FCMAT
Soquel Elementary School District Report
special education and special education local plan area (SELPA) review
Read the report at Soquel Elementary School District ↗
Soquel Elementary
School District
Special Education Review
Regarding the
North Santa Cruz County SELPA
May 26, 2010
Joel D. Montero
Chief Executive Officer
May 26, 2010
Kathleen Howard, Superintendent
Soquel Union Elementary School District
620 Monterey Avenue
Capitola, CA95010
Dear Superintendent Howard:
In February 2010, the Soquel Union Elementary School District entered into an agreement with the
Fiscal Crisis and Management Assistance Team (FCMAT) for a special education review regarding the
North Santa Cruz County SELPA.
FCMAT’s study agreement with the district specifies that FCMAT will perform the following:
1. SELPA
A. Review allocation funding model and compare with other comparable SELPAs and
make recommendations, if necessary to improve equitable allocations to all involved.
B. Review governance structure of SELPA and make recommendations for improving com-
munication, transparency and improved decision making.
C. Review regionalized dollars and they are disseminated.
D. Review role and responsibilities of program specialists, how they are assigned. Make rec-
ommendations on how to improve and maximize program specialist dollars and services.
E. Review how districts operate collaboratively within the SELPA with regards to accessing
resources and support.
F. Review how staff development is provided to district staff on an equal basis throughout the county.
G. Review SELPA policies to assure they are current and consistent with federal and state laws.
This report details the study team’s findings and recommendations. Thank you for allowing us to
serve you, and please give our regards to all the employees of the Soquel Union Elementary School
District and the members of the North Santa Cruz County SELPA.
Sincerely,
Joel D. Montero
Chief Executive Officer
FCMAT
Joel D. Montero, Chief Executive Officer
. .
1300 17th Street - CITY CENTRE, Bakersfield, CA 93
.
301-4533 Telephone 661-6
.
36-4611 Fax 661-63
.
6-4647
422 Petaluma Blvd North, Suite. C, Petaluma, CA 94952 Telephone: 707-775-2850 Fax: 707-775-2854 www.fcmat.org
Administrative Agent: Christine L. Frazier - Office of Kern County Superintendent of Schools
4 Fiscal Crisis & Management Assistance Team
Table of Contents
Foreword .............................................................. 3
Introduction ......................................................... 5
Executive Summary ............................................ 9
Findings and Recommendations .................... 11
Allocation Funding Model..................................................11
Regional Programs ..............................................................23
Alternative Funding Models ...............................................25
SELPA Governance Services ..............................................29
Regionalized Dollars/Program Specialists ........................35
District Collaboration ..........................................................37
SELPA Policies .......................................................................43
Staffing and Caseloads ......................................................47
County Office and Regional Program Staffing ................49
One-to-One Instructional Aides ........................................53
Nonpublic Schools/Agencies ...............................................55
Transfer of Programs ............................................................57
Transportation ......................................................................61
Appendices ....................................................... 67
Soquel Elementary School District 1
2 Fiscal Crisis & Management Assistance Team
FOREWORD
Study Agreements by Fiscal Year
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
Projected
Soquel Elementary School District 3
seidutS
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Foreword - FCMAT Background
The Fiscal Crisis and Management Assistance Team (FCMAT) was created by legislation in
accordance with Assembly Bill 1200 in 1992 as a service to assist local educational agencies
(LEAs) in complying with fiscal accountability standards.
AB 1200 was established from a need to ensure that LEAs throughout California were ade-
quately prepared to meet and sustain their financial obligations. AB 1200 is also a statewide plan
for county offices of education and school districts to work together on a local level to improve
fiscal procedures and accountability standards. The legislation expanded the role of the county
office in monitoring school districts under certain fiscal constraints to ensure these districts could
meet their financial commitments on a multiyear basis. AB 2756 provides specific responsibili-
ties to FCMAT with regard to districts that have received emergency state loans. These include
comprehensive assessments in five major operational areas and periodic reports that identify the
district’s progress on the improvement plans.
In January 2006, SB 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 nearly 750 reviews for local educational
agencies, including school districts, county offices of education, charter schools and community
colleges. Services range from fiscal crisis intervention to management review and assistance.
FCMAT also provides professional development training. The Kern County Superintendent of
Schools is the administrative agent for FCMAT. The agency is guided under the leadership of
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.
Total Number of Studies....................743
Total Number of Districts in CA ........1,050
Management Assistance.............................705 (94.886%)
Fiscal Crisis/Emergency ................................38 (5.114%)
Note: Some districts had multiple studies.
Eight (8) districts have received emergency loans from the state.
(Rev. 12/8/09)
FOREWORD
4 Fiscal Crisis & Management Assistance Team
INTRODUCTION
Introduction
Background
Located in the city of Capitola, the North Santa Cruz County Special Education Local Plan
Area (SELPA) works with school districts and other public agencies in Santa Cruz County to
provide a full range of special education services.
The SELPA is composed of 13 local educational agencies (LEAs) including one high school dis-
trict, two unified school districts, seven elementary school districts, two charter schools and the
Santa Cruz County Office of Education. The SELPA operates under a joint powers agreement
that establishes the Special Education Coordinating Agency (SECA) Governing Council as the
administrative body.
In February 2010, the SELPA requested that FCMAT assist the district by reviewing district
and county special education programs and services. The state fiscal crisis has raised concerns
among SELPA members about the excess costs of special education programs for districts and the
county office. Districts are concerned about a lack of openness and misunderstandings regard-
ing the SELPA funding allocation plan from the SELPA. The study agreement specifies that
FCMAT will perform the following:
1. SELPA
A. Review the allocation funding model and compare with other comparable
SELPAs and make recommendations, if necessary to improve equitable
allocations to all involved.
B. Review the governance structure of SELPA and make recommendations for
improving communication, transparency and improved decision-making.
C. Review regionalized dollars and how they are disseminated.
D. Review role and responsibilities of program specialists, how they are
assigned. Make recommendations on how to improve and maximize
program specialist dollars and services.
E. Review how districts operate collaboratively in the SELPA with regards to
accessing resources and support.
F. Review how staff development is provided to district staff on an equal basis
throughout the county.
G. Review the SELPA polices to assure they are current and consistent with
federal and state laws.
2. Review staffing and caseloads of programs and make recommendations on efficiency.
Review all COE programs, and random sample of some district programs.
3. Review the one-to-one aide policy, procedures and staffing ratios and determine whether
process is effective and make recommendations to improve efficiency and effective use of
assigned aides to special education.
Soquel Elementary School District 5
INTRODUCTION
4. Review NPS and NPA placements and make recommendations for improving process
for placement.
5. Review COE operated programs and determines whether some programs would be
more cost effective if operated by districts. Determine capacity of districts to operated
additional programs (such as facilities, staffing etc)
6. Provide comprehensive transportation review of special education transportation delivery
system.
Study Team
The study team was composed of the following members:
William P. Gillaspie, Ed.D JoAnn Murphy
FCMAT Chief Management Analyst FCMAT Consultant
Sacramento, CA Santee, CA
Leonel Martínez Trina Frazier*
FCMAT Public Information Specialist Administrator
Bakersfield, CA Fresno County SELPA
Fresno, CA
James “Sarge” Kennedy
FCMAT Consultant Timothy W. Purvis*
Red Bluff, CA Director, Transportation
Poway Unified School District
Michael G. Rea* Poway, CA
Executive Director
West County Transportation Agency
Santa Rosa, CA
*As members of this study team, these consultants were not representing their respective
employers but were working solely as independent contractors for FCMAT.
Study Guidelines
FCMAT visited the North Santa Cruz County SELPA March 15-18, 2010 to conduct interviews,
collect data and review documents. This report is the result of those activities and is divided into
the following sections:
I. Executive Summary
II. Allocation Funding Model
III. Regional Programs
IV. Alternative Funding Models
V. SELPA Governance Structure
VI. Regionalized Dollars/Program Specialists
VII. District Collaboration
6 Fiscal Crisis & Management Assistance Team
INTRODUCTION
VIII. Staff Development
IX. SELPA Policies
X. Staffing and Caseloads
XI. One-to-One Instructional Aides
XII. Nonpublic Schools/Agencies
XIII. Transfer of Programs
XIV. Transportation
Soquel Elementary School District 7
INTRODUCTION
8 Fiscal Crisis & Management Assistance Team
EXECUTIVE SUMMARY
Executive Summary
The North Santa Cruz County SELPA requested that the Fiscal Crisis and Management
Assistance Team (FCMAT) provide a comprehensive study of the SELPA and county office pro-
grams and services for students with disabilities. During the team’s interviews on site, the super-
intendent, SELPA director, county office staff, members of the Special Education Coordinating
Agency Governing Council, and parents provided information and perspective on all aspects of
programs and services these students.
In January 1974, the California State Board of Education adopted the The funding
California Master Plan for Special Education to help develop an equitable
model includes
funding model for special education services. The study reviewed in detail
some inequity,
each guiding principle adopted in the California Master Plan for Special
Education, which provides the foundation for the SELPA. FCMAT found and a wide
that there is a prevailing stance among SELPA members that students with
variance suggests
severe disabilities should not attend regular school sites. This is contrary to
that the
the guiding principle that supports joint ownership and responsibility for
all students that live in the SELPA. allocation of state
The funding model includes some inequities, and a wide variance among support funds
participating agencies suggests that the allocation of state support funds may not be fair
may not be fair and equitable. This conflicts with the guiding principle that
and equitable.
no SELPA members accrue undue benefit at the expense of other members.
These types of funding inequities are further compounded by a lack of
openness and effective communication. This has diminished trust between the SELPA and its
district and county office members.
The SELPA combines the fee-for-service model with one that funds the costs of regional
programs before distributing resources to local educational agencies, sometimes known as “off-
the-top” funding. Given SELPA demographics, the current funding model is the most effective
possible. The SELPA should use the current allocation model to implement greater protections
for members.
The SELPA operates under a joint powers agreement that establishes the Special Education
Coordinating Agency (SECA) Governing Council as the administrative body. FCMAT heard
numerous reports of frustration over the lack of communication in the governance structure.
This lack is prevalent among members of governing council, Special Education Council and chief
business officials. Further, program and business members do not work collaboratively, hindering
decision-making.
The SELPA has lacked consistent leadership for five years because of a high turnover of interim
SELPA directors and the fact that the position was reduced to part-time status. This resulted in a
series of inconsistent communications and articulation with SELPA members.
The current SELPA budget does not provide regionalized service dollars for program-specialist
services to districts. The districts indicated they need support, particularly with problematic
Individual Education Program (IEP) meetings. The governing council should determine whether
program specialist support to districts should be provided.
FCMAT reviewed the staffing of special education programs at the Santa Cruz County Office
of Education and a random sample of district programs. Some districts perceive that while they
are making significant reductions in special education staffing, the county office is not making
Soquel Elementary School District 9
EXECUTIVE SUMMARY
the same staffing reductions on a proportionate basis. Districts are mainly concerned with what
they perceive as high support ratios in county office classrooms and high administrative ratios.
FCMAT recommends a review and reduction in administrative staffing and program support.
District and county office programs increasingly use one-to-one instructional aides for students
at all levels of programming. There is no industry standard to determine whether SELPA usage
exceeds the standard of practice. The SELPA has administrative procedures for establishing
the need for one-to-one aides; however, they are not used consistently. FCMAT found that the
procedures lack clear guidelines on building independence and transitioning (“fading”) from the
need for one-to-one support.
