FCMAT
Fremont Unified School District Report
special education department and program review
Read the report at Fremont Unified School District ↗
Special Education Review
March 4, 2025
Fremont Unified School
District
Michael H. Fine
Chief Executive Officer
March 4, 2025
Patty Sandoval
Executive Assistant to the Superintendent and Board of Education
Fremont Unified School District
4210 Technology Dr.
Fremont, CA 94538
Dear Executive Assistant Sandoval:
In September 2024, the Fremont Unified School District and the Fiscal Crisis and Management Assistance
Team (FCMAT) entered into an agreement for FCMAT to conduct a review of the district’s special education
program. The agreement stated that FCMAT would perform the following:
1. Analyze special education teacher staffing ratios, class sizes and caseloads using statutory
requirements for mandated services and statewide guidelines, and make recommendations
for improvement, if any.
2. Review the efficiency of staffing allocations of special education paraeducators, per
Education Code requirements and/or industry standards, and make recommendations for
improvement, if any. Review the procedures for identifying the need for paraeducators,
including considerations related to the least restrictive environment and the processes
for monitoring the assignment of paraeducators and determining the need for continued
support from year to year (including classroom and 1-to-1 paraeducators).
3. Analyze staffing and caseloads for related service providers, including but not limited to
speech pathologists, psychologists, occupational/physical therapists, adaptive physical
education teachers and other staff who may be related service providers, and make
recommendations for improvement, if any.
4. Review the Special Education Department’s organizational structure and staffing
within the district’s central office to determine whether its administration, clerical and
administrative support, program specialists, teachers on special assignment and overall
function are aligned with those of districts of comparable size and structure, and make
recommendations for greater efficiencies, if any.
5. Review nonpublic school and nonpublic agency costs and placements, and make
recommendations for improving the process for placement and cost efficiencies, if any.
6. Review the district’s unrestricted general fund contribution to special education and make
recommendations for greater efficiency, if any.
7. Review special education transportation for efficiency and effectiveness, and provide
recommendations for potential cost savings measures, if any. The review will include
but not be limited to the role of individualized education programs, routing, scheduling,
operations and staffing.
Michael H. Fine • Chief Executive Officer
1300 17th Street – City Centre, Bakersfield, CA 93301-4533 • Tel. 661-636-4611 • Fax 661-636-4647
www.fcmat.org
This report contains the study team’s findings and recommendations.
FCMAT appreciates the opportunity to serve the Fremont Unified School District and extends its thanks to
all the staff for their assistance during fieldwork.
Sincerely,
Michael H. Fine
Chief Executive Officer
Table of Contents
Table of Contents
About FCMAT ...................................................................................................ii
Introduction ......................................................................................................iv
Background ...............................................................................................................iv
Study and Report Guidelines ................................................................................iv
Study Team ................................................................................................................iv
Executive Summary ........................................................................................v
Findings and Recommendations................................................................. 1
Background and Context - Transforming Education to Improve
Outcomes for Students with Disabilities .............................................................1
Identification for Special Education .....................................................................3
District Organization and Central Office Special Education Staffing ..........11
Special Education Teacher Staffing ....................................................................17
Special Education Paraeducator Staffing ........................................................23
Related Service Provider Staffing and Caseloads .........................................27
Unrestricted General Fund Contribution to Special Education ..................35
School Transportation ............................................................................................41
Appendix ........................................................................................................52
Appendix A — Study Agreement .......................................................................53
Fiscal Crisis and Management Assistance Team Fremont Unified School District i
About FCMAT
About FCMAT
Purpose and Services
FCMAT was created by the California Legislature to help California’s transitional kindergarten through
grade 14 (TK-14) local educational agencies (LEAs) avoid fiscal insolvency. Today, FCMAT helps LEAs iden-
tify, prevent and resolve financial, management, program, data, and oversight challenges; provides pro-
fessional learning; produces and provides software, checklists, manuals and other tools; and offers other
related school business and data services.
FCMAT may be asked to provide fiscal crisis or management assistance by a school district, charter school,
community college, county superintendent of schools, the state superintendent of public instruction, or the
Legislature.
When FCMAT is asked for help with management assistance or a fiscal crisis, FCMAT management and
staff work closely with the requesting LEA to meet their needs. Often this means conducting a formal
study using a FCMAT study team that coordinates with the LEA for on-site fieldwork to evaluate specified
operational areas and subsequently produces a written report with findings and recommendations for
improvement.
For more immediate needs in a specific area, FCMAT offers short-term technical assistance from a
FCMAT staff member with the required expertise.
To help meet the need for qualified chief business officials (CBOs) in LEAs, FCMAT offers four different CBO
training and mentoring programs that consist of 11 or 12 diverse two-day training sessions over the course
of a full year.
For agencies with professional learning needs, FCMAT offers workshops on specific topics. Popular topics
include associated student body operations, use of FCMAT’s Projection-Pro online financial forecasting
software, use of FCMAT’s Local Control Funding Formula (LCFF) Calculator, and data reporting for the
California Longitudinal Pupil Achievement Data System (CALPADS). FCMAT staff and management also
frequently make presentations at various professional conferences.
The California School Information Services (CSIS) service of FCMAT helps the California Department of
Education (CDE) operate CALPADS; helps LEAs learn about CALPADS, resolve data issues and meet
reporting requirements; and provides LEAs with training and leadership in data management. CSIS also
developed and continues to host and improve the Standardized Account Code Structure (SACS) web-based
financial reporting system for all California LEAs, and provides ed-data.org, which gives educators, policy-
makers, the Legislature, parents and the public quick access to timely and comprehensive data about TK-12
education in California.
Since it was formed, FCMAT has provided LEAs with the types of help described above on more than 2,000
occasions.
FCMAT’s administrative agent is the Kern County Superintendent of Schools. FCMAT is led by Michael
H. Fine, Chief Executive Officer, and is funded by appropriations in the state budget and modest fees to
requesting agencies.
Workshop schedules, manuals, presentation slide decks, Projection-Pro software, LCFF calculators, past
reports, an online help desk, and many other resources are available for download or use at no charge on
FCMAT’s website.
Fiscal Crisis and Management Assistance Team Fremont Unified School District ii
About FCMAT
History
FCMAT was created by Assembly Bill 1200 (Chapter 1213, Statutes of 1991) and Education Code 42127.8.
Assembly Bill 107 (Chapter 282, Statutes of 1997) added Education Code 49080, which charged FCMAT
with responsibility for CSIS and its statewide data management work, and Assembly Bill 1115 (Chapter 78,
Statutes of 1999) codified CSIS’ mission.
Assembly Bill 1200 created a statewide plan for county offices of education and school districts to work
together locally to improve fiscal procedures and accountability standards. Assembly Bill 2756 (Chapter
52, Statutes of 2004) gave FCMAT specific responsibilities for districts that have received emergency state
loans.
In January 2006, Senate Bill 430 (Chapter 357, Statutes of 2005) amended Education Code 42127.8, and
Assembly Bill 1366 (Chapter 360, Statutes of 2005) amended Education Codes 42127.8 and 84041. These
new laws expanded FCMAT’s services to include charter schools and community colleges, respectively.
Assembly Bill 1840 (Chapter 426, Statutes of 2018) changed how fiscally insolvent districts are administered
once an emergency appropriation has been made, shifting oversight responsibilities from the state to the
local county superintendent to be more consistent with the principles of local control, and giving FCMAT
new responsibilities associated with the process.
Fiscal Crisis and Management Assistance Team Fremont Unified School District iii
Introduction
Introduction
Background
Located in Alameda County, the Fremont Unified School District serves students in transitional kindergar-
ten through grade 12 (TK-12). According to DataQuest, 33,063 students in grades TK-12 were enrolled in
2023-24.
The district is a member of the Mission Valley Special Education Local Plan Area (SELPA), which is a
regional service delivery model for special education. In 2023-24, 10.05% of the district’s students were
identified as requiring special education.
In September 2024, the district and the Fiscal Crisis and Management Assistance Team (FCMAT) entered
into an agreement for FCMAT to conduct a review of the district’s special education program.
Study and Report Guidelines
FCMAT visited the district on December 16-17, 2024, to conduct interviews with central office and school
administrators, special education teachers, related service providers, and special education paraeducators.
Following fieldwork, FCMAT reviewed and analyzed data and documents. This report is the result of those
activities.
FCMAT’s reports focus on systems and processes that may need improvement. Those that may be func-
tioning well are generally not commented on in FCMAT’s reports. In writing its reports, FCMAT uses the
Associated Press Stylebook and its own short internal style guide, which emphasize plain language, capital-
ize relatively few terms, and strive for conciseness, clarity and simplicity.
Study Team
The study team was composed of the following members:
Carolynne Beno, Ed.D., CFE Colleen Patterson, MBA, CMA
FCMAT Chief Analyst FCMAT Consultant
Leonel Martínez Tim Purvis
FCMAT Technical Writer FCMAT Consultant
All team members reviewed the draft report to confirm accuracy and achieve consensus on the final
recommendations.
Fiscal Crisis and Management Assistance Team Fremont Unified School District iv
Introduction Executive Summary
Executive Summary
Identification for Special Education
According to DataQuest, the district’s census day enrollment has declined over the past five years, and its
special education enrollment has increased by five students. The percentage of the district’s transitional
kindergarten through 12 (TK-12) students enrolled in special education increased by 0.69 percentage points
between 2019-20 and 2023-24. In 2023-24, 10.05% of the district’s TK-12 students were identified as requir-
ing special education, which was a much lower percentage than in Alameda County or the state.
English learners and students who identify as Hispanic or Latino are overrepresented in the district’s spe-
cial education program, while students who identify as Asian are underrepresented. The district needs to
monitor this data and ensure it identifies all qualifying students with disabilities for special education.
In 2024-25, 80% of students enrolled in special education qualify under a primary disability category of
specific learning disability, autism or speech and language impairment. From 2019-20 through 2024-25,
the number of district students who qualify for special education under the disability category of autism
increased from 745 to 968, which is a 29.93% increase.
Special Education Staffing
Central Office
Fremont Unified has 3.57 full-time equivalent (FTE) fewer administrator/leadership positions and 1.17 FTE
fewer administrative support positions supporting its special education program compared to the surveyed
comparable school districts. In addition, Fremont Unified only has 3.7 FTE positions that require an admin-
istrative services credential supporting the special education program in its central office. This is unusual
in a district this size compared to what is observed across the state and may be one cause of the inade-
quate support from the Special Education Department’s leadership team identified by some staff during
interviews.
The Special Education Department’s eight program specialist positions do not require an administrative
services credential and are similar to a teacher on special assignment (TOSA) position in that the staff work
a 7.5-hour day and 192 days per year. This is far less than a typical program manager’s schedule, and these
staff cannot commit district funds and evaluate specialized itinerant and related service provider staff,
which were needs identified by staff during interviews. The district needs to assess the cost and benefit of
converting some of the program specialist positions into program manager positions, requiring an admin-
istrative services credential, to help meet the Special Education Department leadership needs identified in
interviews.
Resource Specialist Program
Districtwide resource specialist program (RSP) staffing is 5.54 FTE more than what is required to meet
the Education Code (EC) 56362(c) caseload standard. However, the students who receive support from a
resource specialist are not neatly distributed into groups of 28 across district schools, and the district is
attempting to implement an inclusive model. Thus, having more staffing than is required to meet the EC
56362(c) standard appears necessary to meet student needs.
Fiscal Crisis and Management Assistance Team Fremont Unified School District v
Introduction Executive Summary
The Circle of Independent Learning (COIL) Charter School is staffed 0.61 FTE RSP teacher below what is
needed to meet the EC 56362(c) caseload standard. Staff are evaluating how to increase RSP teacher sup-
port at COIL Charter School.
Special Day Class Programs
Most of the district’s special education class size goals are aligned with the industry standards, except for
its special day classes (SDCs) for students in preschool and in kindergarten through grade three, which
have a lower class size goal than the industry standards. The district needs to evaluate whether aligning its
SDC caseload guidelines for these programs with industry standards would allow it to reduce costs while
continuing to meet students’ needs.
The districtwide mild-to-moderate SDC teacher caseload average is below the industry-standard range
for preschool and elementary school classes. As a result, the district is staffed with 3.07 FTE more
mild-to-moderate SDC preschool teachers and 2.33-5.07 FTE more mild-to-moderate SDC elementary
school teachers (depending on the industry-standard range of 12-15 students per teacher) than what it
would need to meet industry standards. The districtwide extensive support needs SDC teacher caseload
average is within the industry-standard range for all school levels except for preschool, which is staffed
above the industry-standard range. As a result, the district is staffed with 2.33-2.70 FTE (depending on the
industry-standard range of nine or 10 students per teacher) more SDC preschool teachers for students with
extensive support needs than what it would need to meet industry standards. The district needs to evalu-
ate whether it can increase the class size goals for these school levels to meet industry standards and still
support student needs.
The districtwide counseling enriched SDC teacher caseload average is within the industry-standard range
of 8-10 students per teacher.
The districtwide moderate SDC teacher caseload average is 10.05 students. There is no industry standard
available to compare to the district’s moderate support needs SDC teacher staffing. However, like the
district’s SDC programs for students with mild-to-moderate and extensive support needs, the class size
average for the preschool program is much lower than other school levels.
Special Education Paraeducators
The district has established paraeducator staffing guidelines to assign special education paraeducators to
its RSP and SDC programs, which is a good practice. However, because the district does not use an adult-
to-student staffing ratio to determine paraeducator staffing, it may be over- or understaffed. The district
would benefit from adding the industry-standard adult-to-student ratio to its paraeducator staffing guide-
lines for SDCs, then determining whether it can reduce staffing while still meeting student needs.
In 2024-25, the district has 197.62 FTE 1-to-1 paraeducators assigned to provide 1-to-1 paraeducator support
and 5.38 FTE paraeducators who provide 1-to-1 and classroom paraeducator support. Although there is no
industry standard for comparison, this is high for a district of this size compared to what is observed across
the state.
Staff explained that the number of 1-to-1 paraeducators has grown because student support needs
increased following the COVID-19 pandemic and because teacher turnover results in inexperienced
teachers who need additional help in certain SDCs. Assigning more paraeducator support than neces-
sary is costly. In addition, although a parent/guardian or staff member’s request for a student to have
a 1-to-1 paraeducator may be well meaning, as explained in the “Causes and Consequences of High
1-to-1 Paraeducator Staffing” section of this report, according to the University of Colorado at Denver’s
Fiscal Crisis and Management Assistance Team Fremont Unified School District vi
Introduction Executive Summary
Paraprofessional Resources and Research Center, it can negatively affect the student’s education. The
district needs to consider the recommendations in the “Best Practices in 1-to-1 Paraeducator Assignment”
section of this report to reduce its reliance on 1-to-1 paraeducators.
The Special Education Department contracts with nonpublic agencies (NPAs) for paraeducators. Staff iden-
tified an inconsistency between the number of special education paraeducator position vacancies and the
number of paraeducators for which the Special Education Department contracts with an NPA. Staff esti-
mated the district contracts for 100 special education paraeducators but only has approximately 25 paraed-
ucator vacancies. The district needs to contract for no more than the number of vacant special education
paraeducator positions and to obtain administrative cabinet approval for any additional special education
paraeducator positions.
Related Service Providers
The district is staffed within the industry-standard range for teachers of students who are visually impaired
and is staffed almost exactly at the Education Code maximum caseload for speech and language patholo-
gists (SLPs) for school-age programs. The district is staffed above the industry standards for adapted physi-
cal education (APE) teachers, credentialed school nurses and school psychologists.
The district’s staffing for occupational therapists and SLPs supporting the preschool program is approxi-
mately double the industry standard, and its staffing for physical therapists for the entire district is three
times the industry standard. The district needs to review caseload projections, the assessment load, the
number of schools supported, travel time between schools, direct and consultation service minutes and
student needs to determine if staffing for these three providers can be reduced while still meeting student
needs.
The district is staffed significantly less than the industry-standard staffing level for teachers for students
who are deaf or hard of hearing. The district needs to review caseload projections, the assessment load,
the number of schools served, driving time between schools, direct and consultation service minutes, and
students’ needs to determine whether it needs to increase staffing for teachers of students who are deaf or
hard of hearing.
Nonpublic Agency and Nonpublic Schools Costs and Placements
In 2023-24, 68 district students attended a nonpublic school (NPS), which was a 24% increase over 2022-
23. District data indicates that its NPS expenditures went up by $3,198,388.24 between 2021-22 and 2023-
24, which is a 58.69% increase.
At the time of FCMAT’s visit, 67 district students were enrolled in an NPS; four of these were preschool age
students and 63 were in TK through grade 12. Half the preschool age and 65% of the school-age students
attending an NPS qualify for special education under the disability category of autism.
In 2023-24, the district’s average cost for a student to attend an NPS was $127,178, but it reduced its pro-
jected per student cost in 2024-25 to $125,724. The district projected a decrease in the number of students
attending an NPS and in NPS expenditures from $8,648,123.24 in 2023-24 to $8,172,068.91 in 2024-25.
