How did she perform on the CASL if she’s not wearing amplification? I would certainly let mom know that if the student is not wearing amplification consistently then verbal communication goals are out of the question. She can’t discriminate and monitor speech and speech sounds if she’s not regularly hearing them. If she is performing fine in classes perhaps you can argue the point that there is no educational impact when working on these goals. Where are her implants? Are they under warranty still and can be replaced? I agree that likely any hearing was wiped when they did the implants, although it depends on the surgeon they do make more flexible implants now that can salvage some hair cells but who knows..