Six of the 13 local education agencies in the SELPA, including the county office, provide or con-
tract for transportation service. However, these transportation programs operate independently
of one another. The districts should explore ways to jointly provide services, stabilizing trans-
portation costs. Communication between SELPA members regarding transportation services
is inefficient and lacks openness. For example, the lack of a common calendar for county office
programs and individual school districts exposes individual districts to increased costs. This is
further complicated by the inability to stagger start and dismissal times for programs, which
would increase efficiency and reduce program costs.
Compared to five other county offices, the Santa Cruz County Office of Education costs for edu-
cation students with severe disabilities are normal. Districts should analyze the comparative data
from these county offices to determine the effectiveness of program transfers. Districts should
also build the appropriate infrastructures and provide teachers with training to ensure successful
transition of severely handicapped programs.
10 Fiscal Crisis & Management Assistance Team
ALLOCATION FUNDING MODEL
Findings and Recommendations
Allocation Funding Model
In January 1974, the California State Board of Education adopted the California Master Plan for
Special Education. While much has changed over the last 34 years, the underlying purpose of
the fiscal model remains intact and provides excellent guidance. The objectives essential to build-
ing an equitable funding plan for special education are as follows:
1. Provide adequate resources to assure equality of
educational opportunity for all individuals with In defining a funding
exceptional needs. allocation model,
2. Provide levels of support for special education programs
Special Education Local
which will promote programs and services of equal
Plan Areas (SELPAs)
quality.
should remember that
3. Provide encouragement for the development of
comprehensive programs. these resources are not
4. Promote both program and fiscal accountability.
intended to fully fund
5. Clarify fiscal relationships between state, county, and
the costs of providing
district.
6. Ensure equity in support levels among various program special education
components. programs and services.
7. Provide adjustments in support levels to reflect changing
costs.
8. Provide support based on needs of pupils enrolled in special education-funding
based on specified programs and services rather than on categorical disability
groupings.
9. Ensure that reporting and auditing policies and procedures are meaningful for
evaluation and program development.
10. Provide methods for monitoring and evaluating quality control in special
education.
Source: California Master Plan for Special Education, California State Board of Education,
Jan. 10, 1974, Pages 36-37. Emphasis added.
The three objectives highlighted in bold are particularly relevant. In defining a funding alloca-
tion model, Special Education Local Plan Areas (SELPAs) should remember that these resources
are not intended to fully fund the costs of providing special education programs and services. The
four sources for funding special education programs and services are as follows:
• Local support from the general unrestricted funds of school districts.
• Revenues from local property taxes levied for special education programs and
services.
• State aid from Part 30 of the California Education Code, commencing at section 56000.
• Federal local assistance from the Individuals with Disabilities Education Act
Soquel Elementary School District 11
ALLOCATION FUNDING MODEL
Part 30 of the Education Code provides for state aid, and the Individuals with Disabilities
Education Act (IDEA) provides for federal local assistance. IDEA and state monitoring place
the responsibility for providing special education services on the district of residence. When
defining a funding allocation model, a SELPA should therefore remember that it is allocating
funds intended to equitably ease the financial burden on districts, not to fully fund the costs of
providing special education programs and services. The primary responsibility for funding these
programs and services belongs to LEAs.
The key to an equitable funding model is understanding the relationship between the level of
funding allocated and the relative cost to each entity of providing similar services. The average
rate of total expenditure per student and the average level of local contribution per student will
reflect this information. A local contribution that is absent or low could suggest an overallocation
of state and federal resources. Conversely, a high local contribution could suggest that state and
federal resources have been underallocated.
Given the intent of state and federal policy makers in providing these funds, mitigation of the
fiscal burden should be considered in terms of equity rather than equality, and might include
factors such as the following:
• Providing special education services in the least-restrictive environment (LRE).
• Responsiveness to changing demographics and service needs.
• Consideration of geographic and demographic factors that could adversely affect the
costs of providing very similar services among the school districts
• Determining who will have primary responsibility for providing programs and services,
based on the disability and the intensity of services required.
• Establishing cost factors for various disabling conditions based on their service needs.
• Considering factors such as socioeconomic and bilingual/bicultural populations that may
contribute to higher special education costs.
• Comparing the cost effectiveness of alternative strategies.
Closely monitoring funding equity will help align the fiscal model with the uses intended for
state and federal funds. The focus will be on alleviating the impact of excess costs based on fac-
tors that may increase those costs.
A primary focus of this study is the degree to which the allocation model meets these guiding
principles, the adequacy of the allocation model, and recommendations for changes that could
address the concerns of SELPA members.
The SELPA model for allocating state and federal fiscal resources is predicated on the following
guiding principles:
Guiding Principle One
SELPA members agree that all children with exceptional needs residing in this SELPA
should be appropriately served.
The SELPA member districts generally agree with this principle. However, some districts believe
that disabled children should not attend regular schools, particularly those with severe dis-
abilities. Others perceive that they have little or no responsibility for disabled students attending
programs operated on regular school sites by the county office.
12 Fiscal Crisis & Management Assistance Team
ALLOCATION FUNDING MODEL
The SELPA should include in the first principle a statement that all SELPA members are jointly
responsible for all disabled students that live in the SELPA. This principle should also state that
students with disabilities are legally required to have equal access to the services and programs
they require regardless of their location in the SELPA.
The following is a prototype developed from the guiding principles of several other SELPAs:
It is incumbent on each LEA member and its respective staff to take ownership of the
responsibility to ensure a free and appropriate education for each special education
pupil residing in the geographical boundaries of the SELPA. This responsibility shall be
met by direct provision of services, establishing an agreement with another public edu-
cation agency, or contracting with nonpublic school and agencies. The allocation plan
for distribution of resources must recognize the collective and individual responsibility
for all children in the SELPA while addressing the need to equitably share resources
among the districts and county office of education.
The intent of this principle is not fully demonstrated throughout the SELPA.
Recommendations
The SELPA should:
1. Consider revising the guiding principle’s wording to include language that supports joint
ownership and responsibility on the part of all SELPA members for all students with dis-
abilities residing in the SELPA
2. Consider conducting disability awareness activities throughout the SELPA annually to
help staff and students understand the nature and effects of various disabilities.
Guiding Principle Two
In order to deliver appropriate services to all students, the SELPA members believe in
everyone working together as a team for the good of all. The cooperation of the business
offices and program departments is critical. Where appropriate and cost effective to do
so, efforts will be made to operate services in a SELPA-wide coordinated fashion.
Based on interviews with a variety of program and business staff, a close collaboration between
program and business representatives does not function as intended by this principle.
The SELPA assigned an AB602 committee to implement this principle. While the AB602
meetings were intended to involve both program and business personnel in the discussion of
programmatic needs and provide the Special Education Coordinating Agency (SECA) with
recommendations, there have been very few recent meetings.
The SELPA should have an operations oversight committee composed of key program and busi-
ness staff members so issues can be fully explored and discussed. The recent decision regarding
the use of American Recovery and Reinvestment Act (ARRA) funds to expand the autism
program would have greatly benefited from committee review. If program and business staff
members have not thoroughly vetted programmatic issues before they are presented to SECA for
action, the result can be long-term fiscal commitments.
Soquel Elementary School District 13
ALLOCATION FUNDING MODEL
Recommendation
The SELPA should:
1. Consider reactivating the AB602 committee as an operations oversight body that helps
develop regional program budgets, reviews proposals before they are submitted to SECA
for action, and provides SECA with the advantages and disadvantages of a proposal from
the programmatic and fiscal perspectives.
Guiding Principle Three
Fairness and equity shall be the basis of the development of this Funding Allocation Plan.
Staff members expressed concern about the equitability of the funding model. While equity and
fairness are often based on whether an equal amount of revenue is allocated to each member, a
more accurate measure is the level of SELPA support of the special education services required by
each local education agency (LEA) member.
A review of information included in the maintenance-of-effort (MOE) documents indicates that the
funding model has some inequity. There is considerable disparity among SELPA members regarding
the percentage of expenditures from combined state and local funds, represented by expenditures from
local-only funds. This suggests that some members may receive an inequitable share of AB602 funds.
Using MOE data for the 2008-09 school year, the level of local support requirements shows considerable
variance among members regarding the proportion of total special education expenditures and combined
state and local expenditures that derive from local support funds. The following table ranks the members
based on the percentage of combined state and local expenditures represented by local funds:
Ranking of Members Based on the Percentage of Combined State and Local Expenditures
Represented by Local Funds
District Local as % of Total Expenditure Local as % of State/Local Expenditure
Bonny Doon 79.50% 83.37%
Santa Cruz City Schools 65.07% 75.51%
Scotts Valley 66.31% 74.09%
Live Oak 51.10% 58.97%
Soquel 50.32% 57.77%
Pacific 49.30% 55.12%
San Lorenzo Valley 40.20% 46.37%
Delta 37.01% 37.01%
Mountain 26.57% 30.36%
Happy Valley 25.66% 28.52%
Pacific Collegiate Charter 0.00% 0.00%
NSCCO Composite 45.01% 50.16%
This wide variance indicates that the allocation of state support funds may not be fair and equi-
table for all participating agencies. However, further analysis is suggested to determine whether
this is a result of external factors such as demographics, geography, or socioeconomic indicators
or internal differences such as salary rates, benefit agreements, or staffing ratios. The current
allocation model may not sufficiently consider factors that cause some districts to provide signifi-
cantly greater funding contribution from their own internal funds than other districts.
14 Fiscal Crisis & Management Assistance Team
ALLOCATION FUNDING MODEL
Recommendation
The SELPA should:
1. Assign a committee such as the operations oversight committee to review the expendi-
ture budgets of districts showing higher levels of support from local funds. This review
should help determine whether the factors affecting that support are external such as
demography, geography, socioeconomic indicators, (or language issues) or internal dif-
ferences that the stem from decisions made by the district regarding salaries, programs,
benefits and staffing. Exceptions to the allocation model should be developed to address
identified external factors.
Guiding Principle Four
Federal and state revenues will flow directly from the state to the SELPA
Administrative Unit, which is currently the Soquel USD. The administrative Unit will
allocate the funds to SELPA members according to this Funding Allocation Plan.
This principle is being followed in accordance with the plan. While it may not be practical, the
SELPA could elect to inform the California Department of Education (CDE) of the percent-
age of AB 602 revenue each entity is to receive and have the state funding sent directly to the
district.
Recommendation
The SELPA should:
1. Refer only to the SELPA administrative unit and not specifically to the current provider
of that service.
Guiding Principle Five
SELPA member districts will retain their own decision making on how to use
their funds in serving special education students based on needs outlined in their
Individualized Education Program (IEP).
This principle raises some concern because it suggests that funds received through the allocation
model are the property of the receiving LEA, and other SELPA members have little or no say
regarding how these funds are implemented. Since the SELPA is a JPA, the concept that the state
and federal funding is communal funding suggests a different perspective.
This principle emphasizes ownership and sovereignty of state and federal resources provided
to help offset the excess costs associated with providing special education services for disabled
students.
Recommendation
The SELPA should:
1. Consider adopting language that emphasizes the communal nature of the funding. The
following prototypes found in the guiding principles of other SELPAs may provide some
guidance::
Soquel Elementary School District 15
ALLOCATION FUNDING MODEL
It should be kept in mind that these are “communal monies” intended to assist in
paying the excess costs of providing special education services and are not the “private
property” of the recipient. Each member has a legitimate stake in the equitability of
the allocations and in how cost-effectively other members use the resources.
The guiding principle should be that no member receives undue benefit at the expense of
other members. The allocation model must be fair, equitable, and understandable to all
members.
Guiding Principle Six
This Funding Allocation Plan will be kept as simple as possible and yet be flexible and
useful in serving special education students.
While the allocation model can be described as simple and flexible, it is not well understood by
most program and business staff members. Its simplicity may limit its flexibility.
