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Committee backs permission to publish revised COMAR on students at risk for reading difficulties
Summary
The committee recommended permission to publish a rewritten COMAR (13A.00.03.08) that would expand universal screening, require MSDE-approved screeners, mandate diagnostic surveys and student reading improvement plans, strengthen MTSS requirements, include students with IEPs in screening, and change the reporting deadline to Sept. 1.
The Education Policy Committee voted to recommend permission to publish a substantially revised COMAR regulation governing identification and support for students at risk for reading difficulties.
Christina Rodriguez, manager of literacy programs and initiatives at MSDE, told the committee the proposed 2025 revision replaces the original 2021 regulation adopted to implement the Ready to Read Act (Maryland Education Code) and expands and standardizes screening and intervention practices across LEAs.
Key changes in the proposed regulation include:
- Universal screening for all kindergarten through third-grade students three times per year (fall, winter and spring), with initial-year screenings completed within the first 60 days of the school year.
- A requirement that LEAs use MSDE-approved screening instruments that assess phonological awareness, phonemic awareness, sound-symbol recognition, decoding, fluency, and rapid automatized naming, and that screening be administered by trained school personnel.
- A requirement that, when a screener identifies a student as at risk, an MSDE-aligned diagnostic survey be administered and a student reading improvement plan (SRIP) established within 30 days describing specific interventions, frequency and intensity, and progress monitoring.
- Clearer definitions and expectations for MTSS tiers (Tier 1 core instruction; Tier 2 supplemental instruction; Tier 3 intensive individualized interventions) and explicit provisions that students with IEPs be screened and considered for SRIPs or IEP revision as appropriate.
- Reporting and accountability adjustments, including moving the annual LEA data submission deadline to Sept. 1 and requiring disaggregation by grade, race, disability status, multilingual learner status and FRPM eligibility.
Rodriguez said MSDE is staging full implementation so that universal screening would be required for K 3 in 2025 26 and that diagnostic surveys, MTSS procedures, SRIPs and enhanced reporting would be phased in during 2026 27. She said retention language was not included in the revised COMAR because retention is governed by separate statute (MD Code, Education — 7-202).
Committee members expressed support for the direction and asked MSDE to clarify how SRIPs should align with IEPs. Committee member Dr. Lewis asked for a clearer statement that SRIPs and IEPs should not be duplicative and that IEP teams should consider screening results when determining needed services; MSDE said it would refine the language and follow up.
The committee voted unanimously to recommend permission to publish the revised COMAR, with instruction to MSDE to clarify wording around IEP coordination before public publication.
Why it matters: The revisions standardize screening tools and timelines, require diagnostic follow-up and individualized planning, and strengthen reporting and equity-oriented disaggregation. The changes would affect screening and intervention practice in every Maryland LEA serving K 3 students.
