You are correct! And without knowing your specific state's laws and regulations (which you might look and and add, if applicable), I believe you are citing everything you need to. There is no requirement in the IDEA that reevaluations must be done concurrent with or before an annual IEP meeting. You can have the annual meeting, and then another meeting following the results of the reevaluation being available. But I would also ask the question: What are you basing this requirement on? If a school district policy, may I please have a copy?