We have a program here through the Early Learning Institute that parents can agree to have the child evaluated at your setting and their's and based on the evaluation recommend services, further evaluation, etc. I had a boy evaluated last summer at 22ish months for lack of speech and some physical stuff. He had maybe 2 words? Not mama, dada, etc. but ball and hi I think? Anyway, we had him evaluated (at a 12-15 month at almost 2) and he qualified for speech and physical therapy and has recently started occupational therapy as well. At 3 they can receive services through the school district and special preschools for therapy on site.
I would do the same evaluation from Dec and then one for his next "milestone" and show them the areas he's behind, and soon to be even further behind, the and recommend formally (in writing on letterhead to keep in his file) that he be evaluated by a professional for delays. Reiterate to them that he's falling further behind every time he doesn't pass his milestones. So if he's behind in even a 2yr old sheet that's a significant period of time. Just be matter of fact and not judgey or in a sympathetic "I'm so sorry" manner. Explain that this is just part of "your job" and if you didn't recommend this that you wouldn't be following protocol for the state, licensing, etc.

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