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In this study we investigate the impact of COVID-19 on education and opportunity to learn (OTL) for students with significant cognitive disabilities, using data collected via an annual teacher survey for students participating in the Dynamic Learning Maps (DLM) alternate assessment. Guided by the OTL literature, we developed a set of indicators from the survey data and compared them in 2019 and 2021. Next, we examined relationships between survey items on instructional conditions during COVID-19 and OTL. The findings to date show slight differences in OTL over the two years, and small impacts of instructional conditions in 2020-21 on OTL. We discuss caveats to aid in interpretation of the findings.