Insufficient source information on the part of the SELPA members and the primary regional
program providers results in confusion and distrust.
The allocation model funds the costs of regional programs before distributing the funding to
local education agencies, often known as the “off-the-top” approach.” This funding is based on
calculated fees for service. The SELPA’s method is to calculate each district’s share of the total
revenue based on its K-12 enrollment.
The total costs of the regional programs are divided in two equal amounts for each program.
One amount is funded by a deduction from each local education agency’s share of the revenue
based on the respective K-12 enrollments. This funds half the cost of regional programs by pro-
rating them over all SELPA members.
The other amount is funded by a deduction from each local education agency’s share of the
revenue based on the number of students that the agency has enrolled in the regional programs.
This funds the other half of the cost of regional programs based on participation.
Interviews with superintendents, special education administrators, and business personnel
from several districts indicate they are more concerned about understanding how county office
regionalized programs costs are funded than about the allocation model. Although Santa Cruz
City Schools operates two regional programs, no one expressed concern about the costs of those
programs.
The model for providing this information and the relevant presentation forms are included in the
procedural section of the allocation model, but the procedure is not followed.
Recommendations
The SELPA should:
1. Ensure that regional program operators clearly present the costs of the program so that
other SELPA members can fully understand this issue.
A suggested format is included in the allocation model and should minimally include the
following:
• A list of staff members, individual full-time equivalencies, individual salaries
and individual benefits costs by job classification
16 Fiscal Crisis & Management Assistance Team
ALLOCATION FUNDING MODEL
• Nonsalary and nonbenefit costs by object code
• Allocated support costs listed by type of support
• Calculation of indirect costs
2. List revenue by description type. All revenue streams should be included, especially those
allocated from sources beyond restricted special education funds.
3. Consider requesting that the governance council approve a format that could be used to
calculate what the actual cost per pupil was in 2008-09, apply it to the current year, and
use it to project 2010-11 effects.
Guiding Principle Seven
The distribution of funding will be understandable, predictable, and timely.
Interviews with LEA staff members indicate that the allocation model has not met the standard
expressed by this principle. Business and program staff members repeatedly stated they do not
understand the model.
The resources are allocated based on each district’s proportionate share of the total ADA in the
SELPA. Once allocated, they are reduced to fund regional programs. The lack of understanding
focuses on what constitutes funding for regional programs. A presentation on this topic by the
county office internal business staff could increase comprehension.
The SELPA fiscal analyst should not be a co-presenter for this information. The analyst’s role
should be to interpret for the SELPA members how these costs will affect them and estimate any
alternatives to regional services.
Recommendation
The SELPA should:
1. Ensure that the regional program operators clearly present the costs of the program
so other SELPA members clearly understand this issue. The information should be
developed with the inclusion of an operations oversight committee and presented by
the regional program manager and an internal business staff member from the agency
providing the information; however, the SELPA fiscal should not be responsible for
presenting this information to SELPA members.
2. Assign the SELPA fiscal analyst to present the effects of the information on the SELPA
members and suggest variances that might mitigate those effects.
Guiding Principle Eight
SELPA members will commit to timely reporting and analysis of all relevant data
necessary for the allocation and distribution of funds.
Data is often not received within the time lines. Further, the quality of the data analysis varies
based on the clarity of the information presented. This principle is not being followed by all
SELPA members.
Soquel Elementary School District 17
ALLOCATION FUNDING MODEL
Recommendation
The SELPA should:
1. Ensure that SELPA members commit to timely reporting and analysis of all relevant
data and information. This material should clearly show the basis and implications of the
information on allocation and distribution of funds.
Guiding Principle Nine
This Funding Allocation Plan will be in legal compliance with federal and state laws.
There are no specific state or federal laws governing the local plan for the allocation of state and
federal funds other than those requiring SELPAS to have a plan. Without any specific restriction,
the funding allocation plan complies with this principle and is being followed by all SELPA
members.
Recommendation
The SELPA should:
1. Continue following its funding allocation plan practices to maintain compliance with
federal and state laws.
Guiding Principle 10
Disputes regarding this Funding Allocation Plan will be resolved at the lowest level
possible with final appeal to SECA.
FCMAT was not made aware of any specific disputes regarding the implementation of the fund-
ing allocation plan that required resolution.
Recommendation
The SELPA should:
1. Continue the practice of resolving disputes at the lowest level possible.
Guiding Principle 11
Provide technical assistance and program support to districts to ensure effective service
delivery to students and families by SELPA, COE or districts.
As regionalized services declined, the capability of all entities to provide such technical assistance
suffered. This guiding principal should be removed from the list as it focuses on programmatic
support and not the allocation of fiscal resources.
Recommendation
The SELPA should:
1. Consider removing this principle from the guiding principles
18 Fiscal Crisis & Management Assistance Team
ALLOCATION FUNDING MODEL
Guiding Principle 12
Provide an incentive for districts not to overidentify students for special education services.
The funding allocation plan has no specific elements that serve as an incentive for providing cost-
effective programs.
Regarding the provision of an emergency pool from which direct-service districts may seek assis-
tance for new placements in a certified nonpublic school, there is no incentive to place students
in a nonpublic school. The inability to draw resources from this pool for ongoing placements
serves as an incentive to provide public school alternatives to nonpublic schools.
Basing 50 percent of the support for regional programs on participation provides an incentive for
school districts to develop more cost-effective alternatives. As a result, the allocation model does
not appear to have any specific incentives or disincentive for providing cost-effective programs.
Recommendation
The SELPA should:
1. Consider factors that might serve as an incentive to encourage districts to provide cost-
effective programs for their students with disabilities instead of sending them to regional
programs.
Guiding Principle 13
Provide no incentive for districts to over-identify students for special education services.
The funding allocation model distributes funds based on K-12 population data and is not
determined by the numbers of identified disabled students. It is not necessary to include this as a
guiding principle of the allocation plan.
Recommendation
The SELPA should:
1. Consider omitting this principle from the guiding principles of the SELPA.
Guiding Principle 14
Recognize that districts have been and will need to continue contributing special edu-
cation revenue limits and general fund contributions to cover special education costs.
An analysis of the SELPA’s funding allocation model found that it assumes fiscal support for
special education from local resources.
As the state proceeds to implement the IDEA excess-cost requirement, the funding allocation
model will probably need to address that issue.
CFR, Title 34 specifies that Part B funds can be used only to pay the excess costs of providing
special education services as follows:
§300.202 Use of amounts.
(a) General. Amounts provided to the LEA under Part B of the Act—
(1) Must be expended in accordance with the applicable provisions of this part;
(2) Must be used only to pay the excess cost of providing special education and related
services to children with disabilities, consistent with paragraph (b) of this section; and
Soquel Elementary School District 19
ALLOCATION FUNDING MODEL
(3) Must be used to supplement State, local, and other Federal funds and not to sup-
plant those funds.
“(b) Excess cost requirement.
(1) General.
(i) The excess cost requirement prevents an LEA from using funds provided under Part
B of the Act to pay for all of the costs directly attributable to the education of a child
with a disability, subject to paragraph (b)(1)(ii) of this section.
“(2)(i) An LEA meets the excess cost requirement if it has spent at least a minimum
average amount for the education of its children with disabilities before funds under
Part B of the Act are used.
IDEA also defines excess cost as follows:
§ 300.16 “excess cost”
“Excess cost” means those costs that are in excess of the average annual per student
expenditure in an LEA during the preceding school year for an elementary school or
secondary school student, as may be appropriate, and that must be computed after
deducting—
(a) Amounts received—
(1) Under Part B of the Act; (IDEA)
(2) Under Part A of title I of the ESEA; and
(3) Under Parts A and B of title III of the ESEA and;
In summary, IDEA requires an average per-pupil expenditure amount to be calculated for
elementary students and a similar amount for secondary students.
Total expenditures are those from all funds, excluding expenditures for the following:
• Capital outlay (Objects 6001-6999)
• Debt service (Objects 7430-7439)
Federal, state, and local expenditures should be subtracted from that total for the following:
• IDEA (special education goals 5000-5999)
• ESEA Title 1 Part A (Resources 3010-3013, 3175-3178, and 7090)
• ESEA Title 3, Parts A and B (resources 4201-4250 and 7091
The remainder should be divided by total elementary or secondary enrollment, as appropriate,
(including disabled students to determine the elementary or secondary enrollment).
Calculations should be made separately for elementary and secondary students. Unified school
districts may not use the same APPE for elementary and secondary students.
Once the APPE is determined for elementary students, it should be multiplied by the total
number of elementary disabled students to determine the amount that must be spent in order
for the expenditures to be excess-cost expenditures. The same formula applies for secondary
students.
IDEA funds can be used only for those excess cost expenditures. EC Section 56836.04 seems to
strongly suggest that AB602 funds can be used only for those excess cost expenditures as well.
20 Fiscal Crisis & Management Assistance Team
ALLOCATION FUNDING MODEL
56836.04. (a) The Superintendent continuously shall monitor and review all special
education programs approved under this part to ensure that all funds appropriated
to special education local plan areas under this part are expended for the purposes
intended.
(b) Funds apportioned to special education local plan areas pursuant to this chapter are
to assist local educational agencies to provide special education and related services to
individuals with
exceptional needs and shall be expended exclusively for programs operated under this
part.
Recommendation
The SELPA should:
1. Modify the funding model as appropriate as the state proceeds to implement the IDEA
excess-cost requirement.
Soquel Elementary School District 21
ALLOCATION FUNDING MODEL
22 Fiscal Crisis & Management Assistance Team
REGIONAL PROGRAMS
Regional Programs
While school districts in several SELPAs provide regional special education services for students
of other districts, most county office SELPAs including the North Santa Cruz County SELPA
primarily give this responsibility to the county office. County offices have a unique role in
SELPAs. They are the responsible agency for relatively few students, but are uniquely positioned
to provide services for students with low-incidence disabilities, severe disabilities, and those with
nonsevere disabilities who live in small, rural and/or sparsely populated areas. This is in accord
with the statutory requirement that the county’s local plan for special education ensure access to
a free appropriate public education (FAPE) for all disabled students, regardless of where they live
in the county. At the North Santa Cruz County SELPA, the responsibility for providing regional
programs for the aurally impaired and those who require transition/work training experience
belongs to Santa Cruz City Schools.
When the SELPA membership requests one or more of its member agencies to act as the provider
of special education services to residents of their districts, the se have the obligation of paying for
those services. To minimize excess costs, the allocation model should ensure that the provider is
not unduly burdened in carrying out this obligation.
Most California county offices historically provided services for students with severe and/or
low-incidence disabilities because they were better situated to do so and had the authority to levy
a property tax for this purpose before passage of Proposition 13. Property tax was maintained as
a part of the funding model after the passage of Proposition 13 and the implementation of the
Master Plan for Special Education in 1979.
Property tax revenues fund the special education programs and services provided by the county
office. However, if tax revenues exceed the cost of providing those programs and services, the
county office is to distribute the excess revenues to the local school districts participating in the
SELPA. Some county offices have initiated a fee-for-service model that allocates all revenues,
including the property tax funds. This allows the districts to provide the services on their own or
to contract with the county office.
The four ways of paying for programs and services provided by one agency for another are as
follows:
• Payment can be made up front on some agreed basis.
• Payment can be made on an as-you-go basis throughout the year.
• Payment can be made upon completion of the provision of services.
• Payment could involve any combination of the above methods.
Property tax revenues are usually treated as up-front payments to the county office for services it
will provide.