However, in 2024-25, the district’s payments for NPS services through October 31, 2024, were 38% higher
than the same period in the prior year, and FCMAT projects the district has underbudgeted by approxi-
mately $9.3 million for the cost of all special education services.
Fiscal Crisis and Management Assistance Team Fremont Unified School District vii
Introduction Executive Summary
Unrestricted General Fund Contribution to Special Education
In 2023-24, the district’s adjusted unrestricted general fund contribution to special education was
$70,799,450, or 62.34% of total special education costs. Between 2021-22 and 2023-24, the district
incurred significant employee collective bargaining settlement costs and increased staffing expenses, and
its adjusted dollar amount of the general fund contribution has grown from $42,934,615 to $70,799,450,
which is a 64.90% increase.
In 2024-25, the district’s unrestricted general fund contribution as a percentage of total special education
costs, inclusive of adjusted indirect costs, is projected to increase to 69.14% based on first interim actual
projections and the district budget.
Transportation
The district’s transportation program expenses doubled between 2021-22 and 2023-24. The district’s
2024-25 adopted budget projects a decrease of $4,653,339 in transportation expenditures over
the previous year. However, based on historical program expenditures and a review of transporta-
tion expenditures for the first half of the 2024-25 fiscal year, FCMAT estimates the district will spend
approximately $13.4 million on student transportation in 2024-25, which is a 24.3% increase in expendi-
tures between 2023-24 and 2024-25.
In 2023-24, the district’s unaudited actuals financial report shows it spent $11,642 per student for
school transportation. FCMAT projects the district will spend $14,470 per student for school transpor-
tation in 2024-25. This is a high per-student cost and is partially caused by the district’s heavy reliance
on a contracted external transportation provider, which has a low load ratio of one to three students
per vehicle.
The district operates an internal transportation program and contracts with two external transportation
providers, Student Transportation of America (STA) and Pawar Transportation. Pawar Transportation is
a transportation network company (TNC) that serves 32.72% of all district special education students
using alternative transportation passenger vehicles. Unlike traditional yellow school buses, alterna-
tive transportation passenger vehicles transport a small number of students per vehicle. Their use
by districts is not unusual to meet certain student needs. However, the high percentage of students
served through Pawar Transportation in alternative transportation passenger vehicles is very unusual
based on what is observed across the state. This is also costly and needs to be reduced. Instead, the
district needs to explore expanding its district-operated bus routes to achieve a significantly greater
student load ratio per bus run, which could reduce its heavy dependence on contracted transportation
providers and its annual per-student transportation expense. If the district expands its district-oper-
ated bus routes, Transportation Department staffing changes to support this are recommended in the
“Transportation Department Staffing” section of this report.
In 2024-25, the district reported it provides transportation services for 1,207 students. Of this number, 281
students receive transportation for the district's Regional Occupational Program (ROP), and 926 students
receive transportation as a related service in their individualized education program (IEP). Based on what
is observed across the state, 10%-15% of special education students in most districts require transportation
as a related service. In contrast, the district reported that 27.8% of students with IEPs receive transporta-
tion services. This high percentage suggests that transportation as a related service may be identified too
Fiscal Crisis and Management Assistance Team Fremont Unified School District viii
Introduction Executive Summary
broadly and may not align with Individuals with Disabilities Education Act (IDEA) guidelines. Additionally, it
may indicate inconsistent use of the district’s transportation decision tree when determining transportation
needs. The high percentage of students receiving transportation as a related service significantly contrib-
utes to the district’s overall high transportation costs.
Fiscal Crisis and Management Assistance Team Fremont Unified School District ix
Findings and Recommendations Background and Context - Transforming Education to Improve Outcomes for Students with Disabilities
Findings and Recommendations
Background and Context - Transforming Education
to Improve Outcomes for Students with Disabilities
Over the past two decades, educational reform movements emphasizing accountability have highlighted
achievement gaps among students based on factors such as race and ethnicity, family income, language
ability, and disability. Although California has made some progress in reducing inequities in educational
outcomes for these student groups, those with disabilities remain among the lowest-performing subgroups.
In 2013, California convened a statewide special education task force dedicated to ending the persistent
poor outcomes for California’s students with disabilities, including eligible infants, toddlers, preschoolers,
and students up to age 22 in kindergarten through grade 12. The task force’s purpose was to study the
complex systems designed to serve the students and provide recommendations to the State Board of
Education, the Commission on Teacher Credentialing, and the California Department of Education (CDE).
The CDE’s project summary for the Statewide Special Education Task Force stated:
California’s current policies, including funding, credentialing, and a range of service deliv-
ery options, tend to ‘bolt on’ special education to general education. While there are cer-
tainly examples throughout the state of well-integrated models of supports, these are the
exceptions rather than the norm. Our prevailing model has made it acceptable, and in some
instances seem desirable, to isolate special education as a unique and separate system that
parallels general education.
The summary further explained that operating special education as a separate program contradicts current
research, which shows:
Inclusive practices, integrated systems, and coherence are essential to provide high-quality,
cost-effective special education programs within (rather than apart from) a well-articulated
system of education.
In March 2015, the Statewide Special Education Task Force published One System: Reforming
Education to Serve All Students, Report of California's Statewide Task Force on Special Education, its
report on the state of special education in California. This report identified seven distinct and intercon-
nected areas of focus to improve outcomes for students with disabilities:
1. Early learning.
2. Evidence-based school and classroom practices.
3. Educator preparation and professional learning.
4. Assessment.
5. Accountability.
6. Family and student engagement.
7. Special education financing.
Among the areas of focus and many recommendations in the 2015 report on one system was the predomi-
nant theme that California’s special education system would improve if one coherent system were designed
Fiscal Crisis and Management Assistance Team Fremont Unified School District 1
Findings and Recommendations Background and Context - Transforming Education to Improve Outcomes for Students with Disabilities
in which general education and special education work together to meet the needs of all students. The
report explained:
In a coherent system of education, all children and students with disabilities are considered
general education students first; and all educators, regardless of which students they are
assigned to serve, have a collective responsibility to see that all children receive the educa-
tion and the supports they need to maximize their development and potential, allowing them
to participate meaningfully in the nation’s economy and democracy.
The CDE’s project summary also identified the need to transform the understanding of special education
from the perception of it as:
A place where students go to receive more or different services, to a viewpoint that includes
special education services as one of many programs of support under the umbrella of general
education.
In 2020, the CDE commissioned WestEd, a nonprofit dedicated to fostering “success for every learner,”
to analyze policy and systemic changes impacting students with disabilities since the 2015 report on
one system. The 2021 WestEd report, California’s Progress Toward Achieving One System: Reforming
Education to Serve All Students, explained that the 2015 report on one system was intended to create
momentum and discourse in California’s efforts to reform special education. To evaluate these efforts,
WestEd reviewed the seven focus areas outlined in the 2015 report on one system and provided addi-
tional recommendations in each area. WestEd concluded that “numerous improvements have been
made to California’s general and special education landscapes.”
Guided by the insights from the 2015 report on one system and the 2021 WestEd report, LEAs should
focus on achieving coherence, fostering inclusive practices, and integrating student support systems.
This approach is essential for building a comprehensive educational system that promotes positive
outcomes for all students. LEAs need to recognize that students receiving special education services
are general education students first and operate with the understanding that special education is one
of the many support programs within general education, not a place where students go to receive
more or different services. These tenets will inform the analysis of the district’s Special Education
Department and its staffing throughout this report.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 2
Identification for Special Education
Before examining the district’s special education staffing, it is critical to consider the population the
program serves: the students receiving special education services. This section provides an over-
view of data and trends related to the district’s special education enrollment.
District Enrollment
From 2019-20 through 2023-24, the district’s census day enrollment for all TK-12 students declined by
2,368 students, as shown in Figure 1 below.
Census Day Enrollment of District Students in Grades TK-12, 2019-20 — 2023-24
36000
35431
35500 35187
35000
34500
33873
34000
33500 33107 33063
33000
32500
32000
31500
2019-20 2020-21 2021-22 2022-23 2023-24
stnedutS
fo
rebmuN
Figure 1. A graph showing an overall decline in district census day enrollment for TK through grade 12 from 35,431 in 2019-20 to 33,063 in
2023-24.
Source: Enrollment for Charter and Non-Charter Schools - Fremont Unified (CDE).
District Special Education Enrollment in Grades TK-12, 2019-20
— 2023-24
Although total district enrollment decreased from 2019-20 through 2023-24, special education en-
rollment in TK-12 increased by five students during that period, as shown in Figure 2 below.
Number of District Students in Grades TK-12 Enrolled in Special Education, 2019-20 — 2023-24
3350 3318 3327 3323
3300
3250
3181
3200 3172
3150
3100
3050
2019-20 2020-21 2021-22 2022-23 2023-24
stnedutS
fo
rebmuN
Findings and Recommendations Identification for Special Education
Figure 2. A graph showing an overall increase in the number of district TK-12 students enrolled in special education, from 3,318 in 2019-20 to
3,323 in 2023-24.
Source: Enrollment for Charter and Non-Charter Schools - Fremont Unified (CDE).
Fiscal Crisis and Management Assistance Team Fremont Unified School District 3
Findings and Recommendations Identification for Special Education
District students who identify as male are much more likely to be identified for special education than those
who identify as female. The former group make up 53% of all students but 68% of students in special edu-
cation, which is only slightly higher than the statewide average of 67% as calculated from DataQuest. The
latter group make up 47% of all students but only 32% of students in special education. The higher repre-
sentation of males in special education is influenced by factors such as referral bias (e.g., boys are more
likely to be referred because of poor grades or behavior support needs) and differences in how teachers
perceive student behavior (e.g., boys often draw more negative attention in school). Consequently, it is
important for LEAs to analyze special education referral rates by gender and provide professional develop-
ment as needed to address any disparities.
District Special Education Enrollment by Disability Category
The Individuals with Disabilities Education Act (IDEA) defines 14 categories of disability under which a stu-
dent may be eligible for special education. In 2024-25, approximately 97% of the district’s students enrolled
in special education qualified under one of the six disability categories shown in Table 1 below.
Table 1: Percentage of District Total Special Education Enrollment by Primary Disability Category,
2019-20 and 2024-25
Specific Speech and
Emotional Intellectual Other Health Learning Language
Autism Disability Disability Impairments Disability Impairment
2019-20 21.10% 1.95% 3.82% 7.00% 42.15% 19.87%
2024-25 26.29% 1.30% 2.74% 12.82% 33.27% 20.51%
Difference 5.19 -0.65 -1.08 5.82 -8.88 0.64
Source: California Longitudinal Pupil Achievement Data System (CALPADS) report 16.1 for 2019-20 and CALPADS report 16.12 for 2024-25.
Notes: Although there are 14 disability categories under which a student with a disability may qualify for special education, this table shows data
only for the six most common in the district.
The main eligibility category of “emotional disability” was previously “emotional disturbance,” which is the term defined in the IDEA and used
throughout the Education Code and the California Code of Regulations. However, Assembly Bill 2173, signed by the governor in July 2024, per-
mits California to use the less offensive term “emotional disability” in state law.
According to the WestEd California Special Education Funding System Study, specific learning disabilities
constitute the vast majority of identified disabilities for students in grades kindergarten through 12, fol-
lowed by speech and language impairments and autism, respectively. In 2024-25, the district reported to
the California Longitudinal Pupil Achievement Data System (CALPADS) that 33.27% of its special education
students were eligible due to a specific learning disability. Autism and then speech and language impair-
ment were the next two most common disability categories in the district, making up 26.29% and 20.51% of
special education enrollment, respectively; this is different from the statewide trends identified by WestEd.
However, the district’s data includes infants and preschool age students, whereas the data in the WestEd
report does not.
Significantly, from 2019-20 through 2024-25, the number of district students who qualify for special educa-
tion under the disability category of autism increased from 745 to 968, which is a 29.93% increase.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 4
Findings and Recommendations Identification for Special Education
Disproportionality in Special Education Identification
The National Association of School Psychologists defines disproportionality as “the extent to which mem-
bership in a given group affects the probability of being placed in a specific disability category.” In simpler
terms, it refers to the disproportionate identification of student groups, such as English learners, males, and
racial or ethnic minorities, for special education.
Racial and Ethnic Balance of Students
For most racial and ethnic groups, their representation as a percentage of total students enrolled in special
education was proportionate to their representation as a percentage of all district students.
However, in 2023-24, 37.50% of the district’s special education students identified as Hispanic or Latino,
compared to 16.10% of the district’s total student population. Conversely, 35.50% of the district’s special
education students identified as Asian, compared to 65.20% of the district’s total student population.
This indicates an overrepresentation of students who are Hispanic or Latino in special education and an
underrepresentation of students who are Asian, as shown in Table 2 below.
Table 2: Percentage of Students in Special Education, by Race and Ethnicity, Compared to Per-
centage of Total Student Population, 2023-24
Two or
African American Hispanic Not Pacific More
American Indian Asian Filipino or Latino Reported Islander Races White
Percentage
of Total 1.80% 0.40% 65.20% 4.20% 16.10% 1.10% 0.50% 3.50% 7.30%
Enrollment
Percentage
of Special
4.60% 0.40% 35.50% 4.50% 37.50% 0.80% 0.60% 3.70% 12.40%
Education
Enrollment
Difference +2.80 0.00 -29.70 +0.30 +21.40 -0.30 +0.10 +0.20 +5.10
Source: Enrollment by Ethnicity for Charter and Non-Charter Schools in 2023-24 - Fremont Unified (CDE).
Overrepresentation of Students who Identify as Hispanic or Latino
The district was recognized by the CDE in its Compliance and Improvement Monitoring (CIM) process as
“significantly disproportionate” because it overidentified students who are Hispanic or Latino for special
education in the disability category of specific learning disability. An LEA identified as significantly dispro-
portionate is required to take action, including reserving 15% of its IDEA funds to develop and implement
a Compliance and Improvement Monitoring for Comprehensive Coordinated Early Intervening Services
Action Plan (CIM for CCEIS Action Plan). The purpose of this plan is to identify and address any factors that
contribute to disproportionality.
It is imperative that the district follow its plan and identify only qualifying students with disabilities. This is nec-
essary for at least two reasons. First, even the most efficient special education programs do not receive enough
funding to support their programs, so it is essential that these finite resources be used for qualifying students
with disabilities. Second, although special education services are vital for students with disabilities, students
identified for special education may experience stigma, reduced expectations, and less access to the general
education curriculum and teachers. These factors can limit their academic achievement and outcomes.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 5
Findings and Recommendations Identification for Special Education
Underrepresentation of Students who Identify as Asian
The district needs to investigate its lower-than-expected identification of Asian students for special edu-
cation. The reason this is occurring is unclear; however, academic literature is informative. A review of 15
academic studies examining the special education identification of Asian students1 found that most studies
reported an underrepresentation of Asian American students in special education because of factors such
as the model minority myth, which stereotypes all Asian Americans as academically successful and hard-
working while ignoring the diversity within this group; cultural differences and parental beliefs about the
stigma of disability labels; and lack of proficiency in Asian languages in school districts.
It is imperative that the district identify all qualifying students with disabilities. Public schools are required
under the IDEA to identify, locate, and evaluate all children who are suspected of having a disability. Failing
to identify a student with a disability for special education can deprive the student of their rights to a free
appropriate public education (FAPE) under the IDEA. This can impede the student’s academic achievement
and outcomes and may obligate the district to pay for compensatory educational services.
English Learners in Special Education
In 2023-24, English learners made up 16.66% of all district TK-12 students but 32.11% of students in special
education.
English learners are commonly overidentified for special education services, and this may be the case in the
district as well. It would benefit the district to review its data annually to monitor for higher-than-expected
identification of English learners in special education and provide professional development as needed.
District Special Education Enrollment Compared to Statewide Enrollment
From 2019-20 through 2023-24, the percentage of district TK-12 students enrolled in special education
increased by 0.69 percentage points from 9.36% to 10.05%.2
FCMAT compared district total and special education TK-12 enrollment to statewide enrollment for 2023-24
(the latest data available). This data is shown in Table 3 below.
Table 3: TK-12 Total and Special Education Enrollment Comparison, 2023-24
2023-24 Fremont Unified Alameda County California
Grades TK-12 Total Enrollment 33,063 211,269 5,837,690
Grades TK-12 Special Education
3,323 26,453 799,980
Enrollment
Percentage 10.05% 12.52% 13.70%
Sources: Enrollment for Charter and Non-Charter Schools - Fremont Unified (CDE), Enrollment for Charter and Non-Charter Schools - Alameda
County (CDE), and Enrollment for Charter and Non-Charter Schools - State (CDE).
The district identified a much lower percentage of TK-12 students as requiring special education than
Alameda County or the state. While the percentage of the district’s TK-12 students enrolled in special
1 Kulkarni, S. S. (2017). Disproportionate representation of Asian students in special education: A systematic review of the literature. Multiple Voices for Ethnically Diverse Exceptional Learners, 17(2), 19-33.
