Garden Grove Unified School District Report

Garden Grove Unified School District Special Education Review June 3, 2016 Joel D. Montero Chief Executive Officer Fiscal crisis & ManageMent assistance teaM June 3, 2016 Gabriela Mafi, Ed.D., Superintendent Garden Grove Unified School District 10331 Stanford Ave. Garden Grove, CA 92840 Dear Superintendent Mafi: In August 2015, the Garden Grove Unified School District and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for a review of the district’s special education programs and services. Specifically, the agreement states that FCMAT will perform the following: 1. Analyze whether the district provides a continuum of special education and related services to students who are in preschool through age 22, and include an analysis of the least restrictive environments. 2. Analyze special education teacher staffing ratios and class and caseload size using the statutory requirements for mandated services and statewide guidelines. 3. Review the efficiency of paraeducator staffing, including 1-1 paraeducators. Analyze the procedures for identifying the need for instructional aides, and the process for monitoring the resources for allocating paraeducators and determining the need for continuing support from year to year. Provide recommendations to improve efficiency of staffing. 4. Analyze all other staffing and caseloads for designated instruction providers, including psychologists, occupational and physical therapists, behavior specialists, and others. 5. Review the use of resources allocated for nonpublic schools and agencies, mental health services and alternative programs, and make recommendations for greater efficiency. 6. Review Special Education Department staffing and organization in the district’s central office, including staffing comparisons, to ensure that clerical and admin- istrative support, programs, and overall functionality are aligned with those of districts of comparable size and structure. The team will compare the district’s special education staffing and organization with that of three to six similar-sized K-12 unified districts using the Ed Data website, or six districts selected by the district. The report will include recommendations to improve staffing and organizational efficiency and effectiveness. 7. Review the district’s implementation of student study/success teams, (SSTs), the 504 process, and Response to Intervention (RtI), and provide recommen- dations as needed. 8. Determine the district’s special education student identification rate compared to statewide average, and make recommendations, if needed. 9. Determine the district’s general education fund contribution to special education and make recommendations for greater efficiency in areas of devel- opment, tracking and coding. This final report contains the study team’s findings and recommendations in the above areas of review. FCMAT appreciates the opportunity to serve the Garden Grove Unified School District, and extends thanks to all the staff for their assistance during fieldwork. Sincerely, Joel D. Montero Chief Executive Officer Fiscal crisis & ManageMent assistance teaM i TABLE OF CONTENTS Table of Contents Foreword .................................................................................................iii Introduction ............................................................................................1 Background ......................................................................................................1 Study and Report Guidelines .....................................................................1 Study Team.......................................................................................................2 Executive Summary ..............................................................................3 Findings and Recommendations .....................................................5 Special Education Programs and Services ............................................5 Staffing and Caseloads ...............................................................................11 Related Service Provider Caseloads .......................................................15 Instructional Assistants ..............................................................................21 Nonpublic Schools/Agencies ...................................................................25 Organizational Structure ...........................................................................27 Response to Intervention ..........................................................................29 Identification Rate ........................................................................................33 Fiscal Efficiencies ..........................................................................................35 Appendices ............................................................................................41 Garden Grove Unified School diStrict ii Fiscal crisis & ManageMent assistance teaM iii ABOUT FCMAT About FCMAT FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify, prevent, and resolve financial, human resources and data management challenges. FCMAT provides fiscal and data management assistance, professional development training, product development and other related school business and data services. FCMAT’s fiscal and manage- ment assistance services are used not just to help avert fiscal crisis, but to promote sound financial practices, support the training and development of chief business officials and help to create efficient organizational operations. FCMAT’s data management services are used to help local educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and inform instructional program decisions. FCMAT may be requested to provide fiscal crisis or management assistance by a school district, charter school, community college, county office of education, the state Superintendent of Public Instruction, or the Legislature. When a request or assignment is received, FCMAT assembles a study team that works closely with the LEA to define the scope of work, conduct on-site fieldwork and provide a written report with findings and recommendations to help resolve issues, overcome challenges and plan for the future. FCMAT has continued to make adjustments in the types of support provided based on the changing dynamics of K-14 LEAs and the implementation of major educational reforms. Studies by Fiscal Year 90 80 70 60 50 40 30 20 10 0 92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15 Garden Grove Unified School diStrict seidutS fo rebmuN FCMAT also develops and provides numerous publications, software tools, workshops and professional development opportunities to help LEAs operate more effectively and fulfill their fiscal oversight and data management responsibilities. The California School Information Services (CSIS) division of FCMAT assists the California Department of Education with the imple- mentation of the California Longitudinal Pupil Achievement Data System (CALPADS) and also maintains DataGate, the FCMAT/CSIS software LEAs use for CSIS services. FCMAT was created by Assembly Bill (AB) 1200 in 1992 to assist LEAs to meet and sustain their financial obligations. AB 107 in 1997 charged FCMAT with responsibility for CSIS and its statewide data management work. AB 1115 in 1999 codified CSIS’ mission. iv ABOUT FCMAT AB 1200 is also a statewide plan for county offices of education and school districts to work together locally to improve fiscal procedures and accountability standards. AB 2756 (2004) provides specific responsibilities to FCMAT with regard to districts that have received emergency state loans. In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to those types of LEAs. Since 1992, FCMAT has been engaged to perform more than 1,000 reviews for LEAs, including school districts, county offices of education, charter schools and community colleges. The Kern County Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D. Montero, Chief Executive Officer, with funding derived through appropriations in the state budget and a modest fee schedule for charges to requesting agencies. Fiscal crisis & ManageMent assistance teaM 1 INTRODUCTION Introduction Background The Garden Grove Unified School District was established July 1965. The district encompasses 28 square miles of territory, serving most of Garden Grove and portions of six surrounding cities: Anaheim, Cypress, Fountain Valley, Santa Ana, Stanton, and Westminster. The 2015-16 budget is $599.4 million, making the district the largest enterprise in Garden Grove. With nearly 45,253 students, the district is the third largest among 28 public school districts in Orange County. The district’s enrollment has declined by 800 students during the 2015-16 school year, with a projected additional decrease of 500 students next year. The decline is expected to last until approximately 2020. The district employs more than 5,000 staff members and operates 66 schools: 44 elementary, 10 intermediate, seven high schools, one continuation school, one adult education center, two special education schools and one preschool family campus. The district provides comprehensive educational services for K-12 students and adults, as well as programs such as adult education, preschool, English language development, regional occupational and career technical education, fine arts, gifted and talented education, and special education. The district utilizes the core curriculum for reading, writing, science, history-social science, and mathematics, in addition to music and visual arts instruction, electives, athletics, and leadership development. Study and Report Guidelines FCMAT visited the district on February 9-12, 2016 to conduct interviews, collect data and review documents. This report is the result of those activities and is divided into the following sections: • Executive Summary • Special Education Programs and Services • Staffing and Caseloads • Related Service Provider Caseloads • Instructional Assistants • Nonpublic Schools/Agencies • Organizational Structure • Response to Intervention • Identification Rate • Fiscal Efficiencies • Appendices Garden Grove Unified School diStrict 2 INTRODUCTION In writing its reports, FCMAT uses the Associated Press Stylebook, a comprehensive guide to usage and accepted style that emphasizes conciseness and clarity. In addition, this guide empha- sizes plain language, discourages the use of jargon and capitalizes relatively few terms. Study Team The study team was composed of the following members: William P. Gillaspie, Ed.D. Jackie Kirk-Martinez, Ed.D. FCMAT Deputy Administrative Officer FCMAT Consultant Sacramento, CA Pismo Beach, CA JoAnn Murphy Don Dennison FCMAT Consultant FCMAT Consultant Santee, CA Arroyo Grande, CA Phillip Williams* Laura Haywood Associate Superintendent FCMAT Technical Writer Placer County Office of Education Bakersfield, CA Auburn, CA *As a member of this study team, this consultant was not representing his employer but was working solely as an independent contractor for FCMAT. Each team member reviewed the draft report to confirm accuracy and achieve consensus on the final recommendations. Fiscal crisis & ManageMent assistance teaM 3 EXECUTIVE SUMMARY Executive Summary The district did not meet the statewide targets for increasing least restrictive environment in K-12 regular education settings, achieving 48.4% out of the target of 49.2%, and also continues to maintain 30.3% of students in separate programs, with a target of 24.6%. The district has met the target to significantly reduce the number of students in separate schools. The staff indicated a number of concerns with the recent change in program delivery outlined by the district to blended inclusion models. Site staff are confused regarding the co-teaching model and would like the opportunity to participate in the development of changes to program delivery. FCMAT did not find a written definition/description of the blended inclusion model. The district provides elementary school resource specialist program (RSP) services that address the needs of mild/moderate students. All middle and high school settings provide a blended form of mild/moderate services. District data indicates that a total of 51 RSP teachers serve 955 elementary school students, for an average caseload of one teacher per 18.7 