In most multidistrict SELPAs, allocations of federal and/or state funds are set aside for the
regional program providers. They are usually provided on an as-you-go basis, and regional pro-
gram providers receive these funds in the same manner as the districts receive allocations of state
and federal revenues.
Regional programs serve students whose disabilities result in especially labor-intensive services.
For county office regional providers, these students are usually the most severe, requiring several
services and considerable human interaction. An equitable allocation model considers these fac-
Soquel Elementary School District 23
REGIONAL PROGRAMS
tors and provides increased funding. If the increase is not sufficient, excess costs will accrue, and
the districts will be billed for those costs. If the increase is greater than warranted, the regional
program provider will carry over the excess funds to the subsequent year. If the presence of these
funds is not considered in the subsequent year’s allocation design, the regional program provider
will begin accruing a reserve. It may be prudent to have a reserve, but it should not become
unduly large with an inequitable funding model that annually provides a regional program
provider with more funds than needed.
Budgets for regional programs and services provided by the county office and Santa Cruz City
Schools are developed, revised and monitored unilaterally by the county office and school staffs
with little or no involvement from the affected school districts. The operating budgets of the
19.76%
regional program providers for students who live in member districts should not be determined
unilaterally. The districts of residence pay the bill by providing a greater share of the state and
federal resources to the regional p5r8o.5g5ra%m provider or by a combination of allocated resources and
excess cost bill-backs. Therefore, the districts should have a responsible and responsive role in
12.04%
developing and implementing the regional program providers’ budgets for special education.
Increasing the allocation to the regional program providers would reduce allocations to the
districts for the direct provision of services, increasing the districts’ local
. Since all funds support costs. Excess cost bill-backs further reduce district resources.
allocated to all Cost-control measures are warranted, and all affected agencies should
have a role in making those determinations. The relationship should be
agencies are
one of collaborative partnership. Since all funds allocated to all agencies
community monies, are community monies, every district has an interest in whether others
every district has provide services cost effectively and in compliance with the law. The
guiding principal should continue to be that no agency should accrue
an interest in
undue benefit at the expense of other agencies.
whether others
The SELPA does not have a policy regarding the carryover of unused alloca-
provide services
tions from year to year. However, there is a procedure. The funding model
cost effectively and does not allow any carryover of AB602 funds and is monitored by the
SELPA. Any district that has AB602 revenue greater than its special education
in compliance with
expenses will set up accounts payable at closing. In February, with the P-1
the law.
certification, these funds are redistributed with any adjustments in the annual
certification for the previous year to districts with encroachment.
The allocation model provides for the projected costs of regional special education provided by
the county office and Santa Cruz City Schools. Budgets for regionalized program services are
unilaterally developed by the agency providing the regionalized program
The allocation plan does not discuss the carryover of unused funds, but includes a method for agencies to
provide regional programs to return the excess funds of the districts of residence that provided them.
Recommendation
The SELPA should:
1. Review and revise policies on the disposition of unused funds from the operation of
regional programs as appropriate.
24 Fiscal Crisis & Management Assistance Team
ALTERNATIVE FUNDING MODELS
Alternative Funding Models
Before designing a new AB 602 funding model, attention should be focused on the following:
• How services are to be planned and delivered.
• Who will provide services for students with low-incidence disabilities; students with
severe disabilities; small populations of students in sparsely populated areas; and
regional programs as alternatives to service provided in the home school, placement in a
neighboring SELPA, or placement in a nonpublic school.
• How regional program providers will be held harmless so that they do not bear an undue
burden by serving students who are the responsibility of other LEAs.
• What factors need to be considered in developing an equitable funding model in North
Santa Cruz County Schools.
• Whether the current organizational structure meets the needs of the districts, the county
office and students.
• The relative identification rates of students needing special education programs and
services, and whether overidentification is occurring in the SELPA.
Most SELPAs transitioned to the AB602 funding model by developing a plan to allocate
resources with hold-harmless effects. That is, district funding in 1998-99 would approximate the
amount received in 1997-98. Distribution of state funds was usually based on average daily atten-
dance, and federal funds were distributed based on the prior year’s unduplicated pupil counts.
Most SELPAs have revised their allocation models, many of them several times since 1999-2000.
Although they have many variations, the three formats generally used to allocate funds are as
follows:
• Removing the total cost of providing regional program and allocating the remaining
funds to the districts.
• Calculating an allocation for regional program providers and planning for the districts to
fund the costs that exceed the allocation through bill-backs.
• Calculating the total cost of providing a regional program and using that cost to
implement a fee-for-service model
There is a statewide trend toward a fee-for-service model. With this approach, all or most of the
available state and federal resources are allocated to the districts, allowing them to determine
whether they can provide more cost-effective services for their students on their own or with
one or more other districts. They can also contract with a regional program provider for services
based on an established fee structure. The North Santa Cruz County SELPA uses a variation
of the allocation and fee-for-service models. Fees are established and applied to each district’s
allocation. Half are funded by relative enrollment and half by the numbers of students from each
district.
The fee-for-service model is attractive to larger districts that have what they perceive as exces-
sively high bill-backs from a county office. In this model, all revenues accrue to the districts
including property taxes. They can opt to provide for their own students, collaborate with one
or more districts to provide for some students, and/or contract with the county office to provide
services for an established fee.
Soquel Elementary School District 25
ALTERNATIVE FUNDING MODELS
This model provides districts with greater control, but includes risks for the county office, other
regional program providers and smaller districts with fewer resources to augment any allocation
they receive. Protections should be implemented to ensure the enrollment in regional programs
matches the projections used to determine the operating budgets and fees. These protections
should also ensure that smaller districts have access to the regional programs their students may
need and that the related fees are reasonable. The allocation model could also create a funding
pool for smaller districts that may need them.
Because of Santa Cruz County’s demographics, the current model may be the best. It spreads the
cost between a neutral figure such as ADA or CBEDS and each district’s actual enrollment in
regional programs. This structure combines the best of both allocation models.
Staff interviews and a review of the data indicate that the procedures specified in the allocation
plan’s “Fundamental Elements of An Approved Cost Model” are effectively used. This document
specifies the revenue elements considered in developing the regional
Because of Santa program provider fee calculation. It also specifies the expenditures
allowed in the fee-development process. Specific forms are included for
Cruz County’s
presenting expenditure considerations. This information was unavail-
demographics, the
able for the current and prior years from either the county office or the
current model may district providing regional program services.
be the best. It There is room for improvement in the process used to develop and
spreads the cost submit this information to the SELPA for approval. Providers prepare
a budget summary with the cost of regional provider programs. Other
between a neutral
SELPA members are not involved in determining program needs and
figure such as ADA projected expenditures. The district submits its budget for approval, but
or CBEDS and each the county office assigns the program administrator and the SELPA
fiscal analyst to provide the county office budget summary. The SELPA
district’s actual
fiscal analyst should not help present the county office budgets for
enrollment in
regional programs based on best practices. The county office program
regional programs administrator and internal business staff members should present that
information. The SELPA fiscal analyst is a county office employee, but
is not involved in developing these budgets and is not in a position to
explain this information. The SELPA fiscal analyst’s role is to provide
information to the SELPA membership on the affect of these budgets on SELPA members. The
SELPA fiscal analyst should calculate the local fiscal support for the payment of fees by SELPA
members. The analyst should also determine the member costs for any pooling of funds for vari-
ous contingencies.
The SELPA should determine the regional programs with greater cost factors and those with
students that could be better served by the district of residence. Proportional and use rates for
more costly programs may be higher than rates for less-costly programs. Further, the division
between proportional and usage support may differ for programs according to whether districts
should be encouraged to develop their own programs. Some programs may consequently have
zero percent proportional support and 100 percent usage support. Other programs may be 100
percent proportional and zero percent usage (such as low-incidence disabilities). Others might be
divided by ratios of 25 to 75 percent, 33 to 67 percent, 50 to 50 percent or vice-versa.
The SELPA allocation model provides sufficient opportunities to protect all members from nega-
tive fiscal effects and sufficient flexibility to be altered as needs change.
26 Fiscal Crisis & Management Assistance Team
ALTERNATIVE FUNDING MODELS
Expenditure budgets for regional programs are developed unilaterally by the agency providing
the regional service.
The method of determining service fees seems to be oversimplified. Treating all special class
populations equally makes it impossible to determine true program costs or use a fee schedule
with incentives and disincentives.
The SELPA has a pool to help districts that are defined by Education Code 14054(a) as direct-
service address the initial costs of placements in certified nonpublic schools. If there are insuf-
ficient funds in the pool, claims are funded on a pro-rationed basis.
The section on maintenance of effort refers to the maintenance of combined state and local sup-
port funds. It does not mention the option of maintaining the level of support from local funds,
which would sometimes benefit the SELPA. The language contains an outdated figure for the
possibility of reducing the maintenance-of-effort requirement when federal funds are increased
from one year to the next. Since 2004, IDEA has permitted up to 50% of any increase to be
treated as local only for maintenance of effort if a like amount is expended for activities under
ESEA. This was an increase from the 20% established in 1997 and currently specified in the
allocation model. The section contains a segment on the SELPA as a whole demonstrating main-
tenance of effort, but does not discuss the SELPA’s responsibility to monitor the maintenance of
effort of the individual school districts.
The policy does not discuss the SELPA’s responsibility to monitor the maintenance-of-effort of
the individual school districts, but the SELPA financial analyst performs this function. This
position regularly places special education maintenance of effort on the agenda of the district’s
monthly financial information group meetings. The SACS MOE interim reports and MOE
unaudited reports are action/discussion items on the agenda at the SECA board meetings, allow-
ing the superintendents to see how their districts are doing in regard to their MOE. The SELPA
financial analyst attends the SEC meeting and discusses fiscal issues including the districts’s
MOE issues. This year, the county office’s fiscal director and SELPA financial analyst conducted
individual district meetings with the districts’ fiscal staffs, special education director, and in
some cases, the district’s superintendent to review their use of ARRA, IDEA, and possible prob-
lems with their MOE in both current and future years.
Item 9 in the Allocation Model discusses inter-SELPA services between the North Santa Cruz
County SELPA and other neighboring SELPAs. However, FCMAT could not find any informa-
tion regarding agreements that might exist between Pajaro Valley, Monterey County, San Benito
County, or Santa Clara County SELPAs.
Item 10 in the allocation model discusses intra-SELPA transfers from a district of residence to
another district for the receipt of services. However, it does not discuss what happens after the
servicing district informs the district of residence that a student has been referred for special
education services.
Item 12 discusses services to parentally placed disabled students in private schools. It refers to
a determination made in 1999 during consultation with “representatives of children with dis-
abilities” that only speech and language services could be provided to a student with disabilities
parentally placed in a private school. The federal regulation refers to “meaningful and timely
consultation with representatives of the private schools and parents of students with disabilities”
enrolled in these schools. December 1999 does not seem to be timely or meaningful given the
opportunity for populations and needs to change and the increase in federal funds received by
the North Santa Cruz County Schools. Unless the state has changed its position, the language
Soquel Elementary School District 27
ALTERNATIVE FUNDING MODELS
regarding three- to five-year-olds may be moot since California does not have a statutory defini-
tion of “elementary school.”
Information obtained in interviews indicates some districts may initiate special education
programs and begin placing students. During IEP reviews, students are consequently removed
from regional programs and returned to the program created by the district of residence. The
advantage is that the district of residence chooses to provide special education services to its own
students at its school sites. The disadvantage is that this practice may be used to avoid the trans-
fer language contained in EC Section 56207. This has the potential for creating a fiscal hardship
for the regional program provider and increases the support costs to all other SELPA members.
Recommendations
The SELPA should:
1. Continue using the current conceptual allocation model while implementing greater pro-
tections for all SELPA members and flexibility to provide incentives and disincentives.