2 Source: Enrollment for Charter and Non-Charter Schools - Fremont Unified (CDE).
Fiscal Crisis and Management Assistance Team Fremont Unified School District 6
Findings and Recommendations Identification for Special Education
education increased by 0.69 percentage points between 2019-20 and 2023-24, it increased by 1.42 per-
centage points in Alameda County and 2.00 percentage points statewide during that same period. The
district needs to monitor this data and ensure it identifies all qualifying students with disabilities for special
education.
Least Restrictive Environment
The IDEA establishes nationwide minimum standards for providing education services to children with
disabilities, as well as related services for eligible infants, toddlers, preschoolers, children, and youth with
disabilities up to the age of 22. It mandates that each state ensure the availability of a FAPE for any child
with a disability who needs special education and related services, regardless of whether they have failed
or been retained in a course or grade, and even if they are advancing from one grade level to another (Title
34, Section 300.101(c) of the Code of Federal Regulations (34 CFR 300.101(c))).
The IDEA also requires that students with disabilities be educated in the least restrictive environment
(LRE). To determine the appropriate setting for an individual student, their IEP team reviews the student’s
strengths and needs and considers the educational benefit of placement in different educational settings.
LRE placement is assessed by the CDE, and the results are published in its local level annual performance
report. These reports, which are required by the IDEA, evaluate districts on 14 indicators for which the
target is deemed to be either met or not met.
Preschool Least Restrictive Environment
In 2022-23, the district met one of the three targets for Indicator 6, which assesses the placement of
preschool students in the LRE, expressed as a percentage of the total number of preschool students who
receive special education services, as shown in Table 4 below.
Table 4: District’s 2022-23 Performance on Indicator 6 — Preschool Students in the LRE
Indicator Indicator Rate Target Target Met?
6a Preschool LRE: Regular Program 4.72% ≥43.00% No
6b Preschool LRE: Separate Class 60.94% <29.00% No
6c Preschool LRE: Home 1.29% <3.50% Yes
Source: Local Level Annual Performance Report 2022-23 (CDE) (most recent report).
The district met just one of the three targets for preschool LRE in 2021-22 and 2022-23, but decreased the
percentage of students receiving services in a separate setting, which it needs to continue.
School-age Least Restrictive Environment
In 2022-23, the district did not meet any of the targets for indicator 5, which assesses the placement
of school-age students in the LRE, expressed as a percentage of the total number of school-age
students who receive special education services, as shown in Table 5 below.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 7
Table 5: District’s 2022-23 Performance on Indicator 5 — School-Age Students in the LRE
Indicator Indicator Rate Target Target Met?
5a LRE Rate: In Regular Class More than 80% 56.50% ≥62.00% No
5b LRE Rate: In Regular Class Less than 40% 23.33% <16.50% No
5c LRE Rate: Separate Schools 3.97% <3.00% No
Source: Local Level Annual Performance Report 2022-23 (CDE) (most recent report).
The district did not meet any of the targets for school-age LRE in 2021-22 or 2022-23, but slightly increased
the percentage of students in regular class more than 80% of the time, which it needs to continue.
Separate Schools
Indicator 5c on the district’s local level annual performance report measures an LRE rate for students
attending a separate school, which is “a school designed specifically for students with disabilities in either a
public or private day school setting. It is designed to provide specialized education for students with unique
needs.” District students attending a separate school attend either a nonpublic school (NPS) or State
Special School.
Nonpublic Schools
In addition to in-district program options, some district students with IEPs attend an out-of-district program
at NPSs. NPSs are privately operated, publicly funded schools that specialize in providing educational ser-
vices for students with exceptional needs that cannot be met in a traditional public school setting.
In 2023-24, the district had 68 students attending an NPS, as shown in Figure 3 below. There was a 24%
increase in the number of district students attending an NPS between 2022-23 and 2023-24.
Number of District Students Attending an NPS, 2021-22 — 2023-24
80 68
58
55
60
40
20
0
2021-22 2022-23 2023-24
stnedutS
fo
rebmuN
Findings and Recommendations Identification for Special Education
Figure 3. A graph showing an overall increase in the number of district students enrolled in special education who attend an NPS, from 58 in
2021-22 to 68 in 2023-24.
Source: District-provided data.
Staff indicated the number of district students attending an NPS is increasing due to a rise in disruptive stu-
dent behavior following the return to school from the COVID-19 pandemic. However, the district projected
a decrease in the number of students attending an NPS from 68 in 2023-24 to 65 in 2024-25. At the time
of FCMAT’s visit, the district had 67 students enrolled in an NPS; four of these were preschool age students
Fiscal Crisis and Management Assistance Team Fremont Unified School District 8
and 63 were in TK through grade 12. Half of the preschool age and 65% of the school-age students attend-
ing an NPS qualify for special education under the disability category of autism, as shown in Table 6 below.
Table 6: District NPS Enrollment by Primary Disability Category, 2024-25
School Emotional Intellectual Multiple Other Health
Level Autism Deaf Disability Disability Disabilities Impairments
Preschool 50.00% 50.00% 0.00% 0.00% 0.00% 0.00%
TK-12 65.10% 1.59% 7.94% 4.76% 3.17% 17.46%
Source: District-reported data.
Notes: The main eligibility category of “emotional disability” was previously “emotional disturbance,” which is the term defined in the IDEA and
used throughout the Education Code and the California Code of Regulations. However, Assembly Bill 2173, signed by the governor in July of
2024, permits California to use the less offensive term “emotional disability” in state law.
District data indicates that its NPS expenditures went up by $3,198,388.24 between 2021-22 and 2023-24,
which is a 58.69% increase as shown in Figure 4 below.
District Nonpublic School Expenditures, 2021-22 — 2023-24
$10,000,000.00
$8,648,123.24
$8,000,000.00
$6,458,261.45
$5,449,735.00
$6,000,000.00
$4,000,000.00
$2,000,000.00
$0.00
2021-22 2022-23 2023-24
loohcS
cilbupnoN
tcirtsiD
serutidnepxE
Findings and Recommendations Identification for Special Education
Figure 4. A graph showing an overall increase in the district’s nonpublic school expenditures, from $5,449,735.00 in 2021-22 to $8,648,123.24 in
2023-24.
Source: District-provided data.
In 2023-24, the district’s average cost for a student to attend an NPS was $127,178, but it reduced its pro-
jected per student cost in 2024-25 to $125,724. The district projected a decrease in the number of students
attending an NPS and in NPS expenditures in its 2024-25 revised budget from $8,648,123.24 in 2023-24 to
$8,172,068.91 in 2024-25. However, in 2024-25, the district’s payments for NPS services through October
31, 2024 were 38% higher than the same period in the prior year, and FCMAT projects the district has
underbudgeted for the cost of all special education services (NPS/NPA) by approximately $9.3 million.
It would benefit the district to continue to annually file for the Special Education Extraordinary Cost Pool
(ECP) for Nonpublic School/Licensed Children's Institutions (NPS/LCI) under EC 56836.21. The Special
Education Extraordinary Cost Pool for NPS/LCI is ongoing state funding that was increased by almost
700% in 2022-23. The threshold amount for 2023-24 was $97,944.15 for a single placement and services.
According to its SELPA funding exhibits, the district has filed claims. However, if the district’s self-reported
average cost per NPS student in 2023-24 was $127,178 for services plus other expenses and transportation,
the reimbursement requests submitted for that year seem quite low.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 9
Findings and Recommendations Identification for Special Education
State Special Schools
The CDE provides administrative oversight and support to three State Special Schools for students: one
California School for the Blind for students with the low prevalence disabilities of visual impairment and
deafblindness, and two California Schools for the Deaf for students who are deaf and hard of hearing. The
California Schools for the Deaf were established regionally in Riverside and Fremont and the California
School for the Blind is in Fremont.
According to most recent data available in DataQuest, in 2023-24 300 TK-12 students were enrolled at the
California School for the Deaf in Fremont, and 324 TK-12 students were enrolled at the California School for
the Deaf in Riverside. In 2023-24, the district reported it had 49 students enrolled at the California School
of the Deaf in Fremont, of which 40 were in kindergarten through grade 12. Therefore, Fremont Unified stu-
dents make up 6.41% of the California Schools for the Deaf’s total TK-12 enrollment (including the Riverside
and Fremont campuses). In contrast, Fremont Unified comprises 0.57% of the state’s TK-12 enrollment so
district students are overrepresented at the California Schools for the Deaf. Staff reported certain families
move to Fremont because they want to live in proximity to one of the California Schools for the Deaf. In
addition, staff explained that some families mistakenly believe that those who live in Fremont are automat-
ically eligible to attend the California School for the Deaf. Instead, a student must be referred by their local
school district and then go through a four-part admission process to determine whether the student meets
the California School for the Deaf’s enrollment criteria.
According to DataQuest, in 2023-24 49 students in TK through grade 12 were enrolled at the California
School for the Blind. In 2023-24, the district reported it had five TK-12 students enrolled at the California
School for the Blind, which is 10.20% of the school’s total enrollment. In contrast, Fremont Unified com-
prises 0.57% of the state’s TK-12 enrollment so the Fremont Unified students are also overrepresented at
the California School for the Blind. This is likely for the same reasons Fremont Unified students are overrep-
resented at the California School for the Deaf.
Recommendations
The district should:
1. Annually monitor the percentage of students who qualify for special education and assess
the proportionality of students in the special education group compared to the overall
student population at least by gender, race, ethnicity, and English learner status. Provide
training as needed in how to properly identify students for special education.
2. Continue to implement its CIM for CCEIS Action Plan to reduce its overrepresentation of
Hispanic and Latino students in special education.
3. Monitor what percentage of the school day students with IEPs spend in general education
settings, with a focus on meeting or exceeding LRE targets in its Local Level Annual
Performance Report.
4. Develop a better system to track the costs for each individual student attending an
NPS for use in determining whether those expenses may qualify for extraordinary cost
reimbursement.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 10
Findings and Recommendations District Organization and Central Office Special Education Staffing
District Organization and Central Office Special
Education Staffing
District Organization
The organizational structure of a school district is crucial to the effectiveness of its special education pro-
gram. An optimal structure fosters effective communication and collaboration across departments within
the district’s central office and schools. This collaboration is essential to meet the unique needs of students
with disabilities and implement evidence-based practices that support inclusive education.
Interim Executive Director in the Special Education Department
In 2024-25, the district added a 0.70 FTE interim executive director in the Special Education Department.
Staff explained that this position was added to create a direct line of communication between the admin-
istrative cabinet and the Special Education Department. As reported in the “Special Education Staffing
Comparison” section of this report, the district has fewer administrative/leadership positions in its Special
Education Department than similar districts, so it is recommended to retain this position since it facilitates
communication and supports coherence.
Recruitment and Hiring of Special Education Staff
A district may use a centralized, decentralized or hybrid model to recruit and hire special education staff.
In a centralized model, the central office facilitates recruitment and hiring of all special education staff. In
a decentralized model, school site leaders facilitate the recruitment and hiring of special education staff.
Many districts use a hybrid approach in which certain special education positions are recruited for and
hired by the central office and others by school principals.
Fremont Unified uses a hybrid model to recruit and hire special education staff. Although school princi-
pals used to hire special education teachers, the assistant director in the Special Education Department
now manages this process, usually including the principal from the school in interviews. Classified special
education personnel are hired centrally by the Special Education Department for itinerant staff such as
occupational therapists, and paraeducators are hired by school principals. However, the Special Education
Department works with nonpublic agencies to fill open paraeducator positions with contracted staff. The
Special Education Department completes the hiring paperwork for all special-education-related positions.
Despite the regular collaboration reported between staff in the Special Education and Human Resources
departments and school sites, staff reported that the hiring process for special education staff is disjointed
and excessively long. Staff believe the district loses viable candidates for special education positions
because the time spent waiting to be interviewed or between being interviewed and being offered a
position is excessive. Many staff suggested that if school principals were again made responsible for hiring
special education teachers, the process could be quicker, more efficient, and the local needs of individual
schools could be better prioritized.
FCMAT typically finds that districts the size of Fremont Unified have the Special Education Department
manage recruitment and hiring of itinerant special education staff, related service providers, and con-
tracted staff, and designate school principals to hire special education teachers and paraeducators for their
schools. If the district were to make this change, it would need to consider how to coordinate its special
education teacher recruitment efforts so that school principals are not all vying for the same candidates
Fiscal Crisis and Management Assistance Team Fremont Unified School District 11
Findings and Recommendations District Organization and Central Office Special Education Staffing
separately. One way to address this could be to have the Human Resources Department support and coor-
dinate special education teacher and/or paraeducator interviews so that a group of school principals con-
duct interviews together on the same day with a set of candidates. If the district were to do this, it would
need to determine how to complete hiring paperwork and reference checks, and whether the Human
Resources Department would need additional staff to support this work.
Position Control
Position control is a system of tracking information based on positions rather than employees. It is a frame-
work of positions for all jobs in the organization regardless of whether there is an incumbent in a specific
job or not. Position control includes the creation, maintenance, and monitoring of positions and the bud-
gets for them. In school districts, position control is usually managed collaboratively between the Human
Resources and Business Services departments. Position control should begin with staffing ratios based on
site and department needs and consider any contract requirements.
District staff reported that the district uses a position control system, that it uses ratios to determine staffing
for many special education positions, and that special education staffing projections for the coming school
year are developed with input from the Special Education Department. However, staff indicated that the
special education hiring process happens separately from position control. In addition, staff explained there
is a lack of communication and a poor sense organizationwide of which special education staff work at
which school site and for how long. For example, school principals expressed frustration about being asked
to sign timecards for certain special education staff when they did not even know that person had been
assigned to their school or what hours the person was supposed to work. Furthermore, school principals
identified instances where they reported to the central office that a paraeducator was no longer needed at
their school, and it took many months and reminders, or in rare cases up to a year, for the paraeducators
to be moved to a different school site with an open position. This did not occur because of a lack of open
paraeducator positions.
While examining the district’s position control system is beyond the scope of work for this FCMAT study,
the district needs to use its position control system when evaluating and filling all special education posi-
tions to help prevent over- or underbudgeting of staff by including all district-approved positions.
Special Education Program Support Staffing
Administrator/Leadership Positions
The Special Education Department has 13.70 full-time equivalent (FTE) administrator/leadership positions,
as shown in Table 7 below.
Table 7. Administrator/Leadership Positions Supporting Special Education in 2024-25
Number of
Position Title Positions Total FTE
Executive Director (Interim 2024-
1 0.70
25)
Director 1 1.00
Assistant Director 1 1.00
Program Manager 1 1.00
Fiscal Crisis and Management Assistance Team Fremont Unified School District 12
Findings and Recommendations District Organization and Central Office Special Education Staffing
Number of
Position Title Positions Total FTE
Program Specialist 8 8.00
Preschool Program Principal 1 1.00
Preschool Program Assistant
1 1.00
Principal
Total 14 13.70
Source: District-provided data.
The district also has a 0.6 FTE program specialist position supporting its infant program, which was not
included in the forthcoming staffing comparison with similar districts since most do not operate infant
programs.
Central Office Administrative Support Positions
The Special Education Department has 8.00 FTE administrative support staff, as shown in Table 8 below.
Table 8. Administrative Support Staff Positions Supporting Special Education in 2024-25
Number of
Position Title Positions Total FTE
Staff Secretary II 1 1.00
Staff Secretary III 1 1.00
Data Services Technician 1 1.00
Office Assistant III 1 1.00
Account Technician II 1 1.00
School Secretary – Glankler 1 1.00
School Secretary – Rix 1 1.00
Office Assistant I – Glankler 1 0.50
Office Assistant I – Rix 1 0.50
Total 9 8.00
Source: District-provided data.
Special Education Staffing Comparison
FCMAT conducted an informal survey of unified school districts in California with student enrollment
and unduplicated pupil percentages (UPP) similar to those of the Fremont Unified School District.3 The
survey aimed to collect information on central office staffing within the school districts’ special education
departments:
3 The term UPP refers to the percentage of students who are English learners, foster youth, or eligible for free or reduced-price meals. Each student is counted only once, regardless of how many categories they qualify for.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 13
Findings and Recommendations District Organization and Central Office Special Education Staffing
• Central Office Administrator/Leadership Positions – Roles such as directors, assistant
directors, coordinators, program specialists, and teachers on special assignment (TOSAs).
These comparison positions do not need to require an administrative credential.
• Central Office Administrative Support Positions – Roles such as secretaries, administra-
tive assistants, filing clerks, and data technicians.
Table 9 on the following page compares Fremont Unified’s Special Education Department central office
staffing with data from the three school districts that participated in FCMAT’s survey. On average, these
school districts have 17.27 FTE administrator/leadership positions supporting special education in the cen-
tral office, while Fremont Unified reports a lower level of staffing at 13.70 FTE. For special education admin-
istrative support positions in the central office, the comparison school districts average 9.17 FTE, whereas
Fremont Unified reports a lower level of staffing at 8.00 FTE.