students. This is 9.3 students per caseload lower than the Education Code maximum of 28 students. This district began blending traditional RSP and mild/moderate special day class (SDC) services approximately six years ago. The intent was to develop a system of using learning centers for mild and moderate service. An analysis of elementary SDC caseloads indicates that the district is understaffed by 5.66 of teacher FTE. Staff inconsistently reported how personnel are allocated to school sites each year and throughout the school year. Some staff reported it was based on number of special education classrooms at the site, paired with low socioeconomic status of the student population, while other staff reported that each specialty team could choose where to serve as long as all sites were covered. Included in this report are the staffing findings for nurses, school psychologists, vision teachers, orientation mobility teachers, intensive behavioral specialists, audiologists, adapted PE teachers, and speech and language pathologists. FCMAT analyzed the allocation of classroom-based instructional assistants (IAs) in all areas of special education service including 1-to-1 IAs. The district primarily employs 3.5 hour IAs as a cost saving measure. There are different job descriptions for IAs with various rates of pay and hours of employment. The district analyzes nonpublic school costs and determines annually whether it can provide district programs in lieu of nonpublic schools. When capacity is reached, new district programs are developed; however, nonpublic schools are typically used for intensive services not available in the district and have an ongoing role on the continuum of program options in every district. The district contracts with nonpublic agencies for mental health and related services under the provisions of AB 114. Districts may opt to contract out for these services or provide services from district staff. Either option is appropriate; however, the costs of services must be monitored annually to ensure that the service provision is cost effective. The district has a process in place to monitor the costs and expenditures in the provision of mental health services and can make adjustments to district-hired staff at a point that is cost effective and programmatically effective. FCMAT provided a comparison of the administrative and clerical support structures of four single-district SELPAs of comparable size: Corona-Norco, Santa Ana, Long Beach and San Francisco. The district aligns with other comparable single-district SELPAs in the director/assis- tant director positions, with two such positions. Garden Grove Unified School diStrict 4 EXECUTIVE SUMMARY The district has a clearly defined Student Success Team (SST) process consisting of three steps and outlined in the Procedural Handbook for Special Education. The three-step process consists of Consultation, Formal Plan of Action, and Review for Potential Progress and Monitor Interventions. The district’s SST process is clearly defined and represented visually in a flow chart for site-level teams. Although the district’s SST process is clearly described and information is readily available for all sites, interviews with staff indicate the process is not followed consistently across all sites. This inconsistency may result in a student being referred for assessment or evalua- tion for special education eligibility at one site, but not another. The district’s K-22 identification rate for district of residence disabled students is 11.1%, which exceeds the statewide average of 10.1%. The cost of this overidentification is $774,015.43 for the 2015-16 school year. FCMAT compared the district percentage of special education students by disability to the statewide average percent by disability. This comparison found that the district’s speech or language impairment (SLI) identification rate is 22%, which exceeds the statewide average of 19%, and the district’s average of autism identification is 14%, which exceeds the statewide average of 12%. The district’s general fund contribution based on the MOE documents provided to FCMAT was $20,015,600, or 27.7%, in 2013-14 and $23,029,158, or 28.8%, in 2014-15. The district’s general fund contribution is projected to be $27,542,010 for 2015-16, which is 35.6% of the special education budget. The statewide average is 43%. Fiscal crisis & ManageMent assistance teaM 5 SPECIAL EDUCATION PROGRAMS AND SERVICES Findings and Recommendations Special Education Programs and Services The Individuals with Disabilities Education Act (IDEA) is a federal law ensuring services to disabled children throughout the nation. IDEA governs how states and public agencies provide early interventions, special education and related services to all eligible infants, toddlers (preschoolers), children, and youth with disabilities up to age 22. Further, each state must ensure that a free appropriate public education (FAPE) is available to any individual disabled child who needs special education and related services even though the child has not failed or been retained in a course or grade and is advancing from grade level to grade level (34 CFR 300.101(c)). A review of data and staff interviews indicates the Garden Grove SELPA provides special educa- tion services to students from preschool age through 12th grade. In California, a child receiving services under Part C and eligible for services under Part B must have an individualized education program (IEP) created and in place by the time the child turns 3 years old. Preschool program staff reported the district has regular meetings with the regional center (the agency that provides early intervention services) regarding transition from Part C to Part B of the IDEA. An effective and smooth transition is an essential part of the IDEA, and the district has those procedures in place. The district provides services for infants, which supports continuity of service and effective communication regarding student needs as they transition in the IEP process. State and federal laws mandate that students have the opportunity to be educated in a general education setting with their nondisabled peers, also known as the least restrictive environment (LRE), to the greatest extent possible. Compliance with this mandate is measured by the percentage of time a student is removed from the general education classroom and placed in a special education setting. The U.S. Department of Education, Office of Special Education Programs has provided the California Department of Education (CDE) Special Education Division guidance and instruc- tions on developing calculations to measure progress toward meeting the LRE provision of IDEA. Targets and corresponding benchmarks have been established in the State Performance Plan for IDEA 2004 at both the preschool and K-12 areas. Preschool Least Restrictive Environment There are two measures in the preschool area of the Annual Performance Report on Least Restrictive Environment by the CDE: 1. Regular early childhood program and receiving a majority of special educa- tion and related services in the regular program. 2. Separate special education class, separate school or residential facility. CDE establishes targets for each district in all areas identified on the Annual Performance Report. The district did not meet the statewide targets for increasing access to LRE in regular education settings, achieving only 20.6% out of the required target of >39.8%. The district also continues to maintain 72.9% of students in separate programs out of the required target of <34.4%. The 2013-14 data from CDE is the most recent information available. Garden Grove Unified School diStrict 6 SPECIAL EDUCATION PROGRAMS AND SERVICES 2013-14 District-Level Special Education Annual Performance Report Measure for Garden Grove Preschool Total Number of Percent of Students Students Receiving Number of in Environment Special Education Students in the Receiving Special Measure Ages 3-5 Environment Education Target This Year Target Met Regular Program 717 148 20.6% >39.8% No Separate Program 523 72.9% <34.4% No Data Source; December 2013 CASEMIS Submission Items of Accountability, Age, and Federal Preschool Setting In the 2015-16 school year, the district opened two new preschool locations at Carver and Heritage Schools. Programs offered at these preschool sites are intended for students with significant developmental delays. A newly created version of the Early Childhood Education Center (ECEC) Handbook is provided for all parents and defines all elements of program philosophy, instruction and curriculum. The ECEC program follows the California Department of Education Preschool Learning Foundations and Frameworks. There is a list of community resources for general education preschools on page 19 of the handbook; however, there is no indi- cation that disabled students are integrated into any of these general education preschool options. Carver ECEC has one Head Start classroom and one state preschool classroom. There is a waiver with Head Start to integrate up to 15 Special Education students during the instructional day. The district has been working with the state preschool to create a waiver and develop inclusion opportunities for the 2016-17 school year. In addition, the district has created a low-cost program for its employees to enroll their preschool age students into the language development program at the ECEC to increase LRE at the preschool level. The private preschool option indicates that the family funds these programs. The Head Start option is funded by the federal government and is based on low-income financial criteria; however, it does indicate that it is open to disabled students. The state government funds the state preschool option, and enrollment is limited to those families who meet the low-income criteria. The California Childcare Resource and Referral Network also reports that 8-10% of preschool children who are eligible to attend Head Start or state funded preschools are unable to do so due to a lack of capacity in those programs. In other districts reviewed by FCMAT, districts have funded some slots for state preschools to allow access to a general education preschool for disabled students. The district could consider this option as a way of increasing LRE at the preschool level. Another option is to create reverse mainstream options to include general education preschool students in special education classes. Charging tuition for general education students in these classes will help the district to reduce the excess costs of this type of programming. K-12 Least Restrictive Environment The district did not meet the statewide targets for increasing least restrictive environment in regular education settings, achieving 48.4% out of >49.2%, and also continues to maintain 30.3% of students in separate programs out of the target of <24.6%. The district has met the target to significantly reduce the number of students in separate schools. There are three measures in the K-12 areas: • In a regular class 80% or more of the day • In a regular class less than 40% of the day • In separate schools, residential facilities or homebound/hospital placement Fiscal crisis & ManageMent assistance teaM 7 SPECIAL EDUCATION PROGRAMS AND SERVICES The table below from the CDE indicates that the district has not met the LRE goals. Students with special needs spend more time in specialized classrooms than in general education class. 