2. Use an operations oversight committee in developing revenue/expenditure budgets for
regional programs and monitoring ongoing operations from a programmatic and fiscal
aspect.
3. Develop policies on the disposition of any unused funds from the operation of regional
programs.
4. Review and revise, as appropriate, the maintenance-of effort language in the allocation
model.
5. Develop procedures and contractual formats for providing services to residents of neigh-
boring SELPAs.
6. Provide more procedural descriptions of the procedures and activities involving intra-
SELPA services.
7. Review and revise Item 12 in the allocation model. Timely and meaningful consulta-
tions have generally interpreted to mean annual consultations.
8. Review and revise Item 14. The SELPA should consider incorporating language that
triggers a “transfer” if it appears to be occurring. A disincentive should be implemented
for districts to inform a regional provider before March 1 that a certain number of their
students will be enrolled in the program the following year and subsequently change that
number significantly after March 15.
28 Fiscal Crisis & Management Assistance Team
SELPA GOVERNANCE STRUCTURE
SELPA Governance Structure
The Special Education Coordinating Agency (SECA) Governing Council is made up of a
superintendent or administrator from each participating LEA. The governing council contracts
with the county office for the personnel and fiscal services that support functions as the SELPA
administrative unit. Governing boards approve contracts and/or JPAs with the county office and
other participating LEAs in the SELPA.
The North Santa Cruz County SELPA LEAs vary significantly in size and are as follows:
• Bonny Doon Union Elementary School District
• Delta Charter School
• Happy Valley Elementary
• Live Oak Elementary School District
• Mountain Elementary School District
• Pacific Collegiate Charter
• Pacific Elementary School District
• San Lorenzo Valley Unified School District
• Santa Cruz City Schools – Elementary and High School
• Santa Cruz Office County Office of Education
• Scotts Valley Unified School District
• Soquel Union Elementary
Each governing council member has one vote. However, if one member requests a weighted
voting system, each member is required to participate in this system. In this case, each LEA
receives one base point with an additional point granted to LEAs with a CBEDs count of more
than 100. LEAs with a CBEDs count of more than 100 receive one additional point for each
additional thousand students. The number of points assigned to each district and county is
readjusted each October when the new CBEDs figures are determined. Absentee votes are not
counted, and absent members may not assign their voting privileges to other agencies.
The special education administrators of each LEA participate on the Special Education Council
(SEC) have the authority to implement policies and procedures. SEC members meet regularly
and formulate advisory positions of program organization, structure, allocation and policy issues
that are offered as recommendations to the governing council through the SELPA director. The
director serves as the chairperson of this committee and is responsible for providing timely writ-
ten notice of the meeting and agenda, minutes, and any additional documentation.
The SELPA has established a Community Advisory Committee (CAC) as required by Education
Code Part 30 (EC56205 (12) (C). The SELPA actively recruits for members that include the par-
ents of special education students in public or private schools, regular education teachers, special
education teachers, other school personnel, representatives of other public and private agencies,
and people concerned with the needs of special education students.
The SELPA director serves as the SELPA chief administrative officer, the executive secretary of
the governing council, and the chair of the SEC. The director provides the leadership and super-
vision required for development of SELPA reports, implementation of program specialist services
and other regionalized services. The main role of the SELPA director is to provide leadership
Soquel Elementary School District 29
SELPA GOVERNANCE STRUCTURE
and facilitate decision-making. The governing council is responsible for the selection, direction,
discipline and annual evaluation of the SELPA director. The evaluation is performed by a joint
committee; however, no information was provided on the composition of the joint committee.
The administrative unit helps the governing council with hiring and selection.
The SELPA has lacked consistent leadership for five years because of a high turnover in interim
SELPA directors and the fact that the position was reduced to part-time. As a result, commu-
nication and articulation with the districts has been inconsistent. The SELPA should take the
leadership role in communicating with all its member districts and the county office. The county
office will again become the administrative unit July 1, 2010.
The county office does not have a SELPA director. The Soquel Union Elementary School District
is the administrative unit for the SELPA with a .5 FTE director.
Communication
Several of those interviewed expressed frustration over a lack of communication in the gover-
nance structure that affects council members, the SEC and chief business officials. Program and
business members do not work collaboratively, hindering decision-making. There is confusion
regarding agreements made at the meetings of the governing council, which occur four times a
year, and the SEC, which meets monthly. The two committees reportedly view special education
from different perspectives.
FCMAT’s interviews and fieldwork suggests that SECA members are primarily concerned
with fiscal encroachment issues while SEC members are concerned about programmatic needs.
Holding joint meetings of the two groups at least twice a year would help promote understand-
ing and cohesion. Communication would improve if SECA meetings occurred at least every
other month or six times per year.
Superintendents who attend governing council and SEC meetings and serve in several capacities
for their districts have a better understanding of the SELPA and county office and the decisions
of both entities.
The fiscal information discussed at committee meetings is frequently not conveyed to district
chief business officers (CBOs). This information would help CBOs budget and plan. None of the
joint meetings that occur include CBOs. These meetings should occur at least twice a year, with
fiscal information regularly conveyed to CBOs and the fiscal staff via e-mail.
The superintendents, district directors and district fiscal personnel do not receive regular com-
munication and training regarding the SELPA funding allocation plan. The SELPA does not
hold regular AB602 meetings. As turnover occurs in the governance structure, it becomes even
more important to promote a clear understanding of the SELPA funding allocation plan and
AB602.
The SELPA should consider revising its governance structure to improve communication, open-
ness and decision-making. The SELPA lacks a joint oversight committee. Committees of this
type have been established at other SELPAs and allow representatives with different perspectives
of special education to provide input and expertise, improving decision-making.
A joint oversight committee would also perform the following:
• Ensure that local, state, and federal resources are used cost-effectively
• Monitor the efficiency of funding allocation plans
30 Fiscal Crisis & Management Assistance Team
SELPA GOVERNANCE STRUCTURE
• Make recommendations regarding fiscal effectiveness
• Monitor the county office funding model for efficiency
• Ensure the SELPA’s overall cost efficiency and effectiveness
• Meet before each governing council and report any fiscal or programmatic issues to the
council
The committee should be made up of two superintendents, two program directors, two CBOs
from the LEAs and one representative from the county office. The SELPA director should chair
this meeting, develop agendas, and take the minutes.
The SELPA does not conduct an annual orientation for new superintendents, district directors,
and district fiscal personnel. Veteran members should also have the opportunity to participate.
At the orientation, the SELPA should share a treasurer’s report such as the sample attached as
part of Appendix A to this report.
This type of report allows the SELPA governance be kept apprised of revenues and expenditures
at least annually.
Recommendations
The SELPA should:
1. Schedule at least two meetings a year that include the SECA Governing Council, SEC,
and CBOs to improve the communication.
2. Schedule at least two meetings a year that include the SECA Governing Council and
the SEC to discuss the mission of each group. This should improve communication and
decision-making.
3. Ensure that the governing council meets at least every two months or six times per year.
4. Ensure that the information provided during meetings of the governing council and
SEC is regularly conveyed to the district CBOs or fiscal staff. This information could be
disseminated via e-mail after and between meetings.
5. Invite CBOs to at least two meetings per year so they can stay abreast of fiscal matters
regarding the SELPA and districts they serve.
6. Provide regular and ongoing training regarding the funding allocation plan and AB602.
7. Revise the governance structure to include a joint oversight committee made up of gov-
erning council members, SEC members, and CBOs to improve communication, open-
ness and decision-making. This committee should be made up of two superintendents/
administrators, two program directors and two CBOs from member districts.
8. Develop an annual orientation for new superintendents, district directors, and district
fiscal staff on all the basic aspects of the SELPA. Veteran members should also be able to
attend these orientations.
9. Develop and distribute a SELPA treasurer’s report to the members at least annually to
improve communication.
Soquel Elementary School District 31
SELPA GOVERNANCE STRUCTURE
Openness and Decision-Making
Interviews with staff members of each entity indicate there is an overall lack of trust between
the SELPA governance members and the county office. Communication has suffered because of
a lack of openness in sharing detailed program and staffing information on the actual costs of
operating county office programs. The county office provides the governing council with only
per-pupil costs, which the members consider minimally useful. However, the county office does
not provide members of the SELPA governance structure with regular program and staff cost
breakdowns of the programs operated on the districts’ behalf.
Much of the information disseminated at governing Council and SEC meetings is difficult to
understand. Since county office programs are funded before allocations are made to districts, it
is important that districts know the cost of programs and services. A more
detailed breakdown would demonstrate openness. Interviews with
The “Off-the-Top Model Table” attached as part of Appendix A to staff members
this report should be completed by county office Special Education of each entity
Department and provided to the governing council and the SELPA direc-
indicate there is
tor to improve communication. Ideally, this information should also be
an overall lack of
available to other members. It is important for the county office to capture
all costs associated with the program it operates. The table should be com- trust between the
pleted using Microsoft Excel.
SELPA governance
After capturing the total program costs, the county office should use the tables members and the
included as part of Appendix A to provide the exact costs of specific programs.
county office.
Ideally the county office would provide the governing council and SELPA
director with a chart of programs/services. This table should include the
FTEs/numbers of administrative staff members, secretaries, fiscal person-
nel, itinerant staff/teachers, and instructional assistants. The staff-to-student ratios should also be
included. This information should be divided by center-based, integrated severely handicapped,
and itinerant programs and services.
The “Sample Chart for Summary of Classroom Costs” included as part of Appendix A provides
a summary of classroom costs. This table should be completed by county office and provided to
the governing council at least annually.
Ideally, the county office would provide the governing council and SEC members with a monthly
class loading recap. Every class or center that the county office operates should be included. This
table is a changing document that should be discussed at every SECA and SEC meeting.
The above tables should balance to the exact dollar amount that used to operate county office
programs. All costs should be captured in the tables.
The “Sample Forms for Special Day Class Loading” attached as part of Appendix A to this report
should be updated monthly to reflect county office class loading and should be discussed at every
SECA and SEC meeting.
Governance members are frustrated over the lack of control that districts have over compliance
issues. Districts are responsible for 75% of costs associated with due process/mediation, and the
county office is responsible for the remaining 25%. The governance council is not provided with
current program information. However, if parents of students in county office programs file for
due process or mediation, the districts (governing council) are responsible for 75% of associated
costs. These costs are primarily tied to mediation.
32 Fiscal Crisis & Management Assistance Team
SELPA GOVERNANCE STRUCTURE
The county office special education programs have not been named as the primary respondent
in a due process complaint for a student actually enrolled in a county office program since the
2007-2008 school year.
However, districts are experiencing an increase in the number of due process cases in which they
have offered a county office or district special education program as a free appropriate public
education (FAPE) In these cases, even though the county office is named as a co-respondent,
the student either has never actually been enrolled in a county office program or was an interim
30-day placement. These due process complaints have primarily been filed by parents of students
on the autism spectrum,
District staff members indicated their telephone calls to the county office requesting assistance
are frequently not returned in a timely manner or not returned at all. Districts will develop
greater confidence in customer service if the county office special education staff responds to
phone calls and requests for assistance in a timely manner.
The county office should conduct an extensive survey with the districts to determine how to
improve communication, openness, decision-making and services to the members.
Governing council and SEC members do not regularly visit county office programs. These visits
improve communication and familiarize members with programs and students.
Recommendations
The county office should:
1. Address the lack of trust from member districts by providing detailed documentation of
program operational costs and increased opportunities for member districts including
CBOs to meet with program staff.
2. Provide the governing council with all program and staff costs using the tables provided
above. Providing a per-pupil cost is insufficient to satisfy obligations to the governing
council.