Table 9. Administrator and Administrative Support Position Staffing Comparison
2023-24 2023-24 2024-25 2024-25
Census Day Census Day Administrator/ Administrative
District County Enrollment UPP% Leadership Position FTE Support Position FTE
Mt. Diablo Unified Contra Costa 30,010 47.62% 21.00 8.00
Placentia-Yorba Linda
Unified Orange 22,705 47.97% 17.80 6.50
Torrance Unified Los Angeles 22,109 38.85% 13.00 13.00
Average FTE 17.27 9.17
Fremont Unified Alameda 33,063 33.25% 13.70 8.00
Sources: Comparisons (Ed-Data) and FCMAT survey results.
Notes: Fremont Unified was excluded from the average FTE calculations.
Teachers on special assignments were included in administrator/leadership FTE if they are ongoing positions and perform special education
program support functions in the central office.
Any variances in a school district’s actual FTE are due to FCMAT’s interpretation of the survey data.
Fremont Unified has 3.57 FTE fewer administrator/leadership positions and 1.17 FTE fewer administrative
support positions supporting special education compared to the surveyed school districts. Ideally a higher
number of districts would have responded to FCMAT’s survey. However, the district most similar in size to
Fremont Unified had 7.30 FTE more administrator/leadership positions.
Special Education Department Administrator/Leadership
Positions
In addition to having fewer administrator/leadership positions than the similar districts who responded
to FCMAT’s survey, Fremont Unified only has 3.7 FTE positions in its central office supporting the special
education program that require an administrative services credential. This is unusual in a district this size
compared to what is observed across the state and may be one cause of the inadequate support from the
Special Education Department’s leadership team identified by some staff during interviews.
The Special Education Department’s eight program specialist positions do not require an administrative
services credential and are similar to a teacher on special assignment (TOSA) position in that the staff work
a 7.5-hour day and 192 days per year. This is far less than a typical program manager’s schedule, and these
Fiscal Crisis and Management Assistance Team Fremont Unified School District 14
Findings and Recommendations District Organization and Central Office Special Education Staffing
staff cannot commit district funds and evaluate specialized itinerant and related service provider staff,
which were needs identified by staff during interviews.
The Special Education Department’s program specialists are viewed positively by all staff interviewed.
Many staff indicated program specialists are more approachable than other central office or site leaders
because they are not administrators. Staff explained that in this district, an administrator must follow steps
to provide feedback to a teacher. The program specialists do not need to follow these steps, which is
viewed as helpful by teachers who need support or timely feedback. Staff interviewed universally indicated
the feedback and support from program specialists is helpful and that they are knowledgeable.
A drawback of the program specialist position identified during interviews is that program specialists do
not serve as the administrator/administrator designee at IEP meetings. Accordingly, if a program specialist
attends an IEP meeting, the school’s administrator must also attend. While having both a school administra-
tor and a program specialist attending an IEP may be optimal in certain cases, having this as the norm is not
the best use of a district’s finite resources.
The district assigns a special education program specialist to each of its five attendance areas, and the
other three program specialists support the following: educationally related mental health services, ser-
vices for infants and preschool age students, and programs for students with autism. Article 36.9.1.5 of the
district’s contract with Fremont Unified District Teachers Association states, “The District will maintain no
fewer than three (3) positions budgeted for special education services. This number is exclusive of program
specialists who work with special categories of students, including the infant program, pre-school program,
or any program for which the District receives reimbursement from special funds, outside of the Special
Education or General Fund.”
The support provided by the Special Education Department’s program specialists is valued by staff and
is useful to the special education program. However, the district needs to assess the cost and benefit of
converting some of the program specialist positions into program manager positions, requiring an admin-
istrative services credential, to help meet the Special Education Department leadership needs identified in
interviews. For example, the district could consider converting five of the program specialist positions into
program manager positions, who follow a manager’s daily schedule and work year. A program manager
could be assigned to each of the five district attendance areas, and these staff could support as administra-
tive designee at high profile IEP meetings.
Recommendations
The district should:
1. Continue its executive director position in the Special Education Department to provide
additional support for the special education program and a direct line of communication
between the administrative cabinet and the Special Education Department.
2. Conduct regular joint meetings of the Business Services, Human Resources and Special
Education departments on staffing, position control, and budget.
3. Use its position control system when evaluating and filling all special education positions to
help prevent over- or underbudgeting of staff by including all district-approved positions.
4. Consider whether having school principals responsible for hiring special education
teachers would make the process more efficient. Determine how the Human Resources
Department would need to support the hiring process and whether it could do so with its
current staffing if this change were made.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 15
Findings and Recommendations District Organization and Central Office Special Education Staffing
5. Perform a cost and benefit analysis to determine whether converting some of the Special
Education Department’s program specialist positions into program manager positions,
requiring an administrative services credential, would better meet special education
program needs.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 16
Findings and Recommendations Special Education Teacher Staffing
Special Education Teacher Staffing
FCMAT compared the district’s special education teacher staffing to statewide guidelines and/or industry
standards.
Resource Specialist Program Teachers
The Resource Specialist Program (RSP) provides targeted instructional support and services to students
with special education needs. RSP teachers play a critical role in managing caseloads, developing IEPs, and
collaborating with general education teachers to support student success.
Education Code 56362(c) states:
Caseloads for resource specialists shall be stated in the local policies developed pursuant to
Section 56195.8 and in accordance with regulations established by the board. No resource
specialist shall have a caseload which exceeds 28 pupils.
The contract between the district and the teachers’ association specifies a maximum caseload of 28 stu-
dents for RSP teachers.
In 2024-25, the district has 62.4 FTE RSP teachers. Based on caseload estimates provided by the district,
these teachers manage the cases of 1,592 students, averaging 25.51 students per teacher, as shown in
Table 10 below.
Table 10: Resource Specialist Teacher Staffing, 2024-25
Staffing Staffing
Total Total Average Needed to Meet Above (+) or Below (-)
Teacher Student Teacher Education Education Code
School Level FTE Caseload Caseload Code Standard Standard
Elementary School 23.8 622 26.13 22.21 +1.59
Middle School 16.0 399 24.94 14.25 +1.75
High School 19.6 470 23.98 16.79 +2.81
COIL Charter School 3.0 101 33.67 3.61 -0.61
Total 62.4 1,592 25.51 56.86 +5.54
Sources: District-provided data and EC 56362(c).
COIL Charter School is staffed 0.61 FTE RSP teacher below what is needed to meet the EC 56362(c) case-
load standard. Staff reported a 1.0 FTE RSP teacher was moved from COIL Charter School earlier this year
because the caseload size did not warrant that teacher. However, the RSP caseload at COIL Charter School
has since grown and additional RSP teacher support is now needed to meet the EC 56362(c) caseload stan-
dard and student needs. Staff are evaluating how to increase RSP teacher support at COIL Charter School.
Districtwide resource specialist staffing is 5.54 FTE more than what is required to meet the EC 56362(c)
caseload standard. However, the students who receive support from a resource specialist are not neatly
distributed into groups of 28 across district schools. Thus, having more staffing than is required to meet
the EC 56362(c) standard may be necessary. In addition, the standard outlined in EC 56362(c) is based on
a maximum caseload, which is higher than the statewide caseload average observed in LEAs that serve
students using an inclusive model.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 17
Findings and Recommendations Special Education Teacher Staffing
Although the definition of an inclusive model varies across California’s school districts, the intent of such a
model is to enable students to attend their neighborhood schools, progress through the grade levels that
match their chronological ages, and access general education classes and curricula to the greatest extent
possible. As described in the section of this report that discusses placement in the least restrictive environ-
ment, the district did not meet any of the three indicators that measure school age LRE on its annual per-
formance report. However, the district is attempting to operate an inclusive program. Accordingly, resource
specialist staffing that exceeds the 1-to-28 teacher-to-student ratio may be needed to provide sufficient
services to meet students’ needs; these services are based on factors such as the number of specialized
academic instruction (SAI) minutes in a student’s IEP and the percentage of time a student is in general
education.
As the district makes progress toward meeting the LRE targets and increases the percentage of time
students receive support in general education, it will need to consider the RSP support necessary to meet
student needs. The industry standard for SAI-based programs supporting students in their LRE is 20-24
students per special education teacher.
Special Day Class Staffing
The Education Code does not define caseload maximums for SDC programs. Article 12.4.2 of the district’s
contract with the teachers’ association states the district will make reasonable effort not to exceed the
special education class maximum size goals for its SDC programs, which are shown alongside industry
standards in Table 11 below.
Table 11: District Class Maximum Size Goal and Industry Standards for Special Day Class Programs
Type of Program District Class Maximum Size Goal Industry-Standard Caseload Range
Preschool through Grade 3 – Preschool -
10 students per 1 teacher 14 students per 1 teacher
Mild/Moderate Support Needs Special Day Class
– Cross-Categorical
Grades 4-12 – Transitional Kindergarten through Grade 12 –
12 students per 1 teacher 12-15 students per 1 teacher
Preschool – Preschool -
8 students per 1 teacher 10 students per 1 teacher
Extensive Support Needs Special Day Class – Kindergarten through Grade 3 –
Cross-Categorical 6-10 students per 1 teacher
Transitional Kindergarten through Grade 12 –
10-12 students per 1 teacher
Grades 4-12 –
6-12 students per 1 teacher
Preschool –
9 students per 1 teacher
Extensive Support Needs Special Day Class – No Class Size Goal in Collective
Autism Focus Bargaining Agreement
Transitional Kindergarten through Grade 12 –
8-10 students per 1 teacher
Special Day Class – Mental Health and No Class Size Goal in Collective
8-10 students per 1 teacher
Behavioral Support Needs Bargaining Agreement
Sources: District collective bargaining agreement and industry standards.
Most of the district’s special education class size goals are aligned with the industry standards, except for
its SDCs for students in preschool and in kindergarten through grade three, which have a lower class size
goal than the industry standards. The district needs to evaluate whether aligning its SDC caseload guide-
Fiscal Crisis and Management Assistance Team Fremont Unified School District 18
Findings and Recommendations Special Education Teacher Staffing
lines for these programs with industry standards would allow it to reduce costs while continuing to meet
students’ needs.
Mild-to-Moderate Special Day Class Programs
In 2024-25, the district has 51.0 FTE SDC teachers of classes for students with mild-to-moderate support
needs. Based on caseload estimates provided by the district, these teachers manage the cases of 563 stu-
dents, averaging 11.04 students per teacher, as shown in Table 12 below.
Table 12: Mild-to-Moderate Special Day Class Program Teacher Staffing, 2024-25
Industry-
Total Total Teacher Standard Staffing FTE Staffing FTE
School Teacher Student Caseload Caseload Needed to Meet Industry Above (+) or Below (-) Industry
Level FTE Caseload Average Range Standard Standard
14 students +3.07 FTE (above 14 students per
Preschool 5.00 27 5.40 1.93 FTE
per teacher teacher)
13.67 FTE needed
to meet 12 students per +2.33 FTE (above 12 students per
12-15
Elementary teacher teacher)
16.00 164 10.25 students per
School 10.93 FTE needed +5.07 FTE (above 15 students per
teacher
to meet 15 students per teacher)
teacher
12-15
Middle Within Industry-Standard
11.00 148 13.45 students per Within Industry-Standard Range
School Range
teacher
12-15
Within Industry-Standard
High School 19.00 224 11.79 students per Within Industry-Standard Range
Range
teacher
Total 51.00 563 11.04 N/A N/A N/A
Sources: District-provided data and industry standards.
The districtwide mild-to-moderate SDC teacher caseload average is below the industry-standard range
for preschool and elementary school classes. As a result, the district is staffed with 3.07 FTE more
mild-to-moderate SDC preschool teachers and 2.33-5.07 FTE (depending on the industry-standard range
of 12-15 students per teacher) more mild-to-moderate SDC elementary school teachers than what it would
need to meet industry standards.
The district is staffed above the industry-standard range for mild-to-moderate preschool and elementary
SDCs because it determines its staffing using class size goals that are lower than the industry standards.
In addition, the district’s current preschool numbers are lower than they will be at the end of the school
year because preschool numbers grow as students turn 3 years old and become eligible for the program.
District preschool numbers may also be trending lower overall with the phase in of the TK program. Staff
reported that most students move from preschool to TK when they turn 4. Accordingly, the district needs to
evaluate start and end-of-year preschool program numbers to see what trends it can identify and determine
whether the current number of mild-to-moderate SDC preschool teachers are needed.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 19
Findings and Recommendations Special Education Teacher Staffing
Counseling Enriched Special Day Class Program
In 2024-25, the district has 9.00 FTE SDC teachers of classes for students with social-emotional and behav-
ioral support needs. Based on caseload estimates provided by the district, these teachers manage the
cases of 85 students, averaging 9.44 students per teacher, as shown in Table 13 below.
Table 13: Counseling Enriched Special Day Class Program Teacher Staffing, 2024-25
Average Industry-
Total Total Caseload Standard Staffing FTE Staffing FTE
Teacher Student Per Caseload Needed to Meet Above (+) or Below (-)
Program FTE Caseload Teacher Range Industry Standard Industry Standard
10.63 FTE (8 students per
Counseling
8 -10 students per teacher)
Enriched 9.00 85 9.44 Within Industry-Standard Range
teacher 8.50 FTE (10 students per
SDC
teacher)
Sources: District-provided data and industry standards.
The districtwide counseling enriched SDC teacher caseload average is within the industry-standard range
of 8-10 students per teacher.
Moderate Support Needs Special Day Class Program
In 2024-25, the district has 39.00 FTE SDC teachers of classes for students with moderate support needs.
Based on caseload estimates provided by the district, these teachers manage the cases of 392 students,
averaging 10.05 students per teacher, as shown in Table 14 below.
Table 14: Moderate Support Needs Special Day Class Program Teacher Staffing, 2024-25
Total Total Student Average Caseload
School Level Teacher FTE Caseload Per Teacher Industry-Standard Caseload Range
Preschool 6.00 39 6.50 No Industry Standard Available
Elementary School 19.00 201 10.58 No Industry Standard Available
Middle School 6.00 67 11.17 No Industry Standard Available
High School 5.00 57 11.40 No Industry Standard Available
Young Adult Program 3.00 28 9.33 No Industry Standard Available
Total 39.00 392 10.05 No Industry Standard Available
Sources: District-provided data.
No industry standard is available to compare with the district’s moderate support needs SDC teacher
staffing. However, like the district’s mild-to-moderate SDC program, the caseload average for the preschool
program is much lower than other school levels.
Extensive Support Needs Special Day Class Program
In 2024-25, the district has 28.00 FTE SDC teachers for students with extensive support needs. Based on
caseload estimates provided by the district, these teachers manage the cases of 254 students, averaging
9.07 students per teacher, as shown in Table 15 below.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 20
Findings and Recommendations Special Education Teacher Staffing
Table 15: Extensive Support Needs Special Day Class Program Teacher Staffing, 2024-25
Staffing FTE
Staffing FTE Above (+)
Total Total Average Needed to or Below
School Teacher Student Caseload Industry-Standard Caseload Meet Industry (-) Industry
Level FTE Caseload Per Teacher Range Standard Standard
3.67 FTE (9 +2.33 FTE (9
9 students per teacher – autism students per students per
focus teacher) teacher)
Preschool 6.00 33 5.50
10 students per teacher – cross- 3.30 FTE (10 +2.70 FTE (10
categorical students per students per
teacher) teacher)
8-10 students per teacher – autism
Elementary focus
11.00 124 11.27 Within Industry-Standard Range
School 10-12 students per teacher –
cross-categorical
8-10 students per teacher – autism
focus
Middle School 3.00 26 8.67 Within Industry-Standard Range
10-12 students per teacher –
cross-categorical
8-10 students per teacher – autism
focus
K-8 1.00 11 11.00 Within Industry-Standard Range
10-12 students per teacher –
cross-categorical
8-10 students per teacher – autism
focus
High School 4.00 30 7.50 Within Industry-Standard Range
10-12 students per teacher –
cross-categorical
Young Adult 10-12 students per teacher –
3.00 30 10.00 Within Industry-Standard Range
Program cross-categorical
8-10 students per teacher –
autism focus
Total 28.00 254 9.07 Within Industry-Standard Range
10-12 students per teacher –
cross-categorical
Sources: District-provided data and industry standards.
The districtwide extensive support needs SDC teacher caseload average is within the industry-standard
range for all school levels except for preschool, which is staffed above the industry-standard range. As a
result, the district is staffed with 2.33-2.70 FTE (depending on the industry-standard range of nine or 10
students per teacher) more SDC preschool teachers for students with extensive support needs than what it
would need to meet industry standards.
The district is staffed above the industry-standard range for extensive support needs preschool SDCs
because it determines its staffing using class size goals that are lower than the industry standards. In addi-
tion, as previously mentioned, the district’s current preschool numbers are lower than they will be at the
end of the school year because preschool numbers grow as students turn 3 years old and become eligible
for the program. District preschool numbers may also be trending lower overall with the phase in of the
TK program. Staff reported that most students move from preschool to TK when they turn 4. Accordingly,
the district needs to evaluate start and end-of-year preschool program numbers to see what trends it can
identify and determine whether the current number of extensive support needs SDC preschool teachers
are needed.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 21
Findings and Recommendations Special Education Teacher Staffing
Recommendations
The district should:
1. Determine how it can increase RSP teacher staffing at COIL Charter School to ensure it
meets the EC 56362(c) caseload standard and student needs.
