIS Sessions, effective September 1, 2015: nysed.gov (PDF)
ASHA, 2024 Schools Survey: SLP Caseload and Workload Characteristics: asha.org (PDF)
ASHA Practice Portal, Caseload and Workload: asha.org
CMS, Delivering Services in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming (2023): medicaid.gov (PDF)