2013-14 District Level Special Education Annual Performance Report Measure for Garden Grove Unified School District K-12 Total Number of Percent of Students Measure of Time in Students Receiving in Environment Regular Education Special Education Number of Students Receiving Special Class (ages 6-22) in the Environment Education Target This Year Target Met >80% 2681 48.4% >49.2% No <40% 1677 30.3% <24.6% No Separate Schools 5528 56 1% <4.4% Yes Data Source: December 2013 CASEMIS submission items - district of accountability, age, and a complete data field consisting of unduplicated federal school setting and percent in regular class. Retrieved from www.cde.gov April 16, 2015 Note: Separate schools include students in separate schools, residential facilities and homebound/hospital. It does not include students in correctional facilities or those that are parentally placed in private school. The district improved in 2014-15 in reaching LRE targets from 2013-14 (47.8% to 48.5% of students inside the regular class for >80% of the day) and 33.1% to 30.3% (<40% in regular class less than 40% of the day); however, the targets have not been met. The district has met the 4.4% decrease in student placements in separate schools, residential facilities or homebound/ hospital placements. Program Delivery The district provides a range of services to disabled students in kindergarten through 12th grade that includes designated instructional services and general education program/support divided into two categories: mild to moderate and moderate/severe. No strategic planning was completed with school site and district staff (general and special education) to redesign the program delivery model. The staff indicated a number of concerns with the program delivery outlined by the district with regard to the blended inclusion model. Site staff are confused regarding the co-teaching model. The site staff would like the opportunity to participate in the development of changes to program delivery. The district did not provide FCMAT a written definition/descrip- tion of the blended inclusion model. Secondary staff reported that LRE can be a challenge to attain when creating the master schedule. For example, classes are “blocked” on the master schedule for special education students, forcing students to take classes they do not need and denying access to required classes. Staff also are concerned that special education students are unable to access some elective classes. There is confusion among the administrative staff regarding the perception that special education students “do not count” in the overall ADA of the school; however, the district office staff reported that Special Education students have always been counted for ADA. This may be an old perception from the previous funding model that did not provide revenue limit to SDC students. Recent changes in the Local Control Funding Formula (LCFF) funding model have adjusted the revenue limit and included it in the base funding to the district; however, some administrators were not aware of the change. Garden Grove Unified School diStrict 8 SPECIAL EDUCATION PROGRAMS AND SERVICES Staff reported that there are instances at the secondary level where the availability of the blended programs drives the IEP rather than the needs of the student driving placement and services. This can lead to compliance issues with federal and state law. Vision teachers cluster their direct services at three primary locations: Cook Elementary, Jordan Intermediate, and Bolsa Grande High School. Students who can benefit from an itinerant collaborative inclusion setting attend their neighborhood school, while students requiring daily vision services attend one of the hub schools. Cook Elementary provides an RSP but not a mild/moderate program. Staff reported that students who are vision impaired and attend Cook Elementary for direct vision services may not receive an appropriate academic supported educa- tion if they require more academic support than the RSP program allows. The intermediate and high school both provide resource, mild/moderate and moderate/severe programs; therefore, all students can benefit. Mental Health Services On June 30, 2011, Assembly Bill 114, Chapter 43, Statutes of 2011 was signed into law. Under AB 114, several sections of Chapter 26.5 of the California Government Code were amended or rendered inoperative, thereby ending the state mandate on county mental health agencies to provide mental health services to disabled students. With the passage of AB 114 the local educa- tion agencies (LEAs) are now solely responsible for ensuring that disabled students receive mental health and related services. The Annual Service Plan for 2015-16 outlines all of the programs and services for disabled students including mental health services. The Garden Grove Procedural Handbook, Chapter VII describes the program options and services for disabled students and lists educationally related mental health services. The district offers levels of counseling for both students and families and residential treatment when necessary; however, there is no indication of the use for a day treatment option to provide more intensive structured education training and support services to address mental health needs (Code 540, California Department of Education Annual Plan Service/Program Codes 2016). The district provides 24-hour, out-of-home placement that offers intensive therapeutic services to support the educational program. The district does not utilize social work services under the program delivery option in the range of mental health services for disabled students. Although not required, the use of these services outlined in 5 CCR Section 3051.13; 34 CFR Section 300.34 (c)(14) is used by school districts to expand the range of mental health and related services to address problems in the child’s living situation (home, school, community) that affects the child’s adjustment in school and mobilizing school and community resources to enable a child to learn as effectively as possible in the educa- tional program (Code 525, California Department of Education Annual Plan Service/Program Codes 2016). The district provides crisis counseling, short-term counseling, and direct counseling as designated in the IEP. Disabled students needing more intensive counseling are referred for educationally related mental health services assessment and services if needed. The district contracts with two nonpublic school agencies, Rossier Education and Mental Health Enterprises, Inc. and Western Youth Services to complete assessments and provide direct counseling services if needed. Many districts that FCMAT has reviewed do not use the contractor completing the assessment to provide direct services recommended as a result of that assessment; however, the district clearly outlines the responsibilities to avoid any potential conflict of interest pursuant to California Fiscal crisis & ManageMent assistance teaM 9 SPECIAL EDUCATION PROGRAMS AND SERVICES Education Code 56042 in the Master Contract (Section 19) signed by both the district and provider. Recommendations The district should: 1. Continue to adhere to district procedures for eligible students transitioning from Part C services to Part B services of IDEA. 2. Provide clear program criteria for least restrictive environment. 3. Continue efforts to meet LRE targets by maintaining students in programs with access to general education students. 4. Develop a Strategic Plan for Special Education that defines LRE and program delivery and includes representatives from all stakeholders: teachers, special- ists, administrators, parents, etc. 5. Develop an implementation guide to ensure that critical elements of the Strategic Plan are implemented. 6. Continue to provide training and support on co-teaching models for general education and special education teachers. 7. Provide training for site administrators on LRE and the mandate for inclusion that includes equal access to master schedule based on need, not availability. 8. Provide training to site administrators on the LCFF funding model as it relates to special education revenue limit. 9. Examine the availability of academic support programs for students requiring direct vision services at Cook Elementary. 10. Consider the addition of an intensive specialized therapeutic day class as an intensive structured education, training and support service to address student mental health needs. 11. Consider the addition of social work services to strengthen the support services for the mental health needs of students. Garden Grove Unified School diStrict 10 Fiscal crisis & ManageMent assistance teaM 11 STAFFING AND CASELOADS Staffing and Caseloads The resource specialist position provides specialized academic instruction/intervention to disabled students in the general education classroom setting using both a push-in and pullout program. Education Code 56362 identifies the maximum RSP caseload as one teacher per 28 students. The district provides RSP services at the elementary level that address the needs of mild/moderate students. In other elementary settings the district maintains traditional mild/moderate special day classes, as addressed below. All middle and high school settings provide a blended form of mild/ moderate services. District data indicates that a total of 51 RSP teachers serve 955 students, for an average caseload of one teacher per 18.7 students. These RSP services at the elementary schools are approximately 9.3 students per caseload lower than the Education Code maximum of 28 students. By bringing RSP services to the caseload maximum, the district could reduce certificated staffing by approximately 19 FTE. This would yield an annual savings of $2,154,799.50 including salary and benefits. RSP Caseloads Education Code Guideline Ratio Grade Span Total Teacher FTE Total Students Total Ratio (FTE to Student Caseload) Elementary 51 955 1: 18.7 1: 28 Middle 0 0 0 0 High School 0 0 0 0 Total 51 955 1:18.7 1: 28 Source: California Education Code 56362 and district data Mild/Moderate Services The district began blending traditional RSP and mild/moderate SDC services approximately six years ago. The intent was to develop a system of using learning centers for mild and moderate service. Over the intervening years the learning center concept has become a less formal system of combined mild/moderate service. At the elementary level the district maintains traditional RSP services at all elementary school sites, and mild/moderate SDC classrooms at 13 elementary sites. The elementary SDC caseloads are reported separately below. An analysis of elementary SDC caseloads indicates that the district is understaffed by 5.66 of teacher FTE. Adding 5.66 teacher FTE would cost $641,903.43 including salary and benefits. At the middle school and high school levels the district provides a blended service model for all mild/moderate students. Those caseloads are reported separately below. While other districts may alter the name of the program and description of services to maximize efficiency and not require caseload maximums, this district unofficially applies a caseload standard of 28 students. Staff acknowledges the intent to try and maintain caseloads lower than 28 since the services address the needs of students who previously may have been considered appropriate for a mild/moderate SDC. No consistent guidelines for mild/moderate blended caseloads were identified. Therefore, data and information used in this report utilize the data and descriptions aligned with RSP. Staff report more inclusion of special education students in the general education setting but little or no change apparent in staff training and preparation for this service model and little or no change in the direct support provided for those students in the least restrictive environment. Based on an analysis of secondary mild/moderate caseloads, bringing caseload maximums to a standard of Garden Grove Unified School diStrict 12 STAFFING AND CASELOADS 28 students would allow the district to reduce mild/moderate certificated staffing by approximately 12.8 FTE. This would yield a savings of $1,451,654.40 including salary and benefits. Mild/Moderate Elementary School SDC Caseloads Grade Span Total Teacher FTE Total Students Total Ratio Industry Standard (FTE to Student Caseload) Elementary 36 625 1:17.4 1:12-15 Mild Moderate Middle School and High School RSP/SDC Blended Caseloads Grade Span Total Teacher FTE Total Students Total Ratio Industry Standard (FTE to Student Caseload) Middle 27 623 1:23.1 1:28 School High School 51* 1,203* 1:23.5* *Includes Jordan Adult Transition Program Total 78* 1,826* 1:23.4* 1:28 Source: Industry standard and district data Moderate/Severe SDC Services The industry standards for moderate to severe K-12 classrooms are one teacher per 10 to 12 students. The district’s average class size is one teacher per 9.8 students, slightly below the standard for moderate to severe classrooms. In the moderate/severe preschool setting, Education Code 56441.5 establishes a guideline of one adult for every five students. Districts typically utilize instructional assistants as well as teachers to establish the adult-to-student ratio in the preschool setting. The district has 17 preschool teachers. There are 35 IAs in the preschool program which, when converted to 6-hour FTEs, is 32.75 FTE. Applying this total adult FTE to total preschool students reflects an average of 7.9 students per adult. The district addresses high caseloads in the preschool setting by operating both an AM and PM session, with a district imposed maximum class size of 15 students per session. By dividing each teacher caseload into two half-day programs, each program averages 2.93 FTE adult staff. At this staffing level each half-day program averages 3.97 students per adult, which is under the Education Code guideline. Note that each moderate/severe preschool teacher, in the role as case manager, carries an average caseload of 23 students. The review of district-provided records indi- cates that each moderate/severe preschool teacher receives a half day per week without students for case management. Fiscal crisis & ManageMent assistance teaM 13 STAFFING AND CASELOADS Moderate/Severe SDC Caseloads Total Teacher Total Total Grade Span FTE Students Ratio Guidelines (FTE to Student Caseload) 1:10-12 (1 adult to 5 children per EC 56441.5) Preschool 17 395 1:3.97* *Based on 2.93 adult FTE per half-day preschool program. Elementary 26 233 1:9.0 1:10-12 Middle School 7-8 10 87 1:8.7 1:10-12 High School 9-12 11 121 1:11.0 1:10-12 Special Education Center and Adult Transition 13 144 1:11.1 1:10-12 Total 60 585 1:9.8 1:10-12 (Does not include preschool) Source: California Education Code, industry standard and district data Recommendations The district should: 1. Standardize a staffing plan for special education that reflects the total FTE funded by special education revenues, the class sizes and caseload numbers regardless of the type of program implemented at the sites. 