2. Continue to monitor RSP teacher staffing and caseloads to ensure they are adequate to
meet the EC 56362(c) caseload standard and student needs.
3. Evaluate whether aligning its class size goals for its SDC preschool programs and SDCs
for students in kindergarten through grade three with industry standards would allow it
to reduce the number of teachers needed for these programs while continuing to meet
students’ needs.
4. Evaluate its start and end-of-year preschool program numbers for the past three years and
compare them to this school year’s numbers to identify trends and determine whether the
current number of mild-to-moderate and extensive support needs SDC preschool teachers
are needed.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 22
Findings and Recommendations Special Education Paraeducator Staffing
Special Education Paraeducator Staffing
Special education paraeducators, also known as special education aides or instructional assistants, are
trained professionals who work with students, typically under the direction of a classroom teacher. LEAs
often employ special education paraeducators under different titles with distinct job descriptions to per-
form functions such as specialized academic instruction, specialized medical support, behavioral support,
and 1-to-1 student support or intensive individual service (IIS).
Industry-Standard Paraeducator Staffing Ratios
The industry-standard base staffing for SDCs is to assign one paraeducator for every teacher of students with
mild-to-moderate and extensive support needs. For SDCs serving students with autism, the standard is two
special education paraeducators for every teacher. In addition, the industry standard for staffing in excess of
the SDC base staffing level is determined by an adult-to-student ratio, as shown in Table 16 below.
Table 16: Industry-Standard Paraeducator Staffing and Adult-to-Student Ratios
SDC Support Industry-Standard Adult-to-Student
Level SDC Focus Special Education Paraeducator Staffing Ratio
Mild-to-Moderate Noncategorical One to two six-hour special education paraeducators for a class size of 12-15 1-to-7
Extensive Noncategorical One to two six-hour special education paraeducators for a class size of 10-12 1-to-5
All Autism Two to four six-hour special education paraeducators for a class size of 8-10 1-to-3
Source: Industry standards.
Note: Industry-standard staffing for special education paraeducators is determined by class size to meet an adult-to-student ratio, which includes
the classroom teacher and special education paraeducator(s).
The district has established the following paraeducator staffing guidelines:
• Each RSP teacher is assigned one paraeducator.
• An SDC for students with mild-to-moderate support needs is assigned one to three
paraeducators.
• An SDC for students with extensive support needs is assigned three to four paraeducators.
Establishing paraeducator staffing guidelines for SDC programs is a good practice, and the guidelines the
district reported using are reasonable. However, because the district does not use an adult-to-student
staffing ratio to determine paraeducator staffing, it may be over- or understaffed. Assigning more paraed-
ucator support than necessary is costly and may limit students’ opportunities to gain independence; how-
ever, not assigning enough paraeducators to an SDC can mean that students lack appropriate support and
supervision. Therefore, the district would benefit from adding an adult-to-student ratio to its paraeducator
staffing guidelines for SDCs. When using such a ratio to determine staffing, the best practice is to include
the teacher and classroom paraeducators in the adult portion of the ratio, and to remove any students who
have a 1-to-1 paraeducator and their assigned 1-to-1 paraeducator from the ratio.
1-to-1 Student Support
There is no established industry standard for special education paraeducators providing 1-to-1 paraeduca-
tor support. Many LEAs throughout the state have taken steps to remove the designation of 1-to-1 support
because it unintentionally reinforces the concept of one adult assigned to one student. Industry practice
Fiscal Crisis and Management Assistance Team Fremont Unified School District 23
Findings and Recommendations Special Education Paraeducator Staffing
commonly refers to both the assessment process and the special education paraeducator role as spe-
cial circumstance instructional assistance (SCIA). Accordingly, when a student requires SCIA, the district
endeavors to meet student needs by assigning extra paraeducator classroom assistance instead of 1-to-1
paraeducator support.
The district uses a SCIA assessment process to determine whether a student requires 1-to-1 paraeducator
support. This process clarifies decision-making procedures and recognizes that 1-to-1 paraeducator support
is a significant program decision that should be based on a thorough, data-driven evaluation that includes
considering all less-restrictive alternatives. The district’s SCIA assessment aligns with industry standards
because it focuses on personal independence, promotes individual decision-making, works to maximize
existing supports, and is based on data-driven assessment.
After a school team goes through the SCIA assessment process, the district has an SCIA panel that reviews
each SCIA assessment prior to assigning a 1-to-1 paraeducator. Staff reported the SCIA panel causes
the SCIA assessment process to be unnecessarily long and stated there is a backlog of completed SCIA
assessments waiting for SCIA panel review. Many staff indicated they do not understand the reason for the
SCIA panel. The district needs to determine the amount of time completed SCIA assessments wait for SCIA
panel review and evaluate its SCIA process to decide whether revisions are necessary.
In 2024-25, the district has 197.62 FTE one-to-one paraeducators assigned to provide 1-to-1 paraeducator
support and 5.38 FTE paraeducators who provide 1-to-1 and classroom paraeducator support. Although
there is no industry standard for comparison, this is high for a district of this size compared to what is
observed across the state.
Causes and Consequences of High 1-to-1 Paraeducator Staffing
Staff explained that the number of 1-to-1 paraeducators has grown because student support needs
increased following the COVID-19 pandemic and because teacher turnover results in inexperienced teach-
ers who need additional help in certain SDCs.
As previously mentioned, assigning more paraeducator support than necessary is costly. In addition,
although a parent/guardian or staff member’s request for a student to have a 1-to-1 paraeducator may
be well meaning, according to the University of Colorado at Denver’s Paraprofessional Resources and
Research Center, it can negatively affect the student’s education in the following ways:
• The paraeducator may become the student’s primary service provider, and the teacher’s
involvement and interactions with the student may be limited. The University of Colorado
at Denver’s Paraprofessional Resources and Research Center cautions, “This practice is
further exacerbated when paraeducators are not qualified and or trained. It is not in the
best interest of the students with most complex needs to be taught by the least qualified
staff member.”
• The paraeducator’s constant presence may cause the student to become overly dependent
on that adult to do things they could otherwise do independently.
• The paraeducator may create social barriers between the student they are supporting and
the student’s peers.
Best Practices in 1-to-1 Paraeducator Assignment
In addition to using an assessment to determine whether a student requires a 1-to-1 paraeducator, LEAs
should also identify when during the school day a student requires a 1-to-1 paraeducator and assign this
Fiscal Crisis and Management Assistance Team Fremont Unified School District 24
Findings and Recommendations Special Education Paraeducator Staffing
only for those times. The “School Day Analysis” page of the district’s SCIA assessment is designed to be
used to determine which parts of the school day a student requires support (e.g., for mathematics or during
recess). This is an alternative to assigning a student a 1-to-1 paraeducator for the entire school day, which
is only necessary for some students. Staff reported the “School Day Analysis” page is used to determine
whether a 1-to-1 paraeducator can be shared by more than one student at a school.
Part of the SCIA assessment process focuses on planning for a student’s transition to independence and
developing annual IEP goals to support this. Staff reported that they do not consistently write goals for
independence or plans to reduce a student’s reliance on 1-to-1 special education paraeducator support
when it is added to a student’s IEP. Doing so would be a good practice because it focuses IEP services on
addressing deficit areas to strengthen skills, allows the student’s IEP team to monitor annual progress, and
helps them determine whether adjustments to the level of service are needed. It would also help the IEP
team move away from the concept of assigning one adult to one student, which would enable the district
to assign one special education paraeducator to more than one student when appropriate. Staff identified
resistance from parents as the main barrier to reducing or removing 1-to-1 student support, regardless of
whether this support is necessary or beneficial to the student.
Nonpublic Agency Paraeducator Staffing
The CDE defines a nonpublic, nonsectarian agency (NPA) as “a private, nonsectarian establishment or
individual that provides related services necessary for a pupil with exceptional needs to benefit education-
ally from the pupils’ individualized education program (IEP).” Due to statewide shortages, districts com-
monly contract with NPAs for certain types of special education staff such as related service providers and
paraeducators.
The Human Resources Department indicated it does not track contracts initiated by the Special Education
Department with NPAs for special education staff. However, staff identified an inconsistency between the
number of special education paraeducator position vacancies and the number of paraeducators for which
the Special Education Department contracts with an NPA. Staff estimated the district contracts for 100 spe-
cial education paraeducators but only has approximately 25 paraeducator vacancies.
Staff explained that the Special Education Department must request board approval of new paraeducator
positions. However, when requests were denied prior to the COVID-19 pandemic, the Special Education
Department began placing paraeducators, including ones contracted through an NPA, in limited-term assign-
ments instead of board-approved positions. Thus, the Special Education Department can contract for as many
paraeducators deemed necessary up to the dollar amount of its board-approved contract with the NPA with-
out consulting with the Human Resources Department or requesting administrative cabinet approval.
School site staff reported the large number of contracted special education paraeducators in limited term
assignments are difficult to keep track of and monitor. Certain principals reported they cannot provide
proper oversight of these special education paraeducators. They explained that they do not always know
which contracted special education paraeducators are assigned to their school or for what hours but are
asked to sign timecards for these contracted staff.
Recommendations
The district should:
1. Begin using adult-to-student ratios to help determine the assignment of special education
paraeducators to SDCs and determine whether it can reduce paraeducator staffing while
still meeting student needs.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 25
Findings and Recommendations Special Education Paraeducator Staffing
2. Determine the amount of time completed SCIA assessments wait for SCIA panel review and
evaluate its SCIA process to decide whether revisions are necessary.
3. Consistently use SCIA assessment results to determine whether one paraeducator can
provide 1-to-1 support to more than one student at a school.
4. Ensure that each IEP that calls for 1-to-1 paraeducator support, except for medically
necessary support, includes goals for independence and a support phase-out plan that is
actively monitored.
5. Only contract with an NPA for the number of vacant special education paraeducator
positions. Obtain administrative cabinet approval for any new special education
paraeducator positions.
6. Determine criteria for the use of limited term assignments for special education staff, and
avoid deviating from it.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 26
Findings and Recommendations Related Service Provider Staffing and Caseloads
Related Service Provider Staffing and Caseloads
Related services are the developmental, corrective and other services required to help a child with a dis-
ability benefit from special education (34 CFR 300.34). These services are written into students’ IEPs and
include but are not limited to physical therapy, speech and language therapy, and occupational therapy.
FCMAT analyzed staffing ratios for the district’s adapted physical education (APE) teachers, occupational
therapists, physical therapists, school nurses, school psychologists, speech and language pathologists (SLPs),
teachers for students who are deaf/hard of hearing, and teachers for students who are visually impaired.
Staffing ratios for other related service providers were not analyzed because there is no established industry
standard for them. The industry standards for related service providers are shown in Table 17 below.
Table 17: Industry-Standard Provider-to-Student Ratios
Industry-Standard or Education Code
Provider Type Provider-to-Student Ratio
Psychologist 1-to-977
SLP (preschool) 1-to-40
SLP (ages 5-22) 1-to-55
APE Teacher 1-to-45-55
Physical Therapist 1-to-45-55
Occupational Therapist 1-to-45-55
Vision and Orientation and Mobility 1-to-10-30
Deaf and Hard of Hearing 1-to-15-25
Nurse 1-to-2,274
Sources: Industry standards, Education Code 56363.3, and Pupil Services Staff by Type (CDE).
Adapted Physical Education
The district’s contract with the teachers’ association does not stipulate a caseload size for APE teachers.
In 2024-25, the district has 5.0 FTE APE teacher positions with a combined total caseload of 161 students
receiving direct services, as shown in Table 18 below. All APE teachers are district employees.
Table 18: Adapted Physical Education Teacher Staffing, 2024-25
2024-25 Industry-Standard Staffing
Number Total Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-)
Provider of FTE Caseload Average Student Ratio Industry Standard Industry Standard
3.58 FTE (to meet 1-to-45) +1.42 FTE (above 1-to-45)
APE Teacher 5.0 161.0 32.2 1-to-45-55
2.93 FTE (to meet 1-to-55) +2.07 FTE (above 1-to-55)
Sources: District-provided data and industry standards.
Note: Only students receiving direct services from the district’s APE teachers were included in the total caseload and related calculations.
As shown in the table, the district is one to two FTE above the industry-standard staffing level range for
APE teachers. Staff indicated that each APE teacher serves students at several schools, but they split their
assignments by attendance area and reported there is no significant travel time between schools. The dis-
Fiscal Crisis and Management Assistance Team Fremont Unified School District 27
Findings and Recommendations Related Service Provider Staffing and Caseloads
trict needs to review APE teacher caseload projections, assessment loads, the number of schools each APE
teacher supports, driving times between schools, direct and consultation service minutes, and students’
needs to determine if it can reduce the number of APE teachers and continue to meet students’ needs.
Credentialed School Nurses
In 2024-25, the district has 16.0 FTE credentialed school nurse positions, each with an average caseload
of 2,066.44 students, as shown in Table 19 below. The district also has a 1.0 FTE lead school nurse position
that was not included in this analysis.
Table 19: Credentialed School Nurse Staffing, 2024-25
Industry-
Number 2023 Standard Staffing
of FTE Census Day Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-)
Provider Positions Enrollment Average Student Ratio Industry Standard Industry Standard
School
16.0 33,063 2,066.44 1-to-2,274 14.54 FTE +1.46 FTE
Nurse
Sources: Pupil Services Staff by Type (CDE), district-provided data, and Enrollment for Charter and Non-Charter Schools - Fremont Unified (CDE).
Note: The district also has a 1.0 FTE lead school nurse position that was not included in this analysis.
As shown in the table, the district is staffed just above the industry-standard staffing levels for credentialed
school nurses. The district needs to annually review its enrollment, special education enrollment, duties
performed by credentialed school nurses, schoolwide needs, and students’ needs to determine whether it
needs to change credentialed school nurse staffing.
Occupational Therapy
The district’s contract with the teachers’ association does not stipulate a caseload size for occupational
therapists.
In 2024-25, the district has 6.0 FTE occupational therapist positions, each with an average caseload of 19.0
students receiving direct services, as shown in Table 20 below. The district contracts with an NPA for 1.0
FTE of its occupational therapist staff and the other 5.0 FTE are district employees. The district does not
use certified occupational therapy assistants (COTAs).
Table 20: District Occupational Therapist Staffing, 2024-25
Industry-
2024-25 Standard Staffing
Number Total Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-)
Provider of FTE Caseload Average Student Ratio Industry Standard Industry Standard
Occupational 2.53 FTE (to meet 1-to-45) +3.47 FTE (above 1-to-45)
6.0 114 19.0 1-to-45-55
Therapist 2.07 FTE (to meet 1-to-55) +3.93 FTE (above 1-to-55)
Sources: District-provided data and industry standards.
Notes: Only students receiving direct services from the district’s occupational therapists were included in the total caseload and related
calculations.
As shown in the table, the district has more than double the industry-standard staffing levels for occupa-
tional therapists. Staff reported that the number of students who receive consultation services from an
occupational therapist increases the number of occupational therapists needed. However, the district does
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Findings and Recommendations Related Service Provider Staffing and Caseloads
not recognize that it is staffed significantly higher than the industry standard. The district needs to review
occupational therapist caseload projections, assessment loads, the number of schools each occupational
therapist serves, driving time between schools, direct and consultation service minutes, and students’
needs to determine if it can reduce the number of occupational therapists and continue to meet students’
needs.
Physical Therapy
The district’s contract with the teachers’ association does not stipulate a caseload size for physical
therapists.
In 2024-25, the district has 4.0 FTE physical therapist positions, each with an average caseload of 14.0 stu-
dents receiving direct services, as shown in Table 21 below. All the district’s physical therapist positions are
filled through an NPA.
Table 21: District’s Physical Therapist Staffing, 2024-25
Industry-
2024-25 Standard Staffing
Number Total Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-)
Provider of FTE Caseload Average Student Ratio Industry Standard Industry Standard
1.24 FTE (to meet 1-to-45) +2.76 FTE (above 1-to-45)
Physical Therapist 4.0 56.0 14.0 1-to-45-55
1.02 FTE (to meet 1-to-55) +2.99 FTE (above 1-to-55)
Sources: District-provided data and industry standards.
Note: Only students receiving direct services from the district’s physical therapists were included in the total caseload and related calculations.
As shown in the table, the district has more than three times the industry-standard staffing levels for physi-
cal therapists. Staff reported that the number of students who receive consultation services from a physical
therapist increases the number of physical therapists needed. However, as with occupational therapist
staffing, the district does not recognize that its physical therapist staffing is far higher than the industry
standard. The district needs to review physical therapist caseload projections, assessment loads, the
number of schools each physical therapist supports, driving time between schools, direct and consultation
service minutes, and students’ needs to determine if it can reduce the number of physical therapists and
continue to meet students’ needs.
In addition to being staffed significantly above the industry standard for physical therapists, in 2024-25
none of the physical therapist positions are filled with a district employee. Staff reported that the district
has developed a job description for a physical therapist position, but it has not been approved. The district
needs to perform a cost benefit analysis of having district-employed physical therapist positions versus
continuing to contract through an NPA. By not doing so, the district may be increasing its costs. In addition
to potential cost savings, hiring its own employees would give the district more control over the manage-
ment of its physical therapists.
