sally, sorry I was unclear. I agree that the report card as it stands is not illegal. I was making a side comment that many if not most schools actually are HIPAA entities...but, as you note, FERPA trumps that.

The second point, however, has to do with disability rights in public schools admissions. Which, of course, is not really part of the OP's question. Your advice to have sped/504 records destroyed is more relevant to that.

...pronounced like the long vowel and first letter of the alphabet...