3. Understand the differences between an “off-the-top” funding model and a fee-for-service
model.
4. Take the necessary steps to convey to members that the programs provided by the
county office are efficient and effective and that costs are continuously monitored.
5. Complete and distribute the detailed operational expenses using the following forms
provided by FCMAT in the previous section as a sample, and discuss them with the
appropriate employees and/or entities as follows:
FORM EMPLOYEE/ENTITY
SCCOE Off-the-Top Model Table Governing council, SELPA director
SCCOE Special Education Table of Programs/Services Governing council, SEC members
SCCOE Operated Programs – Summary of Classroom
Governing council, SELPA director
Costs for 2009/10
Special Education Class Loading Recap Table Governing council, SEC members (monthly)
Soquel Elementary School District 33
SELPA GOVERNANCE STRUCTURE
6. Address the districts’ responsibility for 75% of the mediations costs. If districts are
responsible for 75% of the costs, they should be involved in decision-making and have a
sense that the county office operates cost efficient programs.
7. Address customer service issues to ensure that phone calls are returned, assistance is
provided when needed and pertinent information is shared.
8. Encourage the governing council and SEC members to visit county office programs at
least annually.
34 Fiscal Crisis & Management Assistance Team
REGIONALIZED DOLLARS/PROGRAM SPECIALISTS
Regionalized Dollars/Program Specialists
According to the 2009-10 P1 certification, the SELPA is receiving $281,000 to provide regional-
ized services and/or program specialist services, additional funding for pass-through to the
districts, accumulated interest, and some funds from specific grants, carryover balances, and
several other sources (Medi-Cal Administrative Services, Region V California Services for
Technical Assistance and Training). The SELPA also receives $39,000 in low-incidence materials/
equipment funds in the current year that must be used solely to provide necessary equipment and
materials for students with disabilities.
The total revenue, $471,932 is used as follows:
• $54,870 are expended for salaries and benefits
• $52,000 for books, materials, and supplies
• $5,340 for travel and conference
• $3,000 for dues and memberships
• $3,900 for insurance
• $11,800 for rents, leases, and repairs
• $3,600 for postage and communications
• $5,700 for capital outlay equipment
Contracts total about $140,000, including contracts for .5 FTE fiscal analyst services with the
county office, other county offices and memorandum-of-understanding services, the Special
Education Information System (SEIS) with the San Joaquin County Office of Education,
Southern Regional Peninsula, and Vavrinek, Trine, Day and Co.
The expenditures total $422,680, leaving a projected surplus of $48,252, well short of the
approximately $90,000 to $100,000 that would be necessary to compensate a program specialist.
Since these revenues/expenditures include resources other than the $281,000 provided by AB602
for regionalized services and program specialists, available funds are insufficient for program
specialist services under the current budget scenario.
TOTAL SELPA REVENUE
10.22 percent
Surplus
Expenditures
89.56 percent
Soquel Elementary School District 35
REGIONALIZED DOLLARS/PROGRAM SPECIALISTS
Last fiscal year, the SELPA expended $84,343.70 for contracted and other services under object
code 5800. In addition to state aid, the SELPA has some funds from specific grants, carryover
balances, and several other sources (Medi-Cal Administrative Services, Region V California
Services for Technical Assistance and Training). No funds are available for program specialist
services under the current budget scenario.
The SELPA has one program specialist employed by the county office. Sixty percent of the cost for
this program specialist is funded by special education and 40 percent by the New Teacher Project.
The New Teacher Project was formed in 1997 to address teacher shortages and teacher quality
throughout the country The specialist position’s duties include providing teacher support through
mentoring, coaching and training. The program specialist does not attend high profile IEPs or
provide program support or coordination. This is inconsistent with the role of program specialists
in other SELPAs, which follow the requirements in Part 30 EC 56368 (a)-(c). The duties of the
program specialist should be re-evaluated and reassigned to include these duties and functions. This
position should be expanded to include the regular functions of a program specialist.
An additional program specialist is employed and funded b Santa Cruz City Schools. The district
does not receive program specialist dollars from the SELPA to support this position. Since the
district supports this position on its own, the district also determines the duties and functions.
All program specialist funds for regionalized services are committed. Additional program
specialist services would require local funds. The governing council should determine whether to
pursue this option.
The county office has a position that functions as .5 FTE program specialist and .5 FTE mentor
teacher and is funded through Medi-Cal Administrative Activities (MAA) and the New Teacher
Project.
Recommendations
The SELPA and county office should:
1. Send the county office program specialist to high-profile IEPs as a support.
2. Ensure the program specialist provides program support.
3. Determine whether districts want to use local funds to support additional program
specialist positions.
4. Consider reviewing and redirecting regionalized services/program specialist funds to
make funding available for regional program specialist services.
5. Review and revise the “off-the-top” allocations for regional program providers and the
allocations of state and federal funds to the districts to provide funding for regional
program specialist services.
6. Obtain job descriptions and function/duty statements for program specialists from other
SELPAs to determine what the North Santa Cruz County SELPA wants of its program
specialists and how they should function.
36 Fiscal Crisis & Management Assistance Team
DISTRICT COLLABORATION
District Collaboration
Some SELPA members are concerned that some districts refer high numbers of students for assess-
ment and others refer few students to county office programs. Many SELPAs address this issue by
adopting a fee-for-service funding model. Others develop a table that indicates the percentage of
students served in severe special day class (SDC) programs. The information is sorted by district of
residence (DOR) and should be completed by the county office and discussed with the governing
council and SEC members at least two times annually. A sample of this type of table without the
required data is as follows:
Percentage of Students served in severe SDC classes sorted by District of Residence
Special Education/Santa Cruz County Programs
Percentage of Students Served in Severe SDC’s Sorted by DOR
December 2009 CASEMIS
1Adjusted 2009/2010
Autism ED MODERATE/SEVERE
P-1
% of Total % of Total % of Total
Total Total Total
Students Students Students ADAK-12 ADA%
Students Students Students
DISTRICT Served Served Served
Bonny Doon Union
Elementary School District
Delta Charter School
Happy Valley Elementary
Live Oak Elementary
School District
Mountain Elementary
School District
Pacific Collegiate Charter
Pacific Elementary School
District
San Lorenzo Valley Unified
School District
Santa Cruz City Schools
(Elem & High School)
Scotts Valley Unified
School District
Soquel Union Elementary
Total Students by Program
1ADA adjusted by adding 93% of total Preschool and Adult pupil count to actual P1 ADA
2 Note: P-1 ADA includes Special Education and Court/Community programs
This table indicates the percentage of students from each district enrolled in severely disabled
(SD), autistic, and emotionally disturbed (ED) county office programs. The chart allows the
governing council to determine whether districts use a disproportional share of county office
program services and the areas where this may occur.
Collaboration between the SELPA and county office is necessary to generate the chart, which should
be completed quarterly. If it is determined that some districts receive a disproportional share of county
office services, the governing council may decide to transition to a fee-for-service funding model. With
this model, each district is billed only for the services it receives from the county office.
Soquel Elementary School District 37
DISTRICT COLLABORATION
The governing council should determine whether the four smaller SELPA districts can afford to
operate under this model since providing for one high-cost student can be fiscally difficult. The
relevant data should be carefully analyzed before considering this change since members may
find that services are equitably provided at present. Members should also realize that one of the
SELPA’s functions is to ensure that services and programs are available for students with special
needs. The document attached as Appendix A to this report is an example of a table that docu-
ments districts’ program costs. If this particular table is used, a different one would have to be
completed for each district.
Recommendations
The SELPA and SCCOE should:
1. Continue to encourage the districts to work collaboratively and assist each other when it
is possible, especially the small districts.
2. Complete the table titled “Percentage of Students Served in Severe SDC’s Sorted by
DOR,” and discuss it with the governing council and SEC members at least twice a year.
The county office and SELPA should collaborate to gather this data.
3. Ascertain whether the governing council wants to determine if some districts receive
a disproportionate share of county office services and programs. If members want to
pursue this issue further, an Off-the-Top Model Table can be completed for each district.
4. Ensure that members are familiar with the smaller districts and their fiscal limitations.
Staff Development
SELPA-provided staff development offers open registration to all SELPA LEAs. However, the
districts indicated they would benefit from additional opportunities for staff development. If the
SELPA finds it costly to provide all the necessary staff development, it should consider charging a
fee to cover speaker costs.
The tables below show the staff development offered to the SELPA for the last three years and the
number of participants from each district.
Form for Reporting Staff Development Training
Staff Development Training
2007/08
Training Title BDUE DCS HVE LO ME PCC PE SLVU SCCS SCCOE SVU SUE O
The Eyes Have It: 0 0 0 0 0 0 0 0 0 0 0 0 0
Tapping the Visual
Modality to Increase
Teaching Effectiveness
- CANCELLED
NEPSY®- II A 0 0 0 3 0 0 0 1 1 2 0 1 2
Developmental
Neuropsychological
Assessment
38 Fiscal Crisis & Management Assistance Team
DISTRICT COLLABORATION
Autism Spectrum 2 0 0 9 0 2 0 0 13 10 0 7 4
Disorders: Best
Practices for
Assessment
Transition Planning 0 0 0 3 0 0 0 1 5 3 3 0 8
for adolescents with
Autism Spectrum
Disorder
Promoting Social 1 0 1 9 1 0 2 3 14 1 1 2 0
Competence: Effective
Strategies for Busy
Teachers
*This table reflects the number of participants that attended each training from each district
Note: Other= Districts outside of SCCOE, Other Agencies (both inside and outside SELPA), Other COEs, Santa Cruz
UC and Mental Health
Staff Development Training
2008/09
Training Title BDUE DCS HVE LO ME PCC PE SLVU SCCS SCCOE SVU SUE O
New Special 0 0 0 0 0 0 0 2 10 12 6 4 0
Education Staff
Orientation
DRDP Training - 0 0 0 0 0 0 0 0 0 0 0 0 0
CANCELLED
BICM Refresher 0 0 0 2 0 0 0 1 6 0 0 2 1
BICM Training 0 0 0 0 0 0 0 0 1 5 2 0 3
Promoting Positive 1 0 2 2 2 0 0 3 5 0 2 4 1
Classroom Behavior
Preschool
Legal Workshop, 0 0 0 1 0 0 0 3 1 8 0 4 8
Assessment Reports
For Para Educators 5 0 0 0 6 0 0 12 2 5 4 3 4
Only: Providing
Support for
Special Education
Students in
General Education
Classrooms
WAIS IV Workshop 0 0 0 0 0 0 0 1 1 0 2 0 0
Students with 0 0 0 2 0 0 0 2 0 4 0 3 1
Asperger
Syndrome and
High Functioning
Autism in General
Education: How
Principals Can Lead
the Way
Middle and High 0 0 0 0 0 0 0 0 0 0 0 0 0
School Transition
Portfolios -
CANCELLED
Executive 0 0 0 0 1 0 0 7 5 6 5 1 9
Functioning: Helping
Students Learn How
to Learn
Soquel Elementary School District 39
DISTRICT COLLABORATION
Staff Development Training
2009/10
Training Title BDUE DCS HVE LO ME PCC PE SLVU SCCS SCCOE SVU SUE O
New Teacher 0 0 0 1 0 0 0 2 5 4 8 1 0
Orientation
Teaching Students 0 0 0 0 0 0 0 0 11 4 1 2 13
with Moderate to
Severe Intellectual
Disabilities
The ABC’s 0 0 0 0 0 0 0 0 0 0 0 0 0
of Transition
Functional
Assessment
Model (TFAM):
Connecting
Assessment to
Transition Goals -
CANCELLED
Will He Catch Up? 0 0 0 0 0 0 0 0 0 0 0 0 0
Talking to Parents
about Cognitive
Impairment -
CANCELLED
Straight Talk About 2 0 0 7 5 0 2 3 10 1 0 3 9
Deficit/Hyper-
activity Disorder:
Evidence-based
Instruction
The Art and 1 0 0 7 1 0 0 12 6 3 3 5 17
Science of
Collaboration in
Special Education
Legal 0 0 0 0 0 0 0 0 0 0 0 0 0
“Development
of Defendable
Assessments” &
“Controlling &
Bringing Closure to
the IEP Process” –
PENDING
*This table reflects the number of participants that attended each training from each district
Note: Other= Districts outside of SCCOE, Other Agencies (both inside and outside SELPA), Other COEs, Santa Cruz UC
and Mental Health
Some staff development offered by the SELPA was cancelled because of low registration. During
the current fiscal crisis, it is difficult for districts to fund release time for the teaching staff. The
SELPA should explore creative options for offering training during evenings or in the summer to
avoid increased staffing costs and low registration.