School Psychologists for School-Age Programs
Article 36.10.2.1 of the district’s contract with the teachers’ association states: “The District will maintain no
fewer than the number of positions budgeted for Special Education testing for 1995-96 for the term of the
Agreement. This number is exclusive of psychologists who work with special categories of students, includ-
ing the infant program, pre-school program, or any program for which the District receives reimbursement
from special funds, outside of the Special Education or General Fund.”
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Findings and Recommendations Related Service Provider Staffing and Caseloads
In 2024-25, the district has 40.5 FTE school psychologist positions; 36.9 FTE of these positions serve
school-age programs, each with an average caseload of 896.02 students, as shown in Table 22 below. The
district’s other 3.6 FTE school psychologists serve the infant or preschool programs, or exclusively provide
educationally related mental health services, and were not included in this staffing comparison.
Table 22: School Psychologist Staffing for School-Age Programs Compared to Industry Stan-
dard, 2024-25
Industry-
2023 Standard FTE Needed to Staffing
Number Census Day Caseload Provider-to- Meet Industry Above (+) or Below (-)
Provider of FTE Enrollment Average Student Ratio Standard Industry Standard
School
Psychologist
36.9 33,063 896.02 1-to-977 33.84 FTE +3.06 FTE
for School-Age
Programs
Sources: District-provided data, Pupil Services Staff by Type (CDE), and Enrollment for Charter and Non-Charter Schools - Fremont Unified (CDE).
Note: The district’s 3.6 FTE school psychologists who serve the infant or preschool programs, or exclusively provide educationally related
mental health services, were not included in this staffing comparison.
As shown in the table, the district is staffed above the industry-standard staffing levels for school psycholo-
gists for school-age programs. Staff reported that school psychologists who serve the school-age program
work in the comprehensive role of a school psychologist, which means they provide social-emotional and
behavioral support, consult with teachers, provide one-to-one counseling, and complete assessments.
Staff reported that most of these psychologists’ time is spent on initial and triennial psychoeducational
assessments.
Staff reported that the high number of initial assessments, which have been ongoing since the return to
schools following the COVID-19 pandemic, places significant demands on the school psychologists’ work-
load and increases the district’s need for school psychologists. The district needs to begin collecting quar-
terly data by school on:
• Referrals for assessments.
• Assessments completed.
• Students who qualify and do not qualify for services.
Tracking this data will enable the district to identify referral patterns by school, teacher or service provider,
supporting more informed decisions about staffing and resource allocation.
District school psychologists identified two other factors, outlined below, which influence their workload
and the number of staff needed.
• Before considering a special education assessment, students with learning differences
and/or behavioral or social-emotional needs should be referred to a student success team
(SST). This school-based team approach is designed to help students with a wide range
of concerns related to their school performance and experience. Staff explained that the
district’s SST and coordination of services team (COST) processes function well at certain
schools, but do not provide adequate intervention and support in the general education
program at other schools, which leads to a high number of initial assessments and influ-
ences the school psychologists’ workload.
• Staff reported school teams have a poor understanding of how the exclusionary factors,
such as limited English proficiency or environment or economic disadvantage, need to be
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Findings and Recommendations Related Service Provider Staffing and Caseloads
considered when determining whether a student qualifies for special education with a spe-
cific learning disability.
In addition to addressing the items above, the district needs to annually review the following items to help
determine how many FTE school psychologist positions it needs:
• The number of initial psychoeducational assessments in the current school year.
• The number of annual and triennial psychoeducational assessments expected next school
year.
• The number of early reassessments expected next school year.
• Total student enrollment.
• Special education enrollment.
• Individual school needs.
Speech and Language Pathologists
Article 36.12.2.1 of the district’s contract with the teachers’ association states, “The District shall not exceed
a caseload maximum beyond California Education Code limits (including those limits for Special Education
Pre-School).”
Speech and Language Pathologists Serving the Preschool
Program
Education Code 56441.7(a) establishes a maximum caseload of 40 students for SLPs serving preschool
students.
In 2024-25, the district has 9.0 FTE SLPs who work exclusively with preschool age students; 3.6 FTE of
these SLPs only administer assessments and do not have a caseload, so they were excluded from this
analysis. The remaining 5.4 FTE SLPs providing therapy for preschool age students each have an average
caseload of 21.85 students receiving a direct service, as shown in Table 23 below.
Table 23: Preschool Speech and Language Pathologist Staffing, 2024-25
Contract and FTE Needed to Staffing Above (+) or
Education Meet Contract Below (-) Contract
2024-25 Code Standard and Education and Education Code
Number Total Caseload Provider-to- Code Provider-to- Standard Provider-to-
Provider of FTE Caseload Average Student Ratio Student Ratio Student Ratio
SLPs for Preschool 5.4 118 21.85 1-to-40 2.95 FTE +2.45 FTE
Sources: District-provided data and EC 56441.7(a).
Note: Only preschool-age students receiving direct services from a SLP were included in the caseload average for comparison with the EC
56441.7(a) maximum.
The district’s 3.6 FTE SLPs who administer preschool assessments and do not have a caseload were not included in this staffing comparison. In
addition, the district’s 1.0 FTE SLP serving infants was not included in this staffing comparison.
As shown in the table, the district has nearly double the industry-standard staffing levels for SLPs serving
preschool age students. Staff indicated that increased student needs following the COVID-19 pandemic
and a higher than usual number of speech and language initial assessments have necessitated an increase
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Findings and Recommendations Related Service Provider Staffing and Caseloads
in the district’s SLP staffing for preschool. However, since the district has 3.6 FTE exclusively performing
assessments, that should not be a factor in determining the number of SLPs needed to provide direct ser-
vices to students. The district needs to review SLP caseload projections and students’ needs to determine
if it can reduce preschool SLP staffing while continuing to meet students’ needs.
Speech and Language Pathologists Serving School-Age
Students
Education Code 56363.3 establishes a maximum caseload of 55 students for SLPs serving students ages
5-22.
In 2024-25, the district has 39.4 FTE SLPs working exclusively with school-age students who each manage
an average caseload of 53.83 students receiving a direct service, as shown in Table 24 below. The dis-
trict also has a 1.0 FTE SLPs supporting students in both the preschool and school age programs who was
excluded from this analysis.
Table 24: School Age Speech and Language Pathologist Staffing, 2024-25
Education FTE Needed to Meet Staffing
2024-25 Code Standard Education Code Above (+) or Below
Number Total Caseload Provider-to- Provider-to-Student (-) Education Code
Provider of FTE Caseload Average Student Ratio Ratio Maximum
SLPs —
39.4 2,121 53.83 1-to-55 38.56 +0.84 FTE
School-Age
Sources: District-provided data and EC 56363.3.
Notes: Only students receiving direct services from an SLP who serves only school-age students were included in the caseload average for
comparison with the EC 56363.3 maximum.
The district’s 1.0 FTE SLP who serves students in both the preschool and school-age programs was not included in this staffing comparison.
As shown in the table, the district is staffed almost exactly at the industry-standard staffing levels for SLPs
for school-age programs.
Teachers for Students Who are Deaf or Hard of Hearing
The district’s contract with the teachers’ association does not stipulate a caseload size for teachers for stu-
dents who are deaf or hard of hearing.
In 2024-25, the district has a 1.0 FTE teacher for students who are deaf or hard of hearing. This teacher has
a caseload of 64.0 students receiving direct services, as shown in Table 25 below.
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Findings and Recommendations Related Service Provider Staffing and Caseloads
Table 25: Staffing for Teachers for Students Who are Deaf or Hard of Hearing, 2024-25
Industry
2024-25 Standard Staffing
Number Total Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-)
Provider of FTE Caseload Average Student Ratio Industry Standard Industry Standard
Teachers for
Students Who are 4.27 FTE (to meet 1-to-15) -3.27 FTE (below 1-to-15)
1.0 64 64.0 1-to-15-25
Deaf or Hard of 2.56 FTE (to meet 1-to-25) -1.56 FTE (below 1-to-25)
Hearing
Sources: District-provided data and industry standards.
Notes: Only students receiving direct services from the district’s teacher for students who are deaf or hard of hearing were included in the total
caseload and related calculations.
As shown in the table, the district is staffed significantly less than the industry-standard staffing level for
teachers for students who are deaf or hard of hearing. Staff reported that the 1.0 FTE teacher for students
who are deaf and hard of hearing is working in a 1.4 FTE position this school year. The district needs to
review caseload projections, the assessment load, the number of schools served, driving time between
schools, direct and consultation service minutes, and students’ needs to determine whether it needs to
increase staffing for teachers for students who are deaf or hard of hearing.
Teachers for Students Who are Visually Impaired
The district’s contract with the teachers’ association does not stipulate a caseload size for teachers for stu-
dents who are visually impaired.
In 2024-25, the district has 2.0 FTE teachers for students who are visually impaired, each with an average
caseload of 18.5 students receiving direct services, as shown in Table 26 below.
Table 26: Staffing for Teachers for Students Who are Visually Impaired, 2024-25
Industry
2024-25 Standard Staffing
Number Total Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-)
Provider of FTE Caseload Average Student Ratio Industry Standard Industry Standard
Teachers for
Students Who are 2.0 37.0 18.5 1-to-10-30 Within Industry-Standard Range
Visually Impaired
Sources: District-provided data and industry standards.
Notes: Only students receiving direct services from the district’s teachers for students who are visually impaired were included in the total case-
load and related calculations.
As shown in the table, the district is staffed within the industry-standard staffing level range for teachers of
students who are visually impaired. Staff reported that they have unfilled teacher positions for students who
are visually impaired, which they have been unable to recruit and fill. The district needs to annually review
caseload projections, the assessment load, the number of schools served, driving time between schools,
direct and consultation service minutes, and students’ needs to determine whether it needs to change staff-
ing for teachers for students who are visually impaired.
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Findings and Recommendations Related Service Provider Staffing and Caseloads
Recommendations
The district should:
1. Annually review staffing for all related service providers to determine whether it is aligned
with the industry standards and meets student needs.
2. Evaluate whether it can reduce its staffing for adapted physical education teachers,
credentialed school nurses, occupational therapists, physical therapists, and SLPs for the
preschool program to align with Education Code or industry standards while still meeting
students’ needs.
3. Collect quarterly data to identify patterns in referrals for initial psychoeducational
assessments by school psychologists, particularly for students who do not qualify for
services.
4. Assess its SST and COST processes to determine if improvements are needed to ensure
there are adequate intervention and support opportunities in the general education
program at all district schools.
5. Provide training for general education teachers and staff serving as administrative
designee at IEP meetings on special education eligibility and how to consider the
exclusionary factors when determining whether a student qualifies for special education
with a specific learning disability.
6. Review caseload projections, the assessment load, the number of schools served, driving
time between schools, direct and consultation service minutes, and students’ needs to
determine whether it needs to increase staffing for teachers for students who are deaf or
hard of hearing.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 34
Findings and Recommendations Unrestricted General Fund Contribution to Special Education
Unrestricted General Fund Contribution to
Special Education
Fiscal Background
California’s special education funding structure was established by and is commonly referred to as
Assembly Bill (AB) 602, which was introduced and signed into law in 1997 and became effective during the
1998-99 fiscal year.
Under AB 602, special education funding is based on the average daily attendance (ADA) of all students in
a school district, regardless of the number of students served in special education programs or the cost to
serve them. California distributes special education funds to SELPAs based on their member districts’ total
ADA counts.
In addition to AB 602 state funding, districts receive a small amount of federal funds. These funds are
designed to supplement the general education program, not to support a standalone program.
The combined state and federal funds are insufficient to pay for even the most efficient special education
programs. Districts make contributions to special education from local resources generated by all students,
including those in special education. These contributions are the amount of funding districts must transfer
from their unrestricted general funds to pay for the portion of special education costs that exceeds program
revenues.
Federal law requires districts to spend at least the same amount of state and local funds on special edu-
cation services in each successive year. This is commonly referred to as the maintenance of effort (MOE).
This requirement has limited exemptions, and if a district is considering reductions to its total general fund
contribution to special education, it is required to follow the guidelines in the MOE document (20 USC 1413
(a)(2)(B)). The IDEA lists the following circumstances as exceptions that allow a district to reduce the amount
of state and local funds it spends on special education:
i. Voluntary departure, by retirement or otherwise, or departure for just cause, of special educa-
tion or related services personnel;
ii. A decrease in the enrollment of children with disabilities;
iii. The termination of the obligation of the agency to provide a program of special education to
a particular child with a disability that is an exceptionally costly program, as determined by the
state educational agency, because the child:
a. Has left the jurisdiction of the agency;
b. Has reached the age at which the obligation of the agency to provide free and appro-
priate public education (FAPE) to the child has terminated; or
c. No longer needs the program of special education; or
iv. The termination of costly expenditures for long-term purchases, such as the acquisition of
equipment or the construction of school facilities.
The year-end expenditures charged to special education goal codes in the Standardized Account Code
Structure (SACS), which is the state’s financial reporting format, and allocated expenses in the Program
Cost Report (PCR), are used to calculate special education MOE. If special education savings are included
in the district’s fiscal sustainability plan, the MOE requirement must be considered. Districts need to mon-
itor their MOE throughout the year and analyze forecasts of MOE calculations at first and second interim
financial reporting periods. Districts should be mindful of what expenses are charged to special education
Fiscal Crisis and Management Assistance Team Fremont Unified School District 35
Findings and Recommendations Unrestricted General Fund Contribution to Special Education
SACS goal codes, including for non-special education SACS resource codes, because those may increase
the MOE. In addition, districts should monitor reductions in expenditures to determine if any meet one of
the exceptions that may allow the district to reduce the amount of state and local funds it spends on special
education.
When monitoring their MOE, districts need to analyze their PCR, which is used to calculate the total cost of
each program within the general fund. The district’s 2023-24 special education MOE increased significantly
due to a higher proportion of expenses reported as special education in its PCR and increases in direct and
indirect costs. CDE indicates that districts may restate additions to MOE because of annual PCR allocations
up to the end of the year subsequent to the year of the report submitted to the CDE. The district needs to
review its special education PCR allocations for 2023-24 and determine whether it may revise or reduce its
MOE.
Building Comparable Data
Resource codes in the SACS are used to identify revenues and expenditures that have specific accounting
or reporting requirements or that are legally restricted. Special education SACS resource codes are used
to record special education spending and therefore contain vital information about a district’s unrestricted
general fund contribution to its special education program.
The special education financial reporting methods used by districts, county offices of education and
SELPAs can vary. For example, Fremont Unified includes expenses such as classroom supplies, furniture,
computer equipment, legal/settlement and transportation costs in this reporting, while other districts
exclude them. There are also differences in how special education funds are allocated by SELPAs. Because
of these differences, it is not always possible to accurately compare a district’s unrestricted general fund
contribution to those of other districts. However, a district should evaluate a contribution that is excessive
compared to other districts or that is increasing disproportionately compared to other costs.
In addition, staff reports and data reviewed indicate the district provides little general education fiscal
support for the special education classes. Since students with disabilities are general education students
who generate Local Control Funding Formula (LCFF) revenue, most districts pay for certain expenditures for
SDCs, such as classroom supplies and furniture, using general fund dollars. However, Fremont Unified does
not do this.
To calculate an unrestricted general fund contribution amount that can be compared year to year and
includes expenditures most districts classify as special education, FCMAT made the following adjustments
to the district’s SACS data:
• To improve multiyear continuity, FCMAT used only ongoing special education income.
FCMAT removed one-time funding totaling $2,674,397 in 2021-22, $1,303,608 in 2022-23,
and $246,222 in 2023-24. It appears that special education expenditures charged to these
one-time state and federal income sources were ongoing and were budgeted by the dis-
trict as such beginning in 2024-25.
• FCMAT used only special education expenses in the comparison. During the review period,
the district charged some non-special education expenditures to special education SACS
resource codes. To ensure that the unrestricted general fund contributions analyzed are
attributed solely to special education services, FCMAT excluded the following non-spe-
cial education expenses from its calculation: $679,952 in 2021-22, $1,085,297 in 2022-23,
$1,648,207 in 2023-24 and $2,667,270 in 2024-25.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 36
Findings and Recommendations Unrestricted General Fund Contribution to Special Education
• The district did not include in its MOE the impact of special education expenses charged
to one-time non-special education SACS resource codes. Because these expenses were
made from non-special education one-time revenue sources, they did not require a dis-
trict contribution. These one-time revenues caused large one-time reductions in the unre-
stricted general fund contribution to special education and included the following:
◦ Elementary and Secondary School Emergency Relief Fund (ESSER).
◦ Extended Learning Opportunities Program grant.
◦ WorkAbility grant.
◦ Other restricted local funds.
FCMAT added the following amounts back for comparison purposes: $2.7 million in 2020-
21, $1.6 million in 2021-22, $2.6 million in 2022-23 and $2.6 million in 2023-24. The impact
of the one-time funding on the unrestricted general fund contribution dropped to $1.2
million in the 2024-25 adopted budget as these funds were exhausted.