2. Develop a comprehensive K-12 plan for providing services to students with mild/moderate disabilities and ensure its implementation. 3. Determine how best to address the elementary understaffing in mild/ moderate SDC within the comprehensive K-12 mild/moderate service plan. 4. Determine how best to address the apparent overstaffing in elementary RSP services and secondary mild/moderate services within the comprehensive K-12 mild/moderate service plan. 5. Consider an increase of 5.66 FTE for mild/moderate elementary SDC teachers at an additional cost of $641,903.43. 6. Consider a decrease of 19 FTE in RSP teachers for a savings of $2,154,799.50. 7. Consider a decrease of 12.8 FTE in secondary mild/moderate teachers for a savings of $1,451,654.40. 8. Provide professional development opportunities for staff who work with moderate students in the general education setting. 9. Provide appropriate support to meet the needs of moderate students in the general education setting. Garden Grove Unified School diStrict 14 Fiscal crisis & ManageMent assistance teaM 15 RELATED SERVICE PROVIDER CASELOADS Related Service Provider Caseloads The district asked FCMAT to analyze related service providers caseloads and staffing ratios including psychologists, speech and language pathologists, nurses, behavior specialists, vision, teachers, orientation and mobility specialists, and adapted physical education teachers. FCMAT received multiple documents prior to conducting fieldwork. During the on-site interviews, it became apparent that documents provided were not all-inclusive. Nor were the documents consistent from the personnel department and the special education department. Specifically, the number of positions filled versus the number of positions allocated differed, as did the resource budget from which the positions were funded. The analysis is provided based on documents that listed specific names of staff who served at specific locations, regardless of resource coding. Staff inconsistently reported how personnel are allocated to school sites each year and throughout the school year. Some reported it was based on number of special education classrooms at the site, paired with low socioeconomic status of the students attending. Other staff reported that each specialty team could choose where to serve as long as all sites were covered. It was expressed that at times multiple same job classification specialists overlap one another at school sites, and it becomes confusing and frustrating for on-site staff to know whom to approach for support. It is also a less efficient way to run an organization. Staff indicated that this is a culture allowed in the district. Occupational Therapists and Physical Therapists The district contracts with nonpublic agencies (NPAs) for occupational and physical therapy. The district reported that in 2014, it conducted a study to determine the cost efficiency of hiring its own staff to serve students. Although FCMAT was unable to obtain those comparison records, staff reported that contracting with an outside agency was a cost benefit to the district. However, this raises several concerns that will be discussed under the NPA/NPS scope of study. Vision Teachers The district employs three full-time vision teachers to serve its infant to 22-year-old visually impaired population. Students who are able to access itinerant services with less frequency and duration are served through their neighborhood school. Students who require more intensive daily instruction are served at one of the sites where a vision teacher is based. The vision teachers’ caseloads are separated by school site. The three teachers’ primary direct intensive services are located at Cook Elementary, Jordan Intermediate and Bolsa Grande High School. The teacher who serves the students at Jordan Intermediate is also the itinerant teacher for the students at all school sites. This teacher is also responsible for the initial assessments and triennial assessments throughout the district. Cook Elementary has five students, all of whom receive direct instruc- tion, and two instructional assistants who provide a total of seven hours of services per day. Jordan Intermediate has two students who both receive direct instruction and one instructional aide who works with the students from 8:30-12:00 daily. The high school has 10 students who require consultative services between teacher and parent for 175 minutes per month. In addition, seven of the students require specialized academic instruction provided by the vision teacher in a pullout service program. Instructional aide hours total 7.5 hours daily. There is also one deaf/ blind intervener used 3.5 hours daily who assists with interpreting and mobility of one student. The teacher who serves the two students at the intermediate school is also the districtwide itin- erant teacher, with a caseload of 48 students. This teacher also consults with the Blind Children’s Learning Center. Some of the students have low vision and can use assistive technology equipment to gain access to their education, while other students may require braille transcription and the need Garden Grove Unified School diStrict 16 RELATED SERVICE PROVIDER CASELOADS to learn braille. Because of the wide variety of service delivery models, the industry standards also vary at one teacher to 10-30 students. The district serves 67 visually impaired students with three teachers, 18 hours per week of instructional aide support and 3.5 hours of a deaf/blind intervener. The average caseload per teacher is 22.33 students, not including aide support. Although it appears the itinerant teacher has an unbalanced caseload, the district determines the caseload. Orientation and Mobility Teachers Orientation and mobility services means “services provided to blind or visually impaired students by qualified personnel to enable those students to attain systematic orientation to and safe movement within their environments in school, home, and community; and includes teaching students the following as appropriate: • Spatial and environmental concepts and use of information received by the senses (such as sound, temperature and vibrations) to establish, maintain, or regain orientation and line of travel (for example, using sound at a traffic light to cross the street); • To use the long cane, as appropriate, to supplement visual travel skills or as a tool for safely negotiating the environment for students with no available travel vision; • To understand and use remaining vision and distance low vision aids, as appropriate; and • Other concepts, techniques, and tools as determined appropriate.” [34 CFR 300.24(b)(6)] Similar to the teachers for the vision impaired, the orientation and mobility teacher industry standards range from 10-30 students depending upon several factors such as: travel time for the instructor; time necessary for consulting with the classroom teacher, other staff and parents; time to develop adapted teaching materials and appropriate sites for instruction; time for completion of documentation; ages of students, the severity of their needs and the instruction necessary to meet those needs. The district’s orientation and mobility teacher provides direct services to 22 students. Sixteen of these students receive direct instruction and six receive a consultation service. Audiologist The district employs one full-time audiologist to serve infants to 22 years of age. The audiologist has a caseload of 109 students through a consultation model. Twenty-six are infants for whom the audiologist coordinates services with other agencies. Other duties include supporting the various amplification technology and equipment for students with hearing impairment. The audiologist serves all district schools. Districts typically utilize the support of an itinerant teacher for the deaf/hard of hearing to assist with collaborative services and equipment. The district does not employ a deaf/hard of hearing itinerant teacher. The district has no procedures or policies to guide staff in accessing the audiologist caseload guidelines. There are no industry standards for audiologists as a sole supporter of all hearing services and equipment. Adapted Physical Education Teachers The district employs nine full time adapted physical education (APE) teachers. The teachers meet monthly with the director of special education. The teachers use consistent entrance and exit criteria. The APE teacher is assigned to the preschool program and can then assess the students prior to kindergarten to determine if they require this service for the following year. The district operates within industry standards for APE. Provider FTE Caseload District average caseload ratio Industry Standards APE 9 496 1-to-55.1 1-to-45-55 Source: District data and industry standards Fiscal crisis & ManageMent assistance teaM 17 RELATED SERVICE PROVIDER CASELOADS Intensive Behavioral Intervention Specialists The Intensive Behavioral Intervention (IBI) program was developed to support district students, return students from private agencies and build defensible programs for students on the autism spectrum disorder. The following is the only district document explaining IBI services, which is located on the district’s website page under the special education department: “In response to the growing population of students eligible for special education and in an effort to meet the unique needs of students with autistic-like characteristics, the Garden Grove Unified School District has pursued the proactive development and implementation of an in-house IBI program with its fundamental principles based on Applied Behavior Analysis (ABA). ABA is a methodology for behavior intervention, in which all of our IBI aides are trained and supervised by our in district Behavior Specialist, who are all licensed Board Certified Behavior Analysts (BCBAs). “ABA is a scientifically validated approach to understanding and managing socially significant behavior that impedes overall student growth. We employ this scientific approach to strategically build appropriate socialization skills, create opportunities for the use of functional communication, eliminate disruptive behavior and teach replacement skills for maladaptive behaviors. The Garden Grove Unified School District honors the IDEA mandate for the appropriateness of least restrictive environments (LRE). Therefore, IBI services range from site consultation to 1:1 support.” There are three levels of IBI supports and services. IBI supervisors must have administrative credentials and must be board certified behavior analysts. These three