Architecture of Grace · Crosswalk
IDEA & Special Education Law Crosswalk
Architecture of Grace is a relationship-centered SEL curriculum, K through adult, with an optional instrument layer and an IEP progress monitor. This crosswalk shows where the framework sits against IDEA, Section 504, FERPA and the Protection of Pupil Rights Amendment — what it may lawfully be used for, what it may not, and what a district owes before the first administration. The full analysis, with quoted regulatory text and the state overlay, is Document 10 of the Master Documents Series. This is an alignment reference, not legal advice.
What changed on August 26, 2026
What changed on August 26, 2026.The U.S. Department of Education's Student Privacy Policy Office issued a Dear Colleague Letter taking the position that a survey administered by a school official is required under PPRA, that instruments probing "emotional wellbeing, internalized distress, social interactions" fall inside the protected category of mental or psychological problems of the student, and that "the opt-out provisions in PPRA do not apply as a way of securing parental consent." It is sub-regulatory guidance and its reading of the statute is contested. This framework treats it as binding on its instrument layer anyway, and recommends districts obtain written parental consent. Document 10, Chapter 8 sets out the contest in full.
The Separation Principle · three objects, three regimes
| Object | What it is in the product | Governed by | Consent posture |
|---|---|---|---|
| The curriculum | Six books K–adult, lessons, anchor charts, scenario decks, worksheet packs, autism-adapted sets, Home Editions, Talk It Out, Quiet Space | Instruction. Board curriculum-adoption policy. PPRA's instructional-materials inspection right — satisfied by publishing the material. | None required. Curriculum exemption on request. |
| The academic probes | Thirty interactive activity pages — mathematics, number concepts and data, science vocabulary — each with an item-by-item record | Academic assessment. Expressly outside PPRA's "instructional material" definition, 20 U.S.C. 1232h(c)(6)(A), and inside the (c)(4)(A) tests-and-assessments exception. | None required. |
| The instrument layer | The nineteen-statement self-reflection, Daily Check-In, School-Day Exit Slip, Home Check-In, Home Observations, adult team check-in, This Is Me | PPRA protected-information survey; IDEA screening under 34 CFR 300.302. | Written consent, in advance, with the questions attached. |
The curriculum runs with the instrument switched off.Every lesson, chart, card, worksheet and activity page functions without a single student answering a single reflection statement. That is not a talking point — it is the architectural fact the whole compliance position rests on, and a district should verify it before adopting.
IDEA · what the framework may and may not do
| Provision | What it requires | Where the framework sits |
|---|---|---|
| 300.302 · Screening is not evaluation | Screening by a teacher "to determine appropriate instructional strategies for curriculum implementation" is not an evaluation. | The shield the check-in relies on. Purpose-bound: lost the moment the instrument is run on one suspected child, or read for eligibility, IEP content, or whether a behaviour plan is working. |
| 300.300(d)(1) · Consent exception | No consent needed to review existing data, or to administer something given to all children. | Check-in history, Daily Log, exit-slip patterns and probe records are existing data under limb (i) — the correct doctrinal home. Limb (ii) is not relied upon where a district runs consent for everyone. |
| 300.111 · Child find | Suspicion triggers the duty, "even though they are advancing from grade to grade." | A flag is knowledge, and knowledge starts the clock. A flag is a reason to ask, never a finding — and screening data may not be used to delay an evaluation either (OSEP Memo 11-07). |
| 300.304(b)(2) · Single-measure bar | No single measure as sole criterion for eligibility and for determining an appropriate educational program. | The trailing clause governs goal-writing. No goal is emitted from the instrument alone. Team-entered, multi-source data is the only defensible basis. |
| 300.304(c)(1)(iii)–(v) · Validity for purpose | Instruments used only for purposes for which they are valid and reliable, by trained personnel, per the producer's instructions. | A duty that runs to the publisher. Disclosure below. |
| 300.305(a)(1) · Existing data | Review of "current classroom-based … assessments, and classroom-based observations" and "observations by teachers." | Where this framework's data legitimately belongs. Contributory, never determinative. |
| 300.320(a)(3) · Progress reporting | How progress toward annual goals will be measured, and when periodic reports are provided. | The framework's strongest ground. Dated measurements, baseline, target, aimline, four-point decision rule, periodic report concurrent with report cards. No consent question; no validity question. |
| 300.503(a)(2) · Prior written notice | Notice owed when an agency refuses to evaluate — and it must describe what the agency relied on. | The most commonly missed notice in child find. The framework's disclosure below is what lets a district write a compliant one. |
| 300.502 · Independent evaluation | A parent who disagrees with the agency's evaluation may seek an IEE at public expense. | The trap: a district that calls the screener its evaluation must fund the IEE and cannot defend its own instrument, because 300.302 says a screening is not an evaluation. |
| 300.530(d)(1)(ii), (f) · FBA / BIP | An FBA is required on a disciplinary change of placement, "as appropriate," and where conduct is a manifestation. | Not triggered by a screening flag; no BIP is a standard IEP component; 300.324(a)(2)(i) says consider. But an FBA, when done, is an evaluation — and reviewing behaviour data to revise an IEP's supports is a reevaluation requiring consent (OSEP, Letter to Sarzynski 2008, Letter to Gallo 2013). |
The publisher's disclosure under 34 CFR 300.304(c)(1)
- What it is. A nineteen-statement self-report reflection across three domains — Emotional Regulation & Well-Being, Self-Compassion & Growth Mindset, Social Competency & Repair. Eighteen are scored. Item 19 is asked and displayed, contributes to no domain and no composite, and exists to raise a safety flag.