• Full indirect costs have been charged to all special education programs using the CDE’s
approved rates for all the comparison years. The best practice is to charge the full indi-
rect rate to all programs, including those with special education SACS resource codes, so
that the true cost of the special education program can be determined. For continuity of
data, FCMAT made minor modifications to the district’s reported prior year indirect costs
charged to special education to account for the adjustments listed above.
Even with these adjustments, the district’s general fund contribution trend does not directly correlate to
its increases in total special education expenditures or special education MOE. This is because transpor-
tation expenses are included in total special education expenditures for MOE purposes but are reported
separately in Table 27 below. Transportation income is not reported since the California School Accounting
Manual has not developed a method to match the income with the expense. For 2024-25, the district’s
transportation expenses are projected to increase its special education MOE by $13 million. However, the
estimated $4.5 million in special education transportation income for 2024-25 is not credited to the SACS
special education goal code.
District Special Education Expenses
FCMAT analyzed the district’s special education income and expenditures, using only ongoing income from
fiscal years 2021-22 to 2024-25 (one-time 2021-22, 2022-23 and 2023-24 income was excluded), as shown
in Table 27 below.
Table 27: Comparison of Special Education Expenses Using Ongoing Income Only, 2021-22 to
2024-25
Average
Historical Historical Historical Projected Historical
Category 2021-22 2022-23 2023-24 2024-25 Annual Rate
Increase in Special Education Students -4.66% 0.28% 4.46% N/A N/A
Increase in Ongoing Income 3.4% 10.5% 2.1% -7.3% 5.3%
Increase in Certificated Salaries 2.6% 11.3% 12.7% 3.6% 8.9%
Increase in Non-Transportation Classified
2.7% 11.0% 14.1% 14.7% 9.3%
Salaries
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Findings and Recommendations Unrestricted General Fund Contribution to Special Education
Average
Historical Historical Historical Projected Historical
Category 2021-22 2022-23 2023-24 2024-25 Annual Rate
Increase in Transportation Classified Salaries -8.7% 45.8% 29.5% 23.8% 22.2%
Increase in Benefits 9.6% 16.8% 17.7% 16.1% 14.7%
Increase in Books and Supplies 80.3% 17.4% -18.6% -3.1% 26.4%
Increase in Transportation Supplies 64.8% 40.4% -7.2% 4.6% 32.7%
Increase in Services (Excluding
17.8% 20.4% 39.3% 21.0% 25.8%
Transportation)
Increase in Services (Transportation Only) 759.2% 41.5% 53.9% 20.5% 284.9%
Increase in Capital Expenditures -100% 100% 185% -21.1% 61.7%
Increase in Indirect Costs -4.3% 19.6% 51.2% 0.5% 22.2%
Increase in Adjusted General Fund
18.9% 18.4% 39.2% 26.1% 25.5%
Contribution
Adjusted Dollar Amount of General Fund
$42,934,615 $50,844,444 $70,799,450 $89,263,331 N/A
Contribution
Adjusted Dollar Amount of Special Education
$80,870,813 $92,750,171 $113,565,725 $129,114,174 N/A
Expenses
Sources: Official SACS unaudited actuals. 2024-25 data was projected using SACS first interim actual year-to-date expenses extrapolated
using SACS first interim to unaudited actual ratios for the past three years, 2024-25 settlements for the classified employee and management
bargaining groups, and health and welfare increases for all bargaining groups according to its public disclosure collective bargaining agreement.
However, certificated instructional salaries for 2024-25 were estimated using a ratio of 2023-24 first interim to unaudited actuals, and adding
step and column increases.
Notes: Official SACS unaudited actuals and 2024-25 income and general fund contribution data were reduced by one-time income in 2020-21,
2021-22, 2022-23, and 2023-24, and indirect costs were adjusted. Ongoing costs charged to non-special education resources are included in
the total cost of the program but do not have a fiscal impact on the district contribution.
Amounts and percentages in the “Increase in Ongoing Income,” “Increase in Adjusted General Fund Contribution,” and “Adjusted Dollar Amount
of General Fund Contribution” categories were adjusted to exclude expenses charged to non-special education ongoing income, and for
adjusted indirect costs.
The “Adjusted Dollar Amount of Special Education Expenses” category was adjusted to match footnoted entries in the district’s budget.
Special Education Funding and Expenses
The average increase in ongoing special education funding over the last three years has been 5.3% per
year. In 2024-25, the district is projecting a 7.3% decrease in special education income.
In 2023-24, special education income increased by 2.1% and special education enrollment increased by
4.46%, but expenses increased more than the income. In addition to increases in the number of special
education employees and their salaries, the cost of services, excluding transportation, increased by 39.3%.
Staffing Costs
From 2021-22 to 2023-24 there was an average annual increase of over 25% per year in paraeducator
expenses, which include raises, positions and/or services. Based on classified payroll documents from July
2024 through FCMAT’s visit, FCMAT estimates that the district’s paraeducator expenses will increase by
another 15% this year and that the district is approximately $3.8 million under budgeted as of first interim.
One cause of this is that the district’s special education hiring process happens separately from position
Fiscal Crisis and Management Assistance Team Fremont Unified School District 38
Findings and Recommendations Unrestricted General Fund Contribution to Special Education
control, as mentioned in the “District Organization” section of this report. So there is an inconsistency
between the number of special education paraeducator position vacancies and the number of paraedu-
cators for which the Special Education Department contracts with an NPA. As explained in the “Nonpublic
Agency Paraeducator Staffing” section of this report, staff estimated that the district contracts for 100
special education paraeducators, some of whom are placed in limited-term assignments, and correspond to
only approximately 25 paraeducator vacancies in the budget.
For its 2024-25 projection, FCMAT used public disclosure collective bargaining agreement documents to
account for negotiated compensation increases, which were approved by the district’s governing board on
October 23, 2024. This included a one-time 3.5% payment off the salary schedule and adding employee
dental coverage. No other settlements occurred prior to first interim in 2024-25 with the district teachers’
union or Service Employees International Unit (SEIU). Even without these settlements all bargaining group
salary increases exceeded average income increases in the review period.
Cost of Services
The cost of NPA/NPS services per student enrolled in special education has increased from $6,488 in 2021-
22 to $11,300 in 2023-24, which is a 74.17% increase. The cost of legal fees and settlements appears to
have stabilized since an escalation in 2022-23 and only increased by 4.5% between 2022-23 and 2023-24.
Therefore, the continuing increase in services is probably not driven by one-time expenditures.
Transportation Costs
Ninety percent of the capital expenditure budget is set aside for transportation. Transportation supply
costs, primarily fuel, continue to increase at a higher rate than other expenses, and service costs are
increasing at approximately the same rate as other educational services. Despite an increase of 22.2% in
transportation salaries, positions and/or services, there has been no corresponding reduction in transporta-
tion-related contracted services.
District Unrestricted General Fund Contribution
The district’s adjusted unrestricted general fund contributions, including expenditures for adjusted indi-
rect costs and increases or reductions for one-time income and redirected income, are shown in Table 28
below.
Table 28: District’s Adjusted Unrestricted General Fund Contributions to Special Education,
2020-21 through 2023-24
Category 2020-21 2021-22 2022-23 2023-24
Adjusted Unrestricted General Fund Contribution $36,124,010 $42,934,615 $50,844,444 $70,799,450
Percentage of Adjusted Special Education Costs 47.74% 53.09% 54.82% 62.34%
Sources: Official SACS unaudited actuals data.
Note: Official SACS unaudited actuals income and unrestricted general fund contribution data were adjusted for one-time income in 2020-21,
2021-22, 2022-23 and 2023-24. Expenses include adjusted indirect costs.
In 2023-24, the district’s unrestricted general fund contribution (using adjusted indirect costs and excluding
one-time income) was 62.34% of adjusted special education costs. The fluctuations in expenses observed
in 2020-21 and 2021-22 were associated with declines in expenses during periods when students were
Fiscal Crisis and Management Assistance Team Fremont Unified School District 39
Findings and Recommendations Unrestricted General Fund Contribution to Special Education
generally not in attendance because of the COVID-19 pandemic. Since 2021-22, the district has incurred
significant employee collective bargaining settlement costs and increased staffing expenses.
In 2024-25, the district’s unrestricted general fund contribution as a percentage of total special education
costs, inclusive of adjusted indirect costs, is projected to increase to 69.14% based on first interim actual
projections and the district budget.
Recommendations
The district should:
1. Review its special education PCR allocations for 2023-24 and determine whether it may
revise or reduce its MOE.
2. Disaggregate, monitor and track transportation, NPA and NPS costs, and annually analyze
trend data to use for budgeting.
3. Conservatively budget for transportation, NPA and NPS costs, and compare year-to-date
actuals to budget at interim reporting.
4. Use position control information in budget development for special education salaries and
benefits, particularly if the revenue source is not a special education SACS resource.
5. Review position control as it relates to paraprofessional placements. Reconcile payroll to
position to budget, paying particular attention to positions filled with contractors.
6. Continue to monitor its unrestricted general fund contribution to the special education
program.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 40
Findings and Recommendations School Transportation
School Transportation
State Funding for School Transportation
Historically, school transportation has been one of the most poorly funded areas in California’s education
budget. Before 1977, school transportation was fully funded. School districts reported their operational
costs and were fully reimbursed in the subsequent school year. However, after the adoption of Proposition
13, the state began reducing the percentage of reimbursement for school transportation. By 1982-83, dis-
tricts were reimbursed at 80% of their reported costs, and the state imposed a cap, limiting reimbursements
to the costs reported by school districts in that particular year.
Between 1982-83 and 2012-13, costs rose significantly, cost-of-living adjustments (COLAs) were only occa-
sionally granted, demographics underwent changes, and the demand for special education transportation
surged dramatically. The subsequent economic downturn during the great recession, beginning in 2007
and lasting several years, prompted the state to reduce all categorical programs, including school transpor-
tation, by approximately 20%.
In the 2013-14 fiscal year, California adopted the LCFF. Under this formula, school transportation funding
was allocated as an add-on to each district’s base grant. This funding must be spent on school transporta-
tion expenses, and districts must meet an MOE requirement, ensuring that they spend at least the amount
received to maintain the same level of funding.
The Budget Act of 2022 increased school transportation funding. Starting in 2022-23, the LCFF home-
to-school transportation add-on receives the cost of living adjustment (COLA). In addition, districts may
receive 60% of total prior year transportation costs (reported in Function 3600), less the LCFF home-to-
school transportation add-on.
In addition, the Budget Act of 2022 trailer bill language reinstated school transportation data collection and
required each district in California to adopt a plan by April 1, 2023, articulating how it will offer pupil trans-
portation to the district’s unduplicated students (those who are English learners, socioeconomically disad-
vantaged, or are foster youth or homeless). The district developed and adopted its Transportation Services
Plan as required so it may receive school transportation funding equal to 60% of the prior year’s student
transportation expenditures reported in Function 3600. Subsequent Transportation Services Plans adopted
by the district’s governing board must be adopted each year by April 1 unless the district chooses to adopt
a multiyear plan.
District School Transportation Funding
Since the inception of LCFF, the district has received $379,937 for school transportation. Its 2022-23 unau-
dited actuals financial report indicates that the district spent $7,551,920 for school transportation. The dis-
trict did not report any capital expenses in 2022-23, which would have reduced its eligible transportation
related expenses for reimbursement. Sixty percent of the district’s eligible school transportation expendi-
tures was $4,531,152.
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Findings and Recommendations School Transportation
District School Transportation Costs
Total Transportation Program Cost
The district’s transportation program expenses doubled between 2021-22 and 2023-24 as shown in Table
29 below. The district’s 2024-25 adopted budget projects a decrease of $4,653,339 in transportation
expenditures over the previous year. However, based on historical program expenditures and a review of
transportation expenditures for the first half of the 2024-25 fiscal year, FCMAT estimates the district will
spend approximately $13.4 million for transportation in 2024-25.
Table 29: District Transportation Expenses, 2021-22 to 2024-25
Total Transportation
Fiscal Year Source Expenditures Percent Increase
2021-22 District 2021-22 Unaudited Actuals $5,212,686 N/A
2022-23 District 2022-23 Unaudited Actuals $7,551,920 +44.88%
2023-24 District 2023-24 Unaudited Actuals $10,780,496 +42.75%
2024-25 District 2024-25 Adopted Budget $6,127,157 -43.16%
FCMAT Projected Based on Expenditures to
2024-25 $13,400,000 +24.30%
Date at the Time of FCMAT’s Visit
Sources: District-provided data.
Transportation Cost Per Student
The district’s unaudited actuals financial report shows it spent $11,642 per student for school transpor-
tation in the 2023-24 fiscal year. Considering the total number of students the district transports and the
most recent state comparisons, this is a high average per-student cost. The state stopped collecting school
transportation data with the implementation of the LCFF, but the Budget Act of 2022 required school trans-
portation data collection to resume. Upon its publication, the district can conduct a thorough comparison of
recent per-student transportation costs.
The district is projecting to spend $14,470 per student for school transportation in 2024-25. This is a high
per-student cost and is partially caused by the district’s heavy reliance on a contracted external transportation
provider that has a low student load ratio of one to three students per vehicle. Many districts contract with exter-
nal transportation providers using low student load ratios per vehicle because it is necessary to support certain
student needs. However, Fremont Unified contracts with an external transportation provider using low student
load ratios per vehicle to transport a significant percentage of the district’s students who receive transportation
service. This is costly and needs to be reduced. The district needs to explore expanding its district-operated
bus routes to achieve a significantly greater student load ratio per bus run, which could reduce its heavy depen-
dence on contracted transportation providers and its annual per student transportation expense.
Under the new law, districts may receive state funding for reimbursement of up to 60% of expenses associ-
ated with contracted external transportation providers if the district tracks these expenses in Function 3600.
Based on the CDE Home-to-School Transportation Apportionment for the period 2022-23 Annual, it appears
the district is not tracking all student transportation-related expenses under Function 3600. As a result, the
district may not receive the full 60% of its student transportation-related expenses annually. All district staffing
and external contract services related to student transportation should be identified under Function 3600 to
ensure the district is receiving up to 60% reimbursement based on its student transportation-related expense.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 42
Findings and Recommendations School Transportation
Staff reported that the district reimburses 72 parents/guardians for mileage for transporting their student in
lieu of receiving district-provided transportation service. The district uses a standard parent in-lieu trans-
portation contract using the prevailing mileage rate set by the IRS and pays for one round trip per school
day of attendance. This use of parent in-lieu transportation contracts increases efficiency, and it is a posi-
tive practice.
Recommendations
The district should:
1. Ensure it tracks all student transportation expenses to Function 3600 so the district can
receive 60% reimbursement for these expenses.
2. Explore expanding its district-operated bus routes to achieve a significantly greater student
load ratio per bus run to improve cost efficiency.
3. Reduce its high dependency on contracted transportation providers that transport only a
few students per vehicle.
Student Transportation Program
In 2024-25, the district reported it provides transportation services for 1,207 students. Of these, 281 stu-
dents receive transportation for the district's Regional Occupational Program (ROP) and 926 receive trans-
portation as a related service in their IEPs.
The district augments its internal student transportation program by using contracted external transporta-
tion providers, including Student Transportation of America (STA) and a transportation network company
(TNC), Pawar Transportation. As shown in Table 30 below, 32.7% of all special education students receiving
transportation support are assigned to Pawar Transportation. Use of a TNC for contracted external trans-
portation services is not unusual, but the volume of students transported by Pawar Transportation is one of
the highest observed across the state in recent years.
Table 30: Number of Vehicles Used, Number of Students Transported, and Average Student
Load Ratio by Student Transportation Provider, 2024-25
Student
Transportation Number of Students Percentage of Total Average Student Load
Provider Number of Vehicles Used Transported Students Transported Ratio
District Internal
Transprotation 39 School Buses 533 57.60% 13.7 Students Per Vehicle
Operation
STA 10 School Buses 90 9.72% 9.0 Students Per Vehicle
TNC Pawar
165 Passenger Vehicles 303 32.72% 1.8 Students Per Vehicle
Transportation
Total 214 926 N/A N/A
Sources: District-provided data.
Note: The number of students includes students receiving transportation as a related service in their IEP and homeless students transported
under the federal McKinney-Vento Assistance Act.
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Findings and Recommendations School Transportation
The district’s use of internal and contracted external transportation resources ensures comprehensive sup-
port for its diverse student population, including those requiring transportation as a related service in their
IEPs and those identified under McKinney-Vento.
Students with disabilities often require a more restrictive transportation model. For example, many require
curb-to-curb service, while others may be assigned to corner or centralized bus stops depending on their
needs. Individualized transportation is often dictated by the student’s disability. Consequently, this service
model, combined with program locations outside a student's residence school, often results in longer ride
times and lower student load ratios on buses and passenger vehicles.
Student Load Ratios
In urban and suburban regions like Fremont, school bus load ratios of 10-15 students are typical. Factors
such as distance from a student's residence to their program, regional traffic, and the need for specialized
transportation equipment can influence these ratios. TNCs and other alternative transportation passenger
vehicle providers are typically used for highly specialized individual transportation needs. Such providers
often transport only one to three students per trip due to limited seating or unique program schedules.