supervisors evaluate the eight IBI leads and two IBI teachers on special assignment (TOSA). They collect and analyze data, provide professional development, collaborate with home programs and outside agencies, attend challenging IEP meetings, and oversee specific student programs. The IBI TOSAs also must have a behavior analyst certificate. The TOSAs provide professional development to all newly hired IBI staff. Eight lead IBI staff run and facilitate field programs and clinic programs. The field leads run programs in SDCs, whereas the clinics run programs before and after school and unique clinics for preschool. The district has approximately 166 IBI assistants, which will be discussed in the Instructional Assistants section of this report. Staff indicate there is no formal process to determine student need for IBI services. Nurses District documents indicate the district employs 20.5 nurses, with 0.5 FTE open positions for a total of 22 school nurse positions. Staff reported there is only a .5 FTE open position.The nurses support students in all school populations such as general education, SDC and separate special school site. The nurses also support 504 accommodation plans, provide professional development and develop specialized health care plans. The district is a single-district SELPA and provides services to all of the total student population. Based on total district populations and industry standards the district requires 16.25 nursing FTE; therefore, the district potentially would not need 5.75 FTE. The district also employs three LVNs and three health technicians. If the district maintained industry standards it could realize a cost savings of $765,083 in certificated nurses. The district would need to determine the health and safety status of students and determine is a reduction is warranted. Provider FTE Caseload Industry standard District caseload average Nurses 22 45,253 1:2784 1:2,056 Source: District data and industry standards Garden Grove Unified School diStrict 18 RELATED SERVICE PROVIDER CASELOADS Psychologists The district employs 33.7 FTE of school psychologists. One psychologist is on special assignment specific to a grant received by the district and .7 FTE is unfilled. This analysis did not include the grant-funded psychologist as this position is designed separate from the usual support and services of school psychologists. Most of the psychologists are assigned to school sites and support the students and programs located there. They perform the duties common to school psycholo- gists, which consist primarily of attendance at student study team meetings, 504 planning, initial assessments for special education eligibility, report writing, participation in IEP team meetings and triennial evaluations. The district has 1.7 FTE assigned to provide support to the infant and preschool program. The district does not separate the infant/preschool funding and K-12 funding resource at the beginning of the school year. This separation is necessary to assist with deter- mining budget and staffing needs. The FCMAT comparison for psychologist staffing is based on the K-12 assignments. There is no statewide comparison for school psychology staffing in the infant/preschool setting. Therefore the preschool psychologist 1.7 FTE is removed from the K-12 comparison. Most of the district’s school psychologists maintain a counseling caseload of students that they see on a regular and ongoing basis. Most students who are seen by a school psychologist are in Special Education. When counseling is considered for an IEP-related service, the student’s IEP team determines the need for counseling, the frequency/duration, and the exit requirements. The general process for adding counseling as an IEP-related service usually consists of the school psychologist observing the student and reviewing the student’s records. The psychologist typically interviews parents, teachers, administrators and the student, then communicates to the IEP team whether or not the student requires counseling. If the student is recommended for counseling, goals are drafted and monitored for progress. If the students meets the counseling goals, the psychologist usually recommends exit from the service to the IEP team. The district’s school psychologists are the main crisis contact at their assigned school. If either a general education or Special Education student experiences a crisis such as suicidal ideation or grieving a loved one, the psychologist is expected to meet with and support the student. If several students or classes are affected, the crisis response team may be called to support. This team consists of six district psychologists and is used as needed to address a specific traumatic event at a school site. The district distinguishes between the counseling the school psychologist provides as a related service and IEP-based educationally related mental health (ERMH) service. Special Education students that may need more intensive counseling services than those noted above are typically referred for an ERMH assessment. This need is determined by the student’s IEP team, and students usually are referred when they are not making progress on their counseling goal(s). The ERMH assessment helps the IEP team to determine the counseling needs for each referred Special Education student. The district contracts with a mental health agency to complete ERMH assessments and provide some direct ERMH services that are agreed on by the student’s IEP team. Staff indicated there are no formal procedures or eligibility criteria in place to determine a student’s need to receive these IEP-driven services. Psychologists are assigned to provide ERMH services to students, also with no eligibility or exit service criteria. Staff indicated the district does not have a preschool assessment process to determine eligibility for special education from preschool to kindergarten. Fiscal crisis & ManageMent assistance teaM 19 RELATED SERVICE PROVIDER CASELOADS FCMAT uses two sources to compare school psychology staffing. Both sources utilize California data since national averages or recommendations vary too widely to be of statistical significance due to differences in state funding that is contributed to special education. Kidsdata provides a statewide caseload average for K-12 school psychologists of 1,321, and CalEdFacts provides an average of 1,235. Using Kidsdata, the district is understaffed in school psychologists by 2.26 FTE and using CalEdFacts, the district is understaffed by 4.64 FTE (see table below). Based on district average cost for a school psychologist including salary and benefits, an addition of 2.25 FTE represents a cost of $322,310.25 and an addition of 4.6 FTE represents a cost of $658,945.40. Provider FTE Caseload CalEdFacts Kidsdata District Caseload Average Psychologist 32 45,253 1:1,235 1:1,321 1:1,414 Source: Kidsdata, CalEdFacts, district data Speech and Language Pathologists Speech and language pathologists (SLP) provide direct services and consultation supports to students with IEPs. Staff reported that approximately 22 students districtwide receive pre-inter- vention services for a short period of time. The students who may receive these services have a single articulation error where pre-intervention is likely to eliminate the error. Staff reported that teachers have access to forms to refer a student for pre-intervention. Administration was unaware that speech pathologists provide pre-interventions. Approximately 36 students receive consultation-only services. Short-term, consultation-only services are provided as students transition out of the service. Staff reported students are on consultation for a year or less, but there is no districtwide guideline for consistency. Similar to the psychologists, no documents describe the staffing positions under infant/preschool and K-12. Documents provided were inconsistent. The district determines staffing placements and caseloads on several internal agreements. Staff receive a “ghost caseload” of 11 students if the staff is a department lead, or is on an assessment team, or is part of a child find, or provides other coordi- nation support. This practice does not follow the actual Education Code caseload criteria, which considers assessments and child find as part of the caseload determination. Therefore, FCMAT removed the “ghost caseloads” from its caseload calculations. FCMAT used three documents to determine staffing for infant/preschool and K-12: two caseload charts dated January 31, 2016; two SLP schedule charts, and the preschool FTE list. The district employs 51 FTE of SLP. A .3 FTE serves the infants, 7.7 FTE serve preschool and 43 FTE serve K-12 students. This level of staffing represents a total cost, with salary and benefits, of $6,710,376. The assignment of speech pathologists was reviewed from the perspective of differ- entiating preschool speech caseloads from K-12 speech caseloads. The Education Code establishes a maximum caseload of 40 students for preschool (Education Code 56441.7(a)) and 55 students for K-12 (Education Code 566563.3). Using these caseloads, the district is understaffed by 3.1 FTE for preschool and by 1.2 FTE for K-12. The district also employs 4.06 FTE speech and language pathology assistants (SLPA) to provide support to the speech pathologists. According to the American Speech-Language Hearing Association (ASHA), “Speech-language pathology assistants are support personnel who, following academic coursework, fieldwork, and on-the-job training, perform tasks prescribed, directed, and supervised by ASHA-certified speech-language pathologists.” In this district, an SLPA receives an Garden Grove Unified School diStrict 20 RELATED SERVICE PROVIDER CASELOADS average salary not including benefits of $42,960.48. The district may be better served by hiring additional SLPs to reduce the caseload and abide by Education Code. Speech and Language Caseload Comparison District Total FTE District Average Ed Code Maximum FTE Provider to Caseload Ratio Caseload Ratio to Caseload Ratio Speech Language Pathologist Ratio, K-12 43-to-2,430 1-to-56.5 1-to-55 Speech Language Pathologist Ratio, Preschool 7.7-to-433 1-to-56.2 1-to-40 Source Education Code 56441.7(a) 56563.3 and district data Recommendations The district should: 1. Consider balancing the caseloads of the vision teachers. 2. Consider the efficiency and time management of the audiologist providing supports to 109 students. 3. Evaluate the cost efficiency of the IBI program. 4. Develop procedures and consistent evaluation measures to determine specific entrance and exit criteria under the IBI program. 5. Consider nursing reduction at a cost savings of $765,083. 6. Develop guidelines for providing counseling services. 7. Develop guidelines for providing educationally related mental health services. 8. Separate infant/preschool psychologist funding from K-12 funding resources at the start of the school year. 9. Consider an increase in school psychologist positions or altering job responsi- bilities. 10. Develop guidelines for speech and language consultation services. 11. Develop a communication pathway for speech pathologists to identify pre-in- tervention services to the Director of Special Education. 12. Examine the function of the SLPA support in the preschool and K-12 programs to determine if it can be reduced or eliminated. 13. Increase speech and language pathologist FTE in both preschool and K-12 to meet Education Code requirements. 