Additional staff development should be considered in the following areas:
• Autism (SELPA-wide)
• AB602 Funding (SECA, SEC, CBOs)
• The SELPA funding allocation plan (SECA, SEC, CBOs)
40 Fiscal Crisis & Management Assistance Team
DISTRICT COLLABORATION
• County office program costs (SECA, SEC, and CBOs)
• Special circumstance instructional assistants (SCIAs)
• Instructional assistants – The Los Angeles County Office of Education offers On-line
Paraeducator Academy Courses (Information is attached to the appendix section of this
report).
A review of sign-in sheets from each staff development session found that participation appears to be
fairly representative of the LEAs in the SELPA. However, a few districts should consider attending
more staff development opportunities.
Recommendations
The SELPA should:
1. Consider charging a fee for staff development to expand its current offerings.
2. .Consider offering staff development sessions during the summer or evenings to avoid
costly expenses for release time and subsequent low registration.
3. Ensure more trainings are provided in the areas of autism, AB602 funding, the funding
allocation plan, county office program costs, special circumstance instructional assis-
tants, and instructional assistants.
4. Consider using the Los Angeles County Office of Education On-line Paraeducator
Academy courses to train instructional assistants.
5. Encourage further participation by the members to prevent staff development opportuni-
ties form being cancelled.
Soquel Elementary School District 41
DISTRICT COLLABORATION
42 Fiscal Crisis & Management Assistance Team
SELPA POLICIES
SELPA Policies
The SELPA local plan states that policies governing the SELPA are adopted by the governing
council and included in the plan. The governing council is the policy-making body for SELPA
and its member LEAs. The policy agreements, regulations and procedures adopted by the
governing council under the authority of the adopting LEA board have the same status as other
LEA board policies and may be contained in a variety of documents approved by the governing
council. In addition, each agency is required to cooperate with other agencies to serve disabled
students that cannot be served in programs at the LEA of residence. This type of cooperation
ensures that a range of program options is available throughout North Santa Cruz County. The
SELPA staff implements the policies and decisions of the governing council.
A review of SELPA policies for consistency with state and federal law found that Policy 10503 –
Independent Educational Evaluations could be simplified as follows:
Notice to Parents
The first bullet in the policy states: “Please read this document before obtaining or paying for an
Independent Educational Assessment. This document may limit your right to reimbursement.”
To soften the language and make it more understandable, it should read: “Parents should be sure
to read the entire document carefully. Your right to reimbursement may be limited if the evalua-
tion is not obtained in accordance with the district guidelines.”
North Santa Cruz County SELPA’s Response to Request for an Independent Evaluation
The current language currently reads as follows:
If parents request an Independent Educational Evaluation at public expense, the dis-
trict will, without unnecessary delay, offer the parent an alternative examiner (option 1
below) and also provide options for an Independent Educational Evaluation at public
expense (option 2, 3, or 4 below) as follows:
1. A staff member from another school;
2. A staff member from another LEA in the SELPA;
3. A staff member from another SELPA;
4. A private sector provider
Once the parent chooses an option, the district will arrange for the alternative evalua-
tor, contract with an independent examiner, or otherwise ensure that an Independent
Education Evaluation is provided at public expense.
If the district initiates a hearing and the final decision is that the district’s evaluation
is appropriate, the parent still has the right to an Independent Educational Evaluation,
but not at public expense.
The language should be simplified to state the following:
District Response to Request
If parents request an independent educational evaluation at public expense, the district
will, without unnecessary delay:
Soquel Elementary School District 43
SELPA POLICIES
• Provide the parents with the independent educational evaluation guidelines
AND
• Review existing evaluations to determine if agreement can be achieved by
providing additional district evaluations by an alternative district or SELPA
evaluator; OR
• Ensure an independent educational evaluation is provided at public expense;
OR
• Initiate a due processing hearing
Time line Regarding Independent Education Evaluations
The third paragraph of this section states as follows:
The district will make arrangements for a new evaluation, or contract with a qualified
independent examiner who is able to provide a written report for an IEP meeting,
within 50 days of the date of contracting for an evaluation
This paragraph should be revised as follows:
The district will make arrangements for a new evaluation, or contract with a qualified
independent examiner who is able to provide a written report for an IEP meeting,
within 60 days of the date of contracting for an evaluation.
Evaluations Ordered by Hearing Officers
This section reads as follows:
If a hearing officer requests an Independent Educational Evaluation as part of a hearing
the cost of the evaluation must be at the district’s expense
The section should be revised to read as follows:
Due Process/Evaluations Ordered by Hearing Officers
If a hearing officer requests an independent educational evaluation as part of a hearing,
the cost of the evaluation must be at the public’s expense.
If the district initiates a hearing and a final decision determines that the district’s
evaluation is appropriate, the parent still has the right to an independent educational
evaluation, but not at public expense.
If the district initiates a due process hearing to show that the district’s evaluation is
appropriate, reimbursement will be made if ordered by a hearing officer.
Procedure 10503.1 – Independent Education Evaluations
This entire procedure could be condensed and simplified for better understanding.
The SELPA should consider adding a policy on disproportionality. Some SELPAs have added this
policy and could provide an example.
44 Fiscal Crisis & Management Assistance Team
SELPA POLICIES
Recommendations
The SELPA should:
1. Simplify and clarify policy 10503 – Independent Educational Evaluations by incorporat-
ing the suggestions provided above.
2. Consider developing a SELPA policy addressing disproportionality.
Soquel Elementary School District 45
SELPA POLICIES
46 Fiscal Crisis & Management Assistance Team
STAFFING AND CASELOADS
Staffing and Caseloads
FCMAT reviewed the staffing of all special education programs at the county office as well as a random
sample of district programs. The following districts were used in the random sample: Live Oak School District,
Pacific Elementary, San Lorenzo Valley Unified, Santa Cruz City Schools, and Soquel Union Elementary. The
county office operates a full range of special day classes, but no resource specialist programs.
North Santa Cruz County and Regional Programs
The Individuals with Disabilities Education Act (2004) requires disabled students from birth to
22 years of age (or until high school graduation) to be provided with the education and related
services necessary to receive a Free Appropriate Public Education (Title 34 Section 300.101).
North Santa Cruz SELPA students with disabilities that require specialized programs and ser-
vices beyond those available in local school districts are referred to county office programs.
The county office operates 20 programs for students with severe disabilities from preschool through
post high school. The student enrollment is 235 served in 25 classrooms on 14 sites, including four Early
Start classes. The districts indicated they rely on the county office to provide programs and services for
approximately 189 severely handicapped students at an annual cost ranging from $37,000 to $38,000
per student. There are additional costs when a student requires a one-to-one instructional aide.
County office programs for autistic students operate at an annual cost of $52,000 per student. In
addition, the districts use two nonpublic school options; Bright Path for emotionally disturbed
students at an annual cost of $49,000 per student and Bay School for autistic students at an
annual cost of $110,000 per student.
Some local districts perceive that although they are making significant reductions in special edu-
cation staffing, county office special education programs are not reduced on a proportional basis.
The district staff indicated that the primacy concerns are the high support ratios in classrooms
and the high administrative ratio at the county office.
Administration
FCMAT reviewed data from a random sample of five districts and the county office, which
budget administrators with special education resources. Most remaining districts did not have an
administrator for special education.
Comparison of Special Education Administrators North Santa Cruz County SELPA dis-
trict/county office SELPA members
Districts Administrators Students Comments
Santa Cruz County Office of 1.0 Senior Director 189 Serves Prek-Post High School/all Severely
Education .8 Associate Supt Handicapped Programs
Live Oak District .7 Administrator 291 K-8 with a Charter High School
San Lorenzo Unified .6 1250 K-12 Unified; many Charter Schools
Santa Cruz City Schools 1.0 Director K-5 Elementary 357 2 districts with one governing board; one
1.0 Program Specialist 6-12 High School 573 special education program serving both
Total: 930 students
Scotts Valley .85 Director 231 K-12
Soquel Union .5 219 K-8
Sources: District and Santa Cruz County Office of Education report on administrative staffing and student
data from the California Special Education Management System (CASEMIS). Note: The county office pro-
gram specialist is not an administrative position, but is on a 182-day contract on the teacher salary schedule.
Soquel Elementary School District 47
STAFFING AND CASELOADS
The county office senior director of special education is a full-time position that supervises the
daily operation of county office programs for 235 students. Duties include interacting with
district special education directors, parents and advocates with a primary role of resolving due
process issues. The director also hires, supervises and reviews the performance of 100 county
office classified and certificated employees. No other duties are assigned.
The associate superintendent (.6 FTE) also oversees the daily operation for special education pro-
grams. Additional duties include supervising categorical programs, with .4 FTE of this position
funded from those programs.
Special education supervisory duties at the districts are performed by administrators funded by
special education or the general fund. These administrators have numerous duties in addition to
special education. The county office maintains a higher ratio of administrators to students than
the districts.
The senior director is responsible for Early Start, which has 46 students served in four classes
and support services. For more specific information on the job duties of the director, they
are available at http://www.santacruz.k12.ca.us/student_services/hr/job_descriptions/mgmt/
dir_spec_ed.pdf
Recommendations
The county office should:
1. Consider reducing the level of administrative support for special education programs
over the next two years as follows:
• Reduce the county office director position from 100% to 50% (a savings of
approximately $60,000) and combine it with the duties of the current SELPA
director that is funded at 50%.
• Transfer oversight of the county office special education programs and services
from the associate superintendent to the senior director as outlined above (county/
SELPA). This will save result in a 60% savings or approximately $75,000 for the
county office special education budget.
• Use the remaining 40% to fully fund the program specialist position from the
SELPA. The functions of this position should be revised to support SELPA and
district functions (an increase of approximately $100,000).
48 Fiscal Crisis & Management Assistance Team
COUNTY OFFICE AND REGIONAL PROGRAM STAFFING
County Office and Regional Program Staffing
Comparison of District/County Office Programs with Guidelines from Statewide Industry
Standards and/or Education Code Requirements
Districts/County Certificated Caseload School Services Inc
Program Staffing Averages
Live Oak School District 6.49 RSP FTE 23 students 28 students*
1 Preschool SDC/SH 4 students 8-10 students
5 (K-8) SDC/SH 7 students 8-10 students
Santa Cruz County Office of 6 (9-12) SDC/SH
Education (includes 1@ 6-12) 12 students 8-10 students
3 (Prek-3)Autism
9 students 8 students
6 ED (K-12)
8 students 8-10 students
San Lorenzo Valley 7 RSP 26 students 28 students
6 SDC/NSH 13 students 12-15 students
Santa Cruz City Schools 24 RSP 22 students 28 students
11.2 SDC/NSH 11 students 12-15 students
Scotts Valley Unified 5 RSP 40 students 28 students
4 SDC/NSH 11 students 12-15 students
Soquel Union Elementary 4 RSP 28 students 28 students
4 SDC/LH 12 students 12-15 students
Notes: The industry standard for staffing caseloads is established by School Services Inc. 2008 and
is written using statewide practice reported by school districts. The resource specialist caseloads are
legislated in EC 56362. In some cases, districts may use different program models which permit
higher caseloads. Consult with district program descriptions before comparing caseload averages with
Education Code requirements. This chart does not reflect the three elementary, two middle and three-
post-senior SH SDC classrooms. Additional information is available from the county office.