The district’s student load ratios for school buses and alternative transportation passenger vehicles are
consistent with state norms. However, its heavy reliance on TNCs and alternative transportation passenger
vehicle providers significantly increases its per-student transportation cost. The district needs to consider a
routing model adjustment to increase the number of students per vehicle or add more district-operated or
contracted school bus routes.
While partnerships with TNCs and alternative transportation passenger vehicle providers can supplement
internal transportation, these services must balance meeting students' needs with cost effectiveness.
Historical routing challenges, exacerbated by the COVID-19 pandemic, have contributed to the district’s
dependency on these providers. A nationwide shortage of licensed school bus drivers, coupled with
competition from the Bay Area's technology sector, has further strained recruitment efforts. Many districts
statewide have similarly turned to alternative transportation passenger vehicle providers to address driver
and vehicle shortages.
Effective use of TNCs or alternative transportation passenger vehicle providers is essential but should not
replace the cost efficiency of school buses, which can transport significantly more students. To address
these challenges, the district needs to focus on recruitment strategies to attract and retain school bus
drivers. Some districts have successfully created transitional positions, employing candidates as alterna-
tive transportation vehicle operators while training them for commercial bus driver certification. Others
have implemented guaranteed-time contracts or combined driver roles with additional responsibilities to
enhance job appeal. As discussed in the “Driver Training and Safety” section of this report, the district
needs to ensure it has adequate training staff to prepare both commercial school bus drivers and alterna-
tive transportation vehicle operators.
Contracted Transportation Services
As previously mentioned, the district contracts with two external transportation providers: Pawar
Transportation and STA.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 44
Findings and Recommendations School Transportation
Pawar Transportation
Pawar Transportation, a TNC, typically subcontracts driver operators who transport one to four students in
alternative passenger transportation vehicles. Districts typically use TNCs to meet individual or small-group
transportation needs, such as to transport a student to a unique program location with limited student
attendance or an out-of-district program in which using a district school bus for just a few students would
be inefficient. Operators of alternative passenger transportation vehicles must comply with driver and
vehicle standards established under Senate Bill 88 (Chapter 380, Statutes of 2023), which include minimum
inspection requirements and basic driver qualifications. Although this transportation model is generally
more costly, it can provide savings when district staff or smaller vehicles are unavailable.
Student Transportation of America (STA)
STA is a yellow school bus external service contractor, operating buses in small-, medium-, and large-chas-
sis configurations designed to transport larger groups of students. Its drivers are commercially trained and
licensed, meeting stringent regulatory and operational standards. School districts often use external yellow
bus contractors to either fully manage their student transportation needs or supplement their internal
operations. Yellow buses, like those operated by the district, achieve significantly higher student load ratios
compared to TNCs or alternative transportation passenger vehicle providers.
In 2024-25, FCMAT’s projected per student transportation cost for the district’s two contracted external
transportation providers is similar, approximately $14,500 per student as shown in Table 31 below.
Table 31: FCMAT’s Projected Costs for the District’s Contracted External Transportation
Providers, 2024-25
FCMAT FCMAT
Contracted FCMAT District Projected Projected
External Projected Reported Per Student 2024-25 District Reported
Transportation 2024-25 Number of 2024-25 Daily Number and Type
Provider Expense Students Expense Expense of Vehicles Student Load Ratio
165 Alternative
Pawar
$4,400,000 303 $14,521.45 $80.67 Transportation 1.8 Students Per Vehicle
Transportation
Passenger Vehicles
STA $1,300,000 90 $14,444.44 $80.25 10 School Buses 9.0 Students Per Vehicle
Total $5,700,000 393 N/A N/A 175 N/A
Sources: District-provided data.
Note: The projected 2024-25 total expense, per student expense, and daily expenses are based on the regular school year (180 days).
The district needs to evaluate its reliance on external transportation contractors, prioritizing a reduction in
dependency on Pawar Transportation. Expanding internal school bus operations by recruiting, training, and
adding additional school bus routes could help achieve this goal. Given the current district student load
ratio of 13.7 students per bus run, adding 10 new school bus routes with an average load of 14 students per
route could reduce reliance on Pawar Transportation by nearly 50%.
Recruiting and training 10 additional school bus drivers would require approximately four to six months. To
ensure the success of this initiative, the district needs to have sufficient state-certified bus driver instructors
and behind-the wheel-instructors in place as described in the “Transportation Department Staffing” section
of this report. A well-planned classroom and behind-the-wheel training schedule will be essential for timely
and successful licensing.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 45
Findings and Recommendations School Transportation
Recommendations
The district should:
1. Explore routing models to increase the number of students per route or vehicle or consider
adding district-operated or contracted school bus routes.
2. Develop alternative driver recruitment strategies to attract and retain certified school bus
drivers and alternative vehicle operators to enhance its internal transportation capacity and
reduce reliance on costly contracted external transportation providers.
Use of Special Education Transportation and Decision Tree
The IDEA explicitly states that transportation should not be a barrier to a student accessing their IEP and
receiving a FAPE. A best practice is to use a transportation decision tree, which is a graphical representa-
tion of different options, when assessing a student’s need for special education transportation as a related
service.
The district reported it created a transportation decision tree to ensure that only students meeting disabil-
ity or program location criteria receive district transportation services. However, the number of students
with IEPs requiring student transportation as a related service raises questions about the effectiveness and
proper application of the decision tree during IEP development.
Based on what is observed across the state, 10%-15% of special education students in most districts require
transportation as a related service. In contrast, the district reported that 27.8% of students with IEPs receive
transportation services, which includes students whose parent/guardian receives in-lieu compensation.
This high percentage suggests that transportation as a related service may be identified too broadly and
not be aligned with IDEA guidelines. Additionally, it may indicate inconsistent use of the transportation
decision tree when determining transportation needs. The high percentage of students receiving transpor-
tation as a related service significantly contributes to the district’s overall high transportation costs.
Recommendation
The district should:
1. Review its transportation decision tree to ensure it aligns with legal requirements and best
practices for authorizing transportation as a related service in a student’s IEP, and ensure it
is consistently used.
Transportation Department Staffing
The district’s Business Services Division supports its transportation program, and the district’s director of
transportation oversees both internal transportation operations and manages the contracted external trans-
portation providers. Day-to-day transportation program duties include school bus routing and scheduling,
dispatch services, managing school bus drivers, facilitating vehicle maintenance by trained mechanics, and
organizing a robust driver training program that covers initial certifications, renewals, and ongoing in-ser-
vice training. The district’s director of transportation maintains a thorough understanding of school trans-
Fiscal Crisis and Management Assistance Team Fremont Unified School District 46
Findings and Recommendations School Transportation
portation laws and regulations. The district has cultivated strong relationships with its contracted external
transportation providers, which contribute to efficient and reliable transportation services.
In addition to facilitating daily student transportation, the district’s Transportation Department coordinates
and schedules extracurricular and cocurricular activity trips. These are often supplemented through con-
tracts with external charter bus companies that employ Special Pupil Activity Bus (SPAB)-licensed operators
and vehicles to ensure compliance with safety regulations.
In 2024-25, the district’s Transportation Department has the positions listed in Table 32 below. Table 32
also outlines recommended staffing changes, which are intended to reduce the district’s heavy reliance on
contracted external transportation providers and support the recruitment and training of additional district
school bus drivers and training personnel.
Table 32: Transportation Department Positions and Full-Time Equivalent or Number of Staff and
Recommended Staffing Changes, 2024-25
Position FTE or Number of Positions Recommended Staffing Change
Director of Transportation 1.0 FTE None
Transportation Supervisor 1.0 FTE None
State Certified Trainer-Driver/Safety 1.0 FTE Add 1.0 FTE
Driver/Designated Behind-the-Wheel Instructor 0 FTE Add 3.0 FTE
Dispatchers 3.0 FTE Reduce by 1.0 FTE
New Technical Position Such as Transportation Router 0 FTE Add 1.0 FTE
Vehicle Maintenance Coordinator 1.0 FTE None
Equipment Mechanic-Lead 1.0 FTE None
Equipment Mechanics 5.0 FTE None
Equipment Mechanic-Sub 1.0 FTE None
Staff Secretary III 1.0 FTE None
Office Assistant III 1.0 FTE None
Account Clerk III 1.0 FTE None
Bus Driver I and II 10 Positions Increase by 10 Positions
Van Drivers 13.0 FTE None
Increase to Create a Substitute Driver
Bus Driver Sub II 1.0 FTE Pool Equivalent to 10% of Total Bus
and Van Routes
Source: District-reported data.
The district’s current transportation staffing includes 13.0 FTE van drivers. Depending on the district’s plans
to expand school bus or passenger vehicle routes, the recommended FTE increase for school bus drivers
can be adjusted to align with its goals.
The district employs a 1.0 FTE substitute bus driver. Industry standards suggest maintaining a substitute
driver pool equivalent to 10% of the total number of bus and passenger van routes. The district needs to
consider increasing its substitute driver pool to meet this benchmark and ensure sufficient coverage.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 47
Findings and Recommendations School Transportation
Recommendations
The district should:
1. Consider adjusting its staffing in accordance with the recommendations in Table 32 to
support the expansion of its internal transportation service, including additional school bus
or passenger van routes, and to reduce its reliance on contracted external transportation
service providers.
2. Increase the substitute driver pool to approximately 10% of the total number of bus and
passenger van routes.
Vehicle Maintenance, Fleet and Facilities
The district operates its own internal school bus fleet and is responsible for fleet maintenance. The fleet
includes 85 school buses of varying sizes and 10 passenger vans. The transportation vehicle maintenance
team also supports 250 additional district vehicles, bringing the total fleet to approximately 345 vehicles.
Safety Compliance Report/Terminal Record Update
California regulations require all school buses to receive a full inspection from the California Highway Patrol
(CHP) Motor Carrier Safety Unit. The CHP Motor Carrier Inspector Unit also inspects all vehicle mainte-
nance records, driver on-duty records, driver timekeeping records, and federal drug and alcohol testing
records. The unit produces a report of its findings entitled the “Safety Compliance Report/Terminal Record
Updates,” commonly referred to as the CHP terminal grade.
The district earned grades of “satisfactory” on its most recent CHP terminal grade inspections in May 2022,
June 2023, and November 2024. This designation is the highest grade awarded to any motor carrier and
indicates that the carrier generally complies with the laws and regulations governing school bus safety.
Conversely, a grade of “unsatisfactory” indicates a serious deficiency or deficiencies. In such cases, the
CHP clearly advises that failure to correct the deficiencies may lead to severe consequences, including a
recommendation to the Public Utilities Commission (PUC) to revoke the district’s motor carrier operating
authority, filing a complaint with the district attorney for potential prosecution, and seeking an injunction.
Failing to correct these issues may result in criminal charges against the governing board and the superin-
tendent. Given the district’s satisfactory CHP terminal grades, it is operating a safe and compliant school
transportation program.
School Bus Safety Inspections and Maintenance
School buses are required to be inspected every 45 days or 3,000 miles, whichever occurs first per Title 13
of the California Code of Regulations, Section 1232 (13 CCR 1232). In addition, this code requires that each
motor carrier have a written preventive maintenance program for its vehicles. FCMAT audited the district’s
school bus inspection reports and school bus maintenance records and found that the 45-day, 3,000-mile
inspections are performed at the required intervals.
As the district transitions to using electric vehicles, specialized training will be essential. The district cur-
rently manages four Thomas Built electric buses but faces infrastructure challenges related to charging
systems, which are being addressed with the bus distributor and charger vendor.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 48
Findings and Recommendations School Transportation
Transportation Department Fleet and Facility
Fleet Expansion and Replacement
Based on current staffing and fleet capacity, the district can add 10 to 20 new school bus routes without
requiring additional buses. However, if passenger van routes are also expanded, additional vans will need
to be acquired.
Staff reported that the district is already aggressively pursuing electric vehicle and infrastructure support
grants through various funding opportunities. These efforts align with California Air Resources Board
(CARB) regulations requiring all new school buses purchased after 2035 to be zero-emission. The district
needs to remain vigilant for potential adjustments or delays to these regulations under new federal admin-
istration policies and update its fleet replacement plans accordingly.
Transportation Facilities
The district has a well-equipped transportation terminal that is located with other district support services.
The facility includes:
• Four double-door maintenance bays with two in-ground lifts, one above-ground lift, and
one set of portable lifts.
• Adequate parking for the district-owned fleet and space for future electric-vehicle
infrastructure.
• Above-ground fuel storage tanks for gasoline and diesel, meeting current double-walled
protection standards.
• An electronic fuel management system for efficient fuel tracking.
Recommendations
The district should:
1. Continue to pursue electric vehicle and related infrastructure support grants.
2. Evaluate passenger vehicle needs if it decides to expand both school bus and passenger
van routes.
3. Monitor changes in emission standards at the state and federal levels and adjust fleet
replacement plans as necessary.
Driver Training and Safety
School Bus Driver Training
School bus driver training in California is highly regulated. Pursuant to EC 40080-40089, prospec-
tive school bus drivers are required to complete a minimum of 20 hours of classroom training and
20 hours of behind-the-wheel training, using a curriculum developed by the CDE’s Office of School
Transportation (CDE’s OST). Typically, classroom training takes approximately 35 hours to cover all the
units, and behind-the-wheel training requires a similar amount of time. Furthermore, in accordance with
EC 40084.5, school bus drivers must also complete at least 10 hours of annual in-service training.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 49
Findings and Recommendations School Transportation
All annual classroom and behind-the-wheel training sessions must be conducted by a state-certified school
bus driver instructor. Additionally, behind-the-wheel training may also be administered by a designated
behind-the-wheel instructor, another classification of instructor allowed by law and certified by the CDE’s OST.
Current Training Resources
The district has one state-certified bus driver instructor. To support the recommendations in the
“Contracted Transportation Services’” section of this report about increasing the number of district-oper-
ated school bus routes and district transportation staffing, the district needs to consider:
• An additional state-certified bus driver instructor.
• Training up to three qualified district drivers as designated behind-the-wheel instructors to
assist with behind-the-wheel training under the guidance of the certified instructors.
Proficiency and Safety Programs
Title 13, Section 1229 of the California Code of Regulations mandates that every commercial driver must
demonstrate proficiency for each type of vehicle before operating it on the road without supervision. The
district has implemented a safety and training program to meet this requirement.
The district also maintains a Transportation Safety Plan compliant with Education Code 39831.3. This plan
outlines protocols for post-route bus checks to ensure no students are left unattended and must be regu-
larly updated to reflect current practices. The plan must be available at each school site and accessible to
CHP officers upon request.
Employer Pull Notice Program
All school bus drivers are enrolled in the California Department of Motor Vehicles’ Employer Pull Notice
program in compliance with the California Vehicle Code. This provides annual driver records and real-time
updates on moving violations, accidents, or incidents involving driving under the influence. Under Senate
Bill 88, the district must also enroll any staff who transport students in district vehicles, such as teachers
and coaches, to ensure compliance with this regulation. At the time of this report, the district indicated that
it is aggressively moving towards full compliance with the numerous sections of SB 88.
Evacuation Drills and Student Safety
Education Code 39831.5 requires districts to conduct school bus emergency evacuation drills annually.
Since all but two of the district’s bus routes are for students in special education, physical evacuations
are conducted only by students able to perform the evacuation drill. Districts must also maintain specific
records for students in TK through grade eight who ride school buses. Specific safety information must also
be announced before every field trip. Staff reported that the Transportation Department is aware of these
regulations and has already conducted and documented, or calendared, the required drills to meet the
annual requirement in 2024-25.
Since the district primarily transports special education students, staff reported that evacuation drills are
carefully planned to accommodate the needs and capabilities of these students. Physical evacuation drills
are conducted only for students able to perform them safely, and plans are tailored to each route to ensure
effective emergency preparedness.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 50
Findings and Recommendations
Recommendations
The district should:
1. Add one state-certified bus driver instructor to meet the increased training and licensing
demands for additional school bus drivers.
2. Identify and train up to three qualified district school bus drivers as designated behind-the-
wheel instructors to assist with training efforts as necessary.
3. Continue to enroll all staff who operate district vehicles, or any volunteer who transports
students, in the California Department of Motor Vehicles’ Employer Pull Notice program.
4. Continue to ensure that all required evacuation drills are completed as early as possible
each school year and provide accommodations for students with disabilities.
Fiscal Crisis and Management Assistance Team Fremont Unified School District 51
Appendix
Appendix
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Appendix
Appendix A: Study Agreement
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Appendix
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Appendix
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Appendix
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Appendix
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Appendix
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Appendix
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Appendix
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Appendix
Erik Burmeister, S
\__,up (cid:1)
erintendent Date
Fremont Unified School District
ForFCMAT:
9/30/24
Shayleen Harte, Deputy Executive Officer Date
Fiscal Crisis and Management Assistance Team
9
V010262024
Fiscal Crisis and Management Assistance Team Fremont Unified School District 61