Well, technically I don't think it does...
but failing grades are a lot more convincing. My son, for example, had an IEP based on ADHD and some fine motor issues. WITH the IEP in place - he was excelling. Then, he got a new teacher, who decided on her own NOT to follow the IEP (ya know, since he was doing so well) and his grades immediately plummeted to Cs and Ds. Based on the grades, I was able to get the IEP enforced.
So no - it is not based on grades alone....but it is more of an uphill battle if the grades are OK.
It's terrible that it always has to be so difficult.
((((hugs)))