14. Continue to closely monitor speech and language pathologist caseloads to determine eligibility and possible consultation reduction. Fiscal crisis & ManageMent assistance teaM 21 INSTRUCTIONAL ASSISTANTS Instructional Assistants FCMAT analyzed the allocation of classroom-based instructional assistants (IAs) in all areas of special education service including 1-to-1 instructional assistants. The district employs 3.5 hour IAs primarily as a cost saving measure. There are different job descriptions for IAs with varying rates of pay and hours of employment. There is a long established category of instructional aide I (that is being phased out through attrition), instructional aide II, intensive behavior instructional assistant (IBI), and special education assistant. For the purposes of this review, all instructional assistant hours were totaled by program and grade level and converted to 6-hour IA FTE. The district has an unofficial guideline for staffing instructional aides that is below industry standards for moderate/severe programs and for RSP. The industry standard for moderate/severe SDC is two 6-hour IAs. The district staffs moderate/severe SDC on average between 1.38 FTE to 1.86 FTE. Any elementary RSP with more than 15 students has a 3.5-hour IA assigned. The district averages .43 IA FTE in the RSP. Staff indicated there is no defined procedure for determining that additional IA support is required in a given program. At the school site, requests are provided to the principal, who forwards them to the special education administration. The decision to increase IA allocations is primarily based on addressing crisis situations or safety issues. Staff expressed frustration with the time it takes to fill an IA vacancy. District administration states the volume of demand for IA positions is a primary factor in delays encountered in the hiring process. Concern was also expressed with the lack of professional development that is specific to IA assignments and a lack of training at the work site. The district’s procedure in its handbook titled, “Related Services of Classroom Support and Temporary Special Needs Aides” lacks sufficient detail and rigor to assist with a meaningful decision-making process regarding the need for 1-to-1 aides. Staff indicate this procedure is rarely used at any school site. Similar to other IA allocations, the assignment of 1-to-1 IA support is based primarily on addressing a crisis or safety issue. Parent request is also a common factor in this determination. Records review and staff interviews indicate there is no procedure or practice for developing an individualized fade plan in the student IEP when the allocation of individual assistant support is made. When staff are in a position to recommend fading individual support to the IEP team they frequently meet resistance due to the lack of individualized criteria for the team to consider. Other districts in the state are beginning to use a formal assessment procedure to determine the need for special circumstance instructional assistance. The advantages of this are consistency and rigor as well as the defensibility of the district finding and recommendation. The conversion of district 1-to-1 IA positions to 6-hour FTE shows a total of 262.3 hours of 1-to-1 IA time allocated. This averages to 43.7 6-hour FTE. The district established an average salary with benefits for all paraprofessionals at $48,864.17. At an average paraprofessional cost of $48,864.17, the district spends $2,136,341.50 on 1-to-1 IA support. Garden Grove Unified School diStrict 22 INSTRUCTIONAL ASSISTANTS Instructional Assistants Converted to 6-Hour Full Time Equivalent Equivalent Avg. 6 hr. IA FTE Program Grade Level Teacher FTE No. of Students IA Total Hours 6 hr. FTE per Teacher RSP Elementary 51 955 133 22.2 .43 M/M SDC Elementary 36 625 276.5 46.0 1.20 M/M Blended Middle School 27 623 105.0 17.5 .64 High School 50 1,187 168.0 28.0 .56 Mod/Sev. SDC Elementary 26 233 267.5 44.6 1.70 Middle School 10 87 112.0 18.6 1.86 High School 11 121 91.0 15.2 1.38 1-to-1 IAs Elementary 111.9 18.7 Middle School 66.9 11.2 High School 83.5 13.9 Total 6 hr. 1-to-1 FTE 262.3 43.7 Source: District data Recommendations The district should: 1. Implement a well-defined procedure for staff to use when requesting addi- tional instructional assistant support. 2. Continue phasing out the instructional aide I position through attrition. 3. Review the hiring process and procedures for instructional assistant vacancies to determine if greater efficiency can be achieved. 4. Provide more assignment-specific job-alike professional development oppor- tunities for instructional assistant employees. 5. Develop or acquire a comprehensive procedure to determine the need for 1-to-1 assistance and ensure it is used consistently. 6. Consider establishing the 1-to-1 procedure as a formal assessment process. 7. Collect data and develop fade plans through the IEP process for all students with 1-to-1 assistants to support independence. Ensure that the fade plan is reviewed annually at each student’s IEP until 1-to-1 support is discontinued. 8. Consider a decrease in the assignment of 1-to-1 instructional assistants. Fiscal crisis & ManageMent assistance teaM 23 NONPUBLIC SCHOOLS/AGENCIES Nonpublic Schools/Agencies Nonpublic Schools Education Code 56034 defines a nonpublic school (NPS) as follows: “a private, nonsectarian school that enrolls individuals with exceptional needs pursuant to an individual education program and is certified by the department. It does not include an organization or agency that operates as a public agency, … an affiliate of a state or local agency, including a private, nonprofit corporation established or operated by a state or local agency, or a public university or college. A nonpublic, nonsectarian school also shall meet standards as prescribed by the Superintendent and board.” NPS is considered to be an option in the continuum of service for disabled students. Students are placed in NPS when their unique needs outlined in an IEP require specialized programs that are unavailable in the district. The district negotiates NPS contracts and develops individual service agreements for the students served. The district has established firm procedures and processing of invoices for these students, reviews them for accuracy, and dispenses funds to the NPS. The costs have remained constant for the past three years. School Year Annual Cost of Nonpublic Schools 2013-14 $2,641,816 2014-15 $2,605,138 2015-16 $2,606,027 Source: District records and estimated budgeted figures for 2015-2016 The district analyzes NPS costs and determines annually whether there is capacity to provide district programs instead. When capacity is reached, new district programs are developed; however, NPS are typically used for intensive services not available in the district and have an ongoing role on the continuum of program options in every district. Nonpublic Agency Nonpublic agency (NPA) Education Code requirements are the same as for NPS. Education Code 56365(a) requires an NPA to be “under contract with the local educational agency to provide the appropriate special education facilities, special education, or designated instruction and services required by the individual with exceptional needs if no appropriate public education program is available.” The district uses independent contractors when specific expertise is needed that is not available in the district, for independent evaluations that are permitted by federal law, and for service providers documented as part of a mediated agreement. The total cost budgeted for NPA costs for 2015-16 is $976,123. These expenditures are commonly part of the special education opera- tional expenditures in most districts reviewed by FCMAT. The district contracts with NPAs for the provision of mental health and related services under AB 114. Districts may opt to contract out for these services or provide district staff. Either option is appropriate; however, the costs of services must be monitored annually for cost effectiveness. The total cost budgeted for mental health for 2015-16 is $5,090,468. The district has a process in Garden Grove Unified School diStrict 24 NONPUBLIC SCHOOLS/AGENCIES place to monitor the costs and expenditures of mental health services and can make adjustments to district-hired staff at a point that it is cost effective and programmatically effective. In addition, the district contracts with occupational therapists in lieu of district-hired staff. Each year the district analyzes costs to determine if it is more effective and efficient to provide district- staffed services. The total cost budgeted for 2015-16 is $638,027. The department finds that in 2015-16 it is more effective to continue contracting for this related service. FCMAT completed an independent review of the services provided, including frequency and duration, and concurs with the district finding. Recommendations The district should: 1. Continue to analyze program needs and nonpublic school enrollment to determine the feasibility of developing district programs. 2. Continue to analyze the use of nonpublic agencies for mental health services in lieu of a district-staffed model. 3. Continue to analyze the use of nonpublic agency providers for occupational therapy in lieu of a district-staffed model. Fiscal crisis & ManageMent assistance teaM 25 ORGANIZATIONAL STRUCTURE Organizational Structure FCMAT analyzed the administrative and clerical support structures of four single-district SELPAs of comparable size: Corona-Norco, Santa Ana, Long Beach and San Francisco. Data for size comparisons was taken from 2014-15 Dataquest, California Department of Education. The total number of special education students birth to age 22 was reported by district of residence. Single District by Comparable Size Enrollment 2014-15 Special Education Enrollment 2014-15 Long Beach 79,709 9,516 Santa Ana 56,815 6,763 San Francisco 58,414 6,752 Corona-Norco 53,739 6,397 Garden Grove 46,177 5,361 Source: Data Quest 2014-15 The districts provided information on both administrative and clerical support staffing. These positions were also available on the district website. Each district identifies positions differently. FCMAT reviewed the available job descriptions for administrative and clerical positions and combined some categories into like groups for purpose of this study only. All of the single districts in the sample have a dedicated SELPA director responsible for both the administration of the SELPA and the operation of district special education programs. Both Santa Ana and Garden Grove assistant superintendents/SELPA directors also have responsibilities for student services. As such, there are separate certificated and classified staffing supports for student services that are not included in this analysis. The district aligns with other comparable single-district SELPAs in the director/assistant director posi- tions with two positions. Garden Grove has 2.0 FTE principals at separate school sites that are not desig- nated in other SELPAs. The average number of program supervisors in comparable size districts is 5.0 FTE. Garden Grove exceeds the average by 8.0 additional positions. This is attributable to the additional 4.0 FTE program supervisor positions in the K-12 allocation of 9.0 FTE program supervisors. Other districts may have program specialists dedicated to the IBI program but not at the administrative level. Single District Administrative Position Comparison Average Administrative Position Garden Grove Corona-Norco Long Beach Santa Ana San Francisco SELPA SELPA Director/Assistant 1 1 1 1 1 1 Superintendent/Director Executive Director 1 1 Director, Assistant Director 2 1 2 1 2 2 Principal 2 0 4 IBI* Coordinator/Program Supervisor 3 6 3 8 5 9 K-12 Source: District organization charts 2016 (IBI program supervisors have primary responsibility for students with autism; the K-12 program supervisors have primary responsibility for all other disability areas) Garden Grove Unified School diStrict 26 ORGANIZATIONAL STRUCTURE FCMAT recommends some caution when using the comparative data in this sample because while it shows that the district exceeds the other comparable size districts in the number of program supervisors, Garden Grove does not have program specialists or teachers on special assignment supporting special education programs. Non-Administrative Support Positions for Special Education San Non-Administrative Support Positions Garden Grove Corona-Norco Long Beach Santa Ana Francisco Program Specialists 0 12 Did not Report 9 0 Teachers on Special Assignment 0 0 0 0 20 Source: District organization charts 2016 The district is understaffed in clerical support positions for special education compared to single-district SELPAs of comparable size. This comparison does not include an analysis of overlap responsibilities that some of the clerical positions may have in other departments. Since Long Beach did not respond to the district’s request for data on clerical support, the analysis was completed by comparing the district to Santa Ana, Corona-Norco, and San Francisco. Single-District Clerical Support Positions in Special Education Clerical Support Positions Garden Grove Santa Ana Corona-Norco San Francisco Long