- Valid for. Instructional planning at class and individual level: what to teach next, which competency to emphasise, which student to have a conversation with.
- Not valid for, and not offered for. Determining disability, disability category, eligibility, or placement. Serving as the sole basis for any IEP goal, present level or service decision. Diagnosis of any kind.
- Independent validation status. The instrument has not been independently validated. It is disclosed as such here and everywhere the framework describes it.
- Who may administer it. Any teacher, for instructional screening. Nobody, for evaluation purposes — 300.304(c)(1)(iv) requires trained personnel for an evaluation instrument, and this is not one.
Records · FERPA and Part 300 Subpart F
| Provision | What the framework does about it |
|---|---|
| 34 CFR 99.3 · sole possession | The framework does not claim it. The observation log syncs, prints into a meeting brief, and feeds the charts — each of which independently defeats the exclusion. Treat everything recorded as an education record by default. |
| 99.31(a)(1) · school official | Requires the agency's direct control over use and maintenance of records. Where the optional sync carries identifiable student data, the destination spreadsheet must be district-owned, inside the district's domain and data agreement. An educator's personal spreadsheet is for de-identified practice data only. |
| 300.613 · inspect and review | Records must be producible within 45 days, and before any IEP meeting or hearing. The framework's export and print paths exist to make that possible from the teacher's own computer. |
| 300.623 · safeguards | One named official; training; an access list maintained for public inspection. A district configuration decision, made once, in writing. |
| 300.624 · destruction | Destroyed at parental request. The framework's removal is symmetric with its backup, so nothing survives a deletion in a file restored later. |
Section 504 · the parallel duty
| Provision | Effect |
|---|---|
| 104.35(c)(1) | More hospitable than IDEA: "teacher recommendations," "social or cultural background, and adaptive behavior" are named sources. A documented check-in pattern is a legitimate input among several. |
| 104.35(b)(1) | Stricter word: materials must be validated for the specific purpose. The instrument is not, and says so — so it may inform a 504 team, never function as evaluation material. |
| 104.35(a) | Evaluation required before any significant change in placement. Using a flag or band to move a student's setting or supports without the group process is a 504 violation on its own. |
Before the first administration · the seven-item check
- Written consent obtained, with the nineteen statements attached, not summarised, in the family's language, at least fourteen days ahead.
- Four boxes separated on the form: the curriculum · the reflection · the individual record · the sync.
- An alternative activity prepared that does not identify who declined. A child must not be able to tell that their family said no.
- The sync destination is a district-owned spreadsheet under the district's data agreement — or the sync is off.
- One named official under 300.623(b), and the access list maintained for public inspection.
- Retention set to the number this state requires. Illinois: five years, as a temporary record. Louisiana: destruction within thirty days.
- The response pathway named in writing: who owns a trusted-adult flag, who owns a self-protection flag, and by when. Do not screen more students than the building can follow up with.
Eight states sit above the federal floor
Eight states sit above the federal floor.Utah, Texas, Arizona, North Carolina, Louisiana, Iowa, Montana and Kansas each require more than PPRA does — advance copies of the questions, fixed notice periods in days, per-violation penalties, or fixed destruction windows. Illinois requires less (105 ILCS 5/2-3.203 specifies an opt-out) and therefore sits directly on the federal floor, where the August 2026 letter lands hardest. Document 10, Chapter 13 is the map. Counsel should read it against current state text before adoption.
On the site today
Where each thing named above lives now.
- Room 12 · Room 18 · Room 36 · Room 104 · Room 207 — the five SEL rooms, each with its lessons, workbook, anchor charts and Grace in Practice.
- Quiet Space and the calm & regulation tools; Talk It Out.
- The Educator Dashboard — the Daily Check-In, exit slips, the Daily Log, probe records, the adult team check-in, IEP Progress, the meeting brief, and the sync and export settings.
- Family Mode — the home check-in and the family's own observations.