Key:
RSP: Resource specialist program
SDC/SH: Special day class/severely handicapped operated by the county office or regional program
SDC/NSH: Special day class/nonseverely handicapped operated in local school districts
SDC/Autism: Special day classes with specially designed instruction for students with Autism
SDC/ED: Special day classes with specially designed instruction and support services for students with
emotional disturbance
Soquel Elementary School District 49
COUNTY OFFICE AND REGIONAL PROGRAM STAFFING
Most special day classes in the county office and local districts operate within the guidelines
established by School Services Inc; however, the preschool’s SDC class enrollment is significantly
below the recommendation. The county office staff should regularly review SDC caseloads and
make appropriate adjustments to class sizes and resources when class sized do not meet expecta-
tions by December 1 of each school year. This will ensure greater efficiency.
Recommendations
The county office should:
1. Evaluate the number of incoming three-year-olds that may increase enrollment in the
preschool program from March to June 2010.
2. Redistribute resources to assist other special education programs in the county office if
there are no prospective students to increase the enrollment,
3. Establish a standard practice of evaluating all caseloads by December 1 of each school
year and make appropriate adjustments to resources.
Instructional Aides
Comparison of Instructional Aides in District/County Programs to Industry Standards
and/or Education Code Requirements
District/County Classified Program Staffing School Services, Inc
Live Oak School District 3.78 FTE Resource Aides 5-6 hours per RSP*
Santa Cruz County Office of Education
2.0 FTE aides per class 2.0 aides per SDC class
San Lorenzo Valley 6.24 RSP aides 5-6 hours per RSP
6.84 SDC/NSH aides 1 aide per SDC class
Santa Cruz City Schools 14.12 FTE RSP 6 hour aides
11.5 FTE SDC/NSH 6 hour aides
Scotts Valley 5.0 RSP aides 5-6 hours per RSP
4.0 SDC/NSH aides 1 aide per SDC class
Soquel Elementary 3.26 FTE SDC aides 1 aides per SDC class
Note: EC 56362 (6)(f) requires at least 80% of the resource specialists within a local plan to be pro-
vided with an instructional aide. It does not require a full-time aide for each resource specialist.
The number of instructional aides in resource specialist/special day class programs at the districts
and the instructional aide staffing for special day classes at the county office are within the
guidelines and/or Education Code requirements and are maintained at an efficient level.
Recommendation
The districts and county office should:
1. Maintain current staffing for instructional aides in RSP and special day classes that align
with industry standards.
50 Fiscal Crisis & Management Assistance Team
COUNTY OFFICE AND REGIONAL PROGRAM STAFFING
Designated Instructional Services
FCMAT reviewed staffing and caseloads for speech and language, adapted physical education,
and occupational therapy services to determine efficiencies.
Comparison of Designated Instruction staffing and caseloads in District/County Office to
the industry standards and/or Education Code requirements.
Program/Provider Average Student Caseload School Services Guidelines
Based on 1.0 FTE
Live Oak School District
Adapted PE .16 FTE @ 17 students 45-55 students
Occupational Therapy
Speech Therapy 51 students 20-35 students*
49 students 55 students
Santa Cruz County Office of
Education
Adapted PE 68 students 45-55 students
Occupational Therapy
Speech Therapy 59 students 20-35 students
42 students 55 students
San Lorenzo Valley
Adapted PE 36 students 45 – 55 students
Occupational Therapy
Speech Therapy 45 students 20-35 students
50 students 55 students
Santa Cruz City Schools
Adapted PE 47 students 45-55 students
Occupational Therapy
43 students 20-35 students
Speech Therapy
45 students 55 students
Scotts Valley
Adapted PE .60 FTE @ 20 students 45-55 students
Occupational Therapy
Speech Therapy 54 students 20-35 students
53 students 55 students
Soquel Elementary
Adapted PE .5 FTE @ 12 students 45-55 students
Occupational Therapy
Speech Therapy .7 FTE @ 44 students 20-35 students
56 students 55 students
Source: District provided data; Guidelines from School Services of California, Inc. 2008
FCMAT found that the caseloads for designated instruction services in the randomly selected
districts and the county office are consistent with the guidelines from School Services of
California, Inc. with one exception. The districts and county office have occupational therapy
caseloads that exceed the SSC guideline; however, FCMAT has found that districts throughout
the state operate closer to caseloads of 55.
Soquel Elementary School District 51
COUNTY OFFICE AND REGIONAL PROGRAM STAFFING
Recommendations
The districts and county office should:
1. Continue following the guidelines for average caseloads from School Services and the
Education Code as appropriate.
2. Work closely with each other to share resources whenever possible, particularly when
caseloads are below standards.
3. Continue using district- or county-office- hired staff and avoid the use of nonpublic
agencies for services.
52 Fiscal Crisis & Management Assistance Team
ONE-TO-ONE INSTRUCTIONAL ASSISTANTS
One-to-One Instructional Aides
There is a general perception among school personnel that districts and the county office overuse
one-to-one aides, particularly for students with autism. California has no industry standards to
compare one-to-one instructional aide usage from district to district or county office; however,
research is available to guide school districts.
The National Research Council performed a thorough review of programs for students with
autism and concluded that “A child must receive sufficient individualized attention on a daily
basis so that the individual objectives can be effectively implemented.” While the council recom-
mended that a student be provided with sufficient individual support and small group instruc-
tion to accomplish his or her goals and objectives, it did not indicate that one-to-one staffing was
required.
Several SELPAs and districts throughout the state including the North Santa Cruz County
SELPA have implemented guidelines for assessing the need for special circumstances instruc-
tional aides. The three main elements of this assessment are as follows:
1. An assessment of the use of classroom supports and accommodations and the level of
success
2. Teacher interviews to determine the need for one-to-one support
3. A transition or “fading” plan to promote student independence over time
A review of SELPA procedure 10460.1 found that it includes assessment and teacher interviews;
but not a “fading” plan during evaluation. The primary objective of one-to-one aide services
should be for the student to achieve as much independence as possible. The SELPA should
expand the procedures of one-to-one aide evaluation to include a section on “fading” that leads
to student independence.
Using a random sample of district SELPAs, FCMAT compared the numbers of students with
one-to-one instructional aides with the percentage of one-to-one aides assigned to students
in each district’s special education program. A separate analysis focused on the number and
percentage of one-to-one aides assigned in the county office. District and county office data were
separated because the student populations were different. The students in county office programs
represent the most severe disabilities that districts are unable to serve. The district data represents
a broader population of mild to moderate disabilities.
Comparative of One-to-One Instructional Aides In Random Districts in North Santa Cruz
County SELPA
School District #One-to-One % of One-to-One aides
Instructional Aides to Special Education Pupil Count
Live Oak School 7 2%
San Lorenzo Valley 15 4%
Santa Cruz City School 33 4%
Scotts Valley 24 10.3%
Soquel Union Elementary 17 8%
Soquel Elementary School District 53
ONE-TO-ONE INSTRUCTIONAL ASSISTANTS
Analysis of One-to-One Instructional Aide Usage in the Santa Cruz County Office of
Education
County Office # One-to-One % of One-to-One aides to special
Instructional Aides education pupil count
North Santa Cruz 33 18%
County Office
The county office has a high use rate for one-to-one instructional aides. Most county office
classes operate at ratio of one adult to two students, however, some classrooms operate at one to
one.
The Chrysalis Center offers a county office program for preschool students with autism. This
program was developed as an alternative to costly nonpublic school placements at the Bay
Center. The ratio of adults to students in these classes is one to one. The Chrysalis Center is
supervised by the county office, and the Morgan Center has a $200,000 contract to advise and
support county office programs. The staffing ratio in the Chrysalis Center mirrors that of the
Morgan Center.
The three programs in question are designed, staffed, operated and supervised by the county
office. The Morgan Center contracts with the county office to provide the county office
administration and classroom staff with ongoing staff development and consultation services in
implementing the Morgan Center model. Morgan Center consultants have no decision-making,
supervisory, or operational role in the county office Chrysalis programs. However, districts per-
ceive that the county office has limited input into staffing ratios.
The administrative staff indicated that this staffing pattern is required for the county office to
provider a defensible autism program. In a review of comprehensive program environments for
students with autism, the National Research Council found that most programs had an adult-
to-student range of ratios of from 1:3 to 1:8. The council also found that a number of programs
“intentionally fade the adult: child ratios across time in intervention, in order to prepare children
to function independently in future sites.”
Recommendations
The SELPA, districts and county office should:
1. Begin to track the number and percent of special education students receiving one-
to-one instructional aides support. The data in the first table above can be used as a
baseline.
2. Track the number of students requiring one-to-one instructional aides that have transi-
tioned away this level of support over time.
3. Expand the procedures for evaluating the need for one-to-one instructional aides out-
lined in SELPA policy to include “fading” as a strategy for increasing independence in
students.
54 Fiscal Crisis & Management Assistance Team
NONPUBLIC SCHOOLS/AGENCIES
Nonpublic Schools/Agencies
Each SELPA district develops and monitors contracts for nonpublic schools and agencies. The
county office operates as a school district member in the SELPA and also develops and monitors
its own contracts for nonpublic schools and agencies. The SELPA has a master contract that is
available to participating SELPA members; however, many districts do not use the SELPA con-
tract. There are no standardized rates for nonpublic schools in the area.
Recommendation
The SELPA should:
1. Encourage the districts to use a common master contract for nonpublic schools and
agencies to ensure continuity in rate structures and common programmatic elements.
Soquel Elementary School District 55
NONPUBLIC SCHOOLS/AGENCIES
56 Fiscal Crisis & Management Assistance Team
TRANSFER OF PROGRAMS
Transfer of Programs
The district and county office have partnered to provide special education services to district-
identified students with severe disabilities and in some cases nonsevere disabilities in county
office programs for many years.
The partnership has succeeded, but not without some difficulties. Several district staff members
indicated they are often unaware of the contents of county office students’ IEPs and do not
attend IEP meetings. In a number of cases, the staff members did not know the students they
were assigned or the services and instruction these students received.
Many severely disabled students served by the county office integrate with the students on the
regular education campus where the program is located. However, this is not a pervasive practice
and is usually prompted by the individual principal and county office teacher(s).
While districts do not receive bill-backs from the county office for services provided to their
students, they are concerned that state aid and federal local assistance may support programs
that are not as cost-effective as those operated by individual districts. Since all funds for program
operation come “off the top,” no state aid is available to help districts with excess costs.
Some districts want to determine whether they should provide some of these services instead of
the county office. As a result, they requested that FCMAT analyze the fiscal effects of pursuing
this course of action. The county office and SELPA recognize these issues and intend to cooper-
ate with the districts in discussing and planning for a possible transfer of programs.
In the 2008-09 fiscal year, the county office provided special education services to 211 disabled
students who were of school age. One-hundred forty-three had severe disabilities, and