Beach Average SELPA Administrative Secretary 1 1 1 1 No Response 1 Secretary I, II, III 8 1 1 0 No Response 3 Senior Clerk 0 4 3 1 No Response 3 Clerk I, II 4 1 8 11 No Response 7 Data provided by the districts 2016 Recommendations The district should: 1. Re-examine the program supervisor positions to determine if more resources are needed in this area. 2. Review clerical support needs to determine if additional supports aligning to comparably sized single-district SELPAs are necessary. Fiscal crisis & ManageMent assistance teaM 27 RESPONSE TO INTERVENTION Response to Intervention In 2004, the reauthorization of the Individuals with Disabilities Act (IDEA 2004) provided support for models that included a response to scientific, research-based interventions. The law stated that these methods may be used as an alternative to the discrepancy model when identi- fying students with learning disabilities. IDEA 2014 also shifted research-based interventions from special education to general education, stressing that this method would no longer be limited to special education students, but would apply to all students. The law left each indi- vidual state to develop its own guidelines and regulations. Response to Intervention (RtI), which the California Department of Education (CDE) now refers to as Response to Instruction and Intervention (RtI2), provides districts with a method to drive educational decisions and measure academic growth. The CDE information further states: RtI2 is meant to communicate the full spectrum of instruction, from general core, to supple- mental or intensive, to meet the academic and behavioral needs of students. RtI2 integrates resources from general education, categorical programs, and special education through a compre- hensive system of core instruction and interventions to benefit every student. The CDE further states that RtI2 is used in the following three ways: 1. Prevention: All students are screened to determine their level of performance in relation to the grade-level benchmarks, standards, and potential indicators of academic and behavioral difficulties. Rather than wait for students to fail, schools provide research-based instruction within general education. 2. Intervention: Based on frequent progress monitoring, interventions are provided for general education students not progressing at a rate or level of achievement commen- surate with their peers. These students are selected to receive more intense interventions. 3. Component of specific learning disability (SLD) determination: The RtI2 approach can be one component of the SLD determination as addressed in the Individuals with Disabilities Education Act (IDEA) 2004 statute and regulations. The data from the RtI2 process may be used to demonstrate that a student has received research-based instruction and inter- ventions as part of the eligibility determination process. The CDE is in the process of further defining how RtI2 could be used in the eligibility process. Source: http://www.cde.ca.gov/sp/se/sr/documents/sldeligibltyrti2.pdf Determining Specific Learning Disability Using Response to Instruction and Intervention The district has a clearly defined student success team (SST) process consisting of three steps and outlined in the Procedural Handbook for Special Education. The process consists of Consultation, Formal Plan of Action, and Review for Potential Progress and Monitor Interventions. All forms have been updated in 2015 and are available to site teams on the district’s SharePoint Site for Special Education Services. The district’s SST process is clearly Garden Grove Unified School diStrict 28 RESPONSE TO INTERVENTION defined and represented visually in a flow chart for site-level teams. Although the district’s SST process is clearly described and information is readily available, interviews with staff indicate the process is not followed consistently across all sites. Instead, it varies by site and SST coordinator. This may result in a student being referred for assessment or evaluation for special education eligibility at one site but not another. Although the district uses a stipend to compensate teacher SST coordinators, the district’s procedural handbook clearly states the site administrator drives the SST process. The assistant superintendents of student services, elementary education, and secondary education should ensure that each site administrator and coordinator follows the district’s approved process. Student Services leadership should formulate a clear communication and follow-up plan utilizing technology and site SST coordinators to communicate district expectations to all staff. Step 3 of the district’s SST process includes the possible development of a 504 plan depending on the student’s progress and response to interventions or program supports. Staff interviews indi- cated the appropriate process and district-approved forms are used across sites. FCMAT found evidence that district and site-level 504 coordinators are trained in how to write and monitor student 504 plans. The district has contracted with a local law firm to train staff and support the full implementation of a comprehensive plan including updating the district’s 504 forms. The district requested FCMAT to review its implementation of Response to Intervention across the district. Although the district identifies a rigorous and supportive academic experience in the district’s Garden Grove Way Strategic Plan, it is not implementing a systemic approach to support RtI. Even though the SST process, as described above, is an important part of RtI, implementing a comprehensive RtI system can ensure all students are supported by defining a process of rigorous instruction, universal screening, timely interventions implemented consis- tently, progress monitoring, and targeted interventions for students not progressing commensu- rate with their peers. District staff indicated the district does not have a districtwide RtI system in place. Interviews also found staff confusing the SST process with RtI and little agreement on what, if any, universal screening tools are used for all students. FCMAT did find that DIBELS (Dynamic Indicators of Basic Early Literacy Skills) was used at most elementary sites and that elementary sites had access to intervention materials supported by the central office, but found no consistent evidence of universal screening tools at other levels or the expectation that sites use the approved intervention curriculum. “Implementation” is defined as a specified set of activities designed to put into practice an activity or program of known dimensions. According to this definition, implementation processes are purposeful and are described in sufficient detail such that inde- pendent observers can detect the presence and strength of the “specific set of activities” related to implementation (Implementation Research: A Synthesis of the Literature, 2005). FCMAT could not discern through interviews or evidence that the district has implemented a set of activities and or practices associated with RtI. Evidence at the district level indicating a district has implemented RtI would be governing policies outlining an RtI system supported by the district superintendent, specific RtI language in federal and state strategic plans, explicitly identified universal screening tools and interventions, and clearly defined district-level implementation teams. Evidence at the site level indicating implementation of RtI would be staff indicating knowledge of governing policies, school site decision trees and schedules, the use of screening tools, and understanding and participation on site-level implementation teams. Further indicators of implementation of an RtI system would Fiscal crisis & ManageMent assistance teaM 29 RESPONSE TO INTERVENTION be district and site organizational charts indicating district and site leaders responsible for the ongoing review and refinement of the RtI process. District-provided financial documents and staff interviews indicate the district is in year one of Positive Behavioral Interventions and Supports (PBIS) training with the Orange County Department of Education at four elementary schools, three intermediate schools, and two high schools. The district should continue supporting the nine schools implementing PBIS and evaluate the readiness of other schools before implementing PBIS. Considering the number of initiatives the district is implementing and preparing to implement, the leadership team should evaluate the readiness of the district before implementing RtI. The district can evaluate both school and district readiness to implement RtI and PBIS (or any effective innovation) with tools like the District Capacity Assessment available through the National Implementation Research Network (http://implementation.fpg.unc.edu/). Recommendations The district should: 1. Ensure site administrators utilize the SST process outlined in the Special Education Procedural Handbook and reinforce with online trainings to reach all site administrators and coordinators on the district’s SST process. 2. Continue with training and updating SST and 504 forms and outline a communication plan for any changes to the forms. 3. Develop online trainings to support any changes to old forms or imple- menting new forms. 4. Develop governing policies and regulations outlining the district’s Response to Intervention practice. 5. Include Response to Intervention practices in the district’s strategic plan and state and federal compliance plans. 6. Develop a communication plan to all stakeholders outlining what Response to Intervention is, how it will benefit all students, and how it will be imple- mented throughout the district. 7. Define and implement universal screenings for all elementary, middle and high school sites. 8. Assess site and district capacity to implement effective innovations using tools like the District Capacity Assessment. References: One System: Reforming Education to Serve ALL Students, Report of California’s Task Force on Special Education (2015) Implementation Research: A Synthesis of the Literature (Fixsen, Naoom, Blasé, Freidman & Wallace, 2005) National Implementation Research Network, University of South Florida National Implementation Research Network http://implementation.fpg.unc.edu/ Garden Grove Unified School diStrict 30 Fiscal crisis & ManageMent assistance teaM 31 IDENTIFICATION RATE Identification Rate The district’s K-22 identification rate of district of residence disabled students is 11.1%, which exceeds the statewide average of 10.1%. The cost of this overidentification is $774,015.43 for the 2015-16 school year. FCMAT compared the district percentage of special education students by disability to the statewide average percent by disability. This comparison found that the district’s speech or language impairment (SLI) identification rate is 22%, which exceeds the statewide average of 19% by 3%, and the district’s average of autism identification is 14%, which exceeds the statewide average of 12%. However, the district identifies 4% less than the statewide average of 43% in the area of specific learning disability and 1% less than the statewide average of 11% in the area of other health impaired. Although the district identifies fewer students in the area of specific learning disability compared to the statewide average, it exceeds the countywide average of 31% by 8%. Further analysis of the December CASEMIS data comparing 2014 to 2015 found the district had a 3% increase in specific learning disability identification. The preschool identification rate of district of residence students for speech or language impair- ment is 5%, which exceeds the statewide identification rate of 4%. The autism identification rate of 2% exceeds the statewide identification rate by 1%. Additional review of CASEMIS data found that overall district identification rates in 2015 increased by 2%, with the most notable increases in preschool and 5th grade. As overall district identification rates have increased by 2%, overall enrollment has declined by 2% for the same time period. Recommendations The district should: 1. Ensure Student Services instructional leaders share with K-6 and 7-12 instructional leaders all special education identification data to inform instructional decisions at the district and site levels. 2. Reduce the number of students identified as having specific learning disabili- ties by consistently implementing effective and timely academic interventions. Implementing effective academic interventions to reduce specific learning disability identification to the county average of 31% will bring the overall district identification rate to 10%. 3. Reduce speech or language impairment identification by offering pre-referral screening and intervention groups for young students demonstrating articula- tion concerns in kindergarten and first grade. Garden Grove Unified School diStrict 32 Fiscal crisis & ManageMent assistance teaM 33 FISCAL EFFICIENCIES Fiscal Efficiencies FCMAT was asked to determine the district’s general education fund contribution to special education and make recommendations for greater efficiency. Districts, including single-district SELPAs, have little control over federal and state special education revenues. California changed its funding model and distributes funds to SELPAs based on their member districts’ total average daily attendance (ADA), not on identified special education students as it was previously deter- mined. The reporting methods of districts, county offices, and SELPAs can vary. There is no consistent, uniform procedure or coding requirements for special education. Some districts include transpor- tation in their expenditures while others do not, and there are variations in how special education funds are allocated through a SELPA’s approved allocation plans. Therefore, it is not always possible to accurately compare a district’s general fund contribution to that of other districts. As a single-district SELPA, Garden Grove Unified School District is able to utilize all revenues received. Staff report that information shared between the administrative staff in the special education, business and human relations departments is inconsistent regarding special education staffing needs and budgets. Staff reports and documents illustrate that not one document is consistently used between the departments for staffing and budgeting. Maintenance of effort (MOE) is the federal statutory requirement that a district must spend the same amount of state and local money on special education each year, with some exceptions. In considering how to reduce the overall general fund contribution, the district is required to follow the guidelines in the MOE document (20 U.S.C.1413 (a)(2)(A)). The MOE document from the CDE lists the following as exceptions that allow the district to reduce the amount of state and local funds spent on special education: 1. The voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel, who are replaced by qualified, lower-salaried staff. 2. A decrease in the enrollment of children with disabilities. 3. 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 FAPE (free and appropriate public education) to the child has termi- nated; or c. No longer needs the program of special education. 4. The termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the construction of school facilities. Garden Grove Unified School diStrict 34 FISCAL EFFICIENCIES 2013-14 2014-15 2015-16 projected Total Costs 72,070,184.17 79,946,934.17 77,401,523.00 Contributions from 20,015,600.85 23,092,158.78 27,542,010.00 Unrestricted Percentage Contribution 27.7% 28.8% 35.6% Source: District Data Special Education Maintenance of Effort The district’s general fund contribution based on the MOE documents provided to FCMAT was $20,015,600, or 27.7%, in 2013-14 and $23,029,158, or 28.8%, in 2014-15. The district’s 2015-16 projection expenditures budget for special education is $77,401,523 based on the MOE document provided to FCMAT. The district’s general fund contribution is projected to be $27,542,010, which is 35.6% of the special education budget. The statewide average is 43%. Several factors affect a district’s general fund contribution, including revenue received to operate the programs and the expenditures for salaries, benefits, staffing and caseloads, NPS and NPA costs and transportation. Litigation can also increase a district’s general fund contribution. Documents show that in 2013-14 the salaries and benefits were $51,023,370.93, whereas it is projected the salaries and benefits for 2015-16 will be $61,523,057.00, a difference of $10,499,686.07 over three years. The Local Control Funding Formula (LCFF) was enacted with the passage of the 2013-14 Budget Act, replacing the previous K-12 finance system with a new funding formula. The new formula for school districts and charter schools is composed of uniform base grants by grade spans (K-3, 4-6, 7-8, 9-12) and includes additional funding for targeted students. Under the previous K-12 finance system there was a revenue limit special education ADA transfer that transferred revenue limit ADA funding generated from the attendance in the SDCs from the unrestricted general fund to the special education program. This ADA is no longer reported separately, and the CDE determined that this transfer will no longer take place due to the LCFF. The implementation of the LCFF has automatically increased many districts’ general fund contri- bution to special education because of this accounting change. Effective in 2013-14, special education transportation revenue was folded in to the LCFF. Now that it is part of the LCFF, it is no longer restricted special education revenue. This change in accounting has increased many districts’ general fund contribution to special education. The table below compares the revenue the district receives from both state and federal resources. The special education revenue data provided to FCMAT was posted to the district’s special education program in its financial system. Since 2013-14 the district’s revenue received to operate special education programs has increased by $1,019,150. Fiscal crisis & ManageMent assistance teaM 35 FISCAL EFFICIENCIES Special Education Revenues from 2013-14 to Projected 2015-16 Projected Difference from 2013-14 Description 2013-14 2014-15 2015-16 to Projected 2015-16 IDEA Entitlement $7,566,342.38 $7,900,917.23 $7,935,573.00 +$369,230.62 IDEA: Local Assistance $34,776.62 $34,655.77 - -$34,776.62 IDEA Preschool Grant $153,242.00 $144,123.00 $144,123.00 -$9,119.00 IDEA Preschool Local $302,042.00 $315,332.00 $315,332.00 +$13,290.00 Entitlement, Part B IDEA Mental Health $531,860.00 $514,433.00 $516,380.00 -$15,480 IDEA Preschool Staff $2,917.00 $2,804.00 $2,655.00 -$262.00 Development Part B IDEA Early Intervention Grants $110,635.00 $110,635.00 $110,635.00 $0 Alternative Dispute Resolution - - $21,097.00 +$21,097.00 Now is The Time (NITT) - $96,878.06 $456,830.00 +$456,830.00 Special Education $24,171,444.00 $25,021,514.00 $24,424,690.00 +$253,246.00 Special Education: Mental Health $2,694,642.00 $2,672,011.00 $2,708,450.00 +$13,808 Services Special Education: State $16,169.00 - - -$16,169 Preschool Grant Special Education: Infant Fund $7,632.00 $6,239.00 $878.00 -$6,754 Special Education: WorkAbility $199,872.00 $186,945.00 $186,945.00 -$12,927 Special Education: Low Incidence $12,864.00 ($12,864.00) - -$12,864 Entitlement Total Revenues $35,804,438.00 $36,993,623.06 $36,823,588.00 $1,019,150 School districts throughout the state face a continuing challenge in funding the costs for serving special education students. Districts are faced with mounting increases in the differences between the federal and state governments’ funding and the mandated costs for these vital student services. The table below compares the district’s special education program expenditures. The special education expenditure data is based on the MOE documents provided to FCMAT. Since 2013-14 the district’s expenditures to operate special education programs have increased by $14,247,736.31. The general fund contribution projected for 2015-16 is $27,542,010.00. Special Education Expenditures from 2013-14 to Projected 2015-16 Projected Difference from 2013-14 Description 2013-14 2014-15 2015-16 to Projected 2015-16 Certificated Salaries $27,094,824.44 $29,139,970.73 $33,281,680.00 +$6,186,855.56 Classified Salaries $11,153,450.46 $13,013,294.98 $14,951,458.00 +$3,798,007.54 Benefits $12,775,096.03 $15,314,407.43 $13,289,919.00 +$514,822.97 Books and Supplies $257,721.65 $385,903.41 $335,224.00 +$77,502.35 Contracts and Operating Expenses $10,135,914.66 $10,907,048.52 $12,983,215.00 +$2,847,300.34 Capital Outlay $2,644.45 $29,619.94 - -$2,644.45 State Special Schools $9,135.00 $5,510.00 $35,000.00 +$25,865 Subtotal, Direct Costs $61,428,786.69 $68,795,755.01 $74,876,496.00 +$13,447,709.31 Transfer Indirect Charges $1,725,000.00 $1,900,085.73 $2,525,027.00 +$800,027.00 Total Expenditures $63,153,786.69 $70,695,840.74 $77,401,523.00 +$14,247,736.31 *Does not includes Program Cost Report Allowance Garden Grove Unified School diStrict 36 FISCAL EFFICIENCIES The table below compares the district’s December 1 identified special education pupil count and the expenditures per identified pupil count. Since 2013-14 the district’s identified special educa- tion pupil count has increased by 86 pupils and the expenditures per identified special education pupil have increased by $2,500.83. No method is in place to communicate the needs of students and the cost of student support. Likewise, when there is a change in the identification of students in special education, there is no mechanism to assess and determine levels of staffing warranted. Difference from 2013-14 to projected Description 2013-14 2014-15 2015-16 2015-16 December 1 Identified 5,193 5,182 5,279 +86 Pupil Count Birth-22 Years of Age Expenditures per Pupil $12,161.33 $13,642.58 $14,662.16 +$2,500.83 per pupil Staff reported that communication and budget transparency is a concern. Special education administrators do not know how much the special education budget is or what and who is being charged to special education. Staff report that the budget is rolled from one year to the next, and they do not review the effective use of the resources available. There is no ownership or accountability for the special education budget. The special education, business services and the human resources departments do not meet regularly. Each department should build and propose its 2016-17 budget, including staffing. The special education, business, and human resources departments should review all staffing and assignments through this process. Staff should review how employees are utilized and how they are charged to the district budget. Adjusting the coding for any staff that provide services to both identified and nonidentified pupils will not reduce the total budget but will ensure that the special education budget is accurate. Recommendations The district should: 1. Monitor the district’s general fund contribution through the annual MOE and determine if expenditures can be reduced using any of the exemptions allowed. 2. Establish monthly meetings with the SELPA director, special education director and the assistant superintendent of business services and human resource department that include the following topics: a. Budget development b. Budget monitoring c. Maintenance of effort requirements d. Additional staff requests or change in assignments e. Nonpublic school and/or agency contracts and invoices and new placements f. Due process or complaint issues Fiscal crisis & ManageMent assistance teaM 37 FISCAL EFFICIENCIES g. Staff caseload h. Identified student counts i. Identified needs 3. Implement zero-based budgeting. 4. Develop a single document to use for staffing in the special education, busi- ness and human resource departments to include but not limited to: a. Name b. Position c. Position control d. Location of placement e. Number of hours f. Resource/coding g. FTE h. Salary and benefits i. Caseload or assignment j. Date of hire k. Credential(s) held Garden Grove Unified School diStrict 38 Fiscal crisis & ManageMent assistance teaM 3399 APPENDDRICAEFST Appendices Appendix A Study Agreement Garden Grove Unified School diStrict 4400 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4411 APPENDDRICAEFST Garden Grove Unified School diStrict 4422 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4433 APPENDDRICAEFST Garden Grove Unified School diStrict 4444 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4455 APPENDDRICAEFST Garden Grove Unified School diStrict 4466 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM