“Legally, grades are not the only measure of need for special education services and an IEP. Sadly, many schools steadfastly believe that a kid has to be failing to qualify for an IEP. That’s not what the law says.”
The threshold is has a disability AND cannot achieve a meaningful and measurable educational benefit without specialized services.
There is no universal definition for how educational access and benefit should be measured.
However, in my evaluations, report card grades hold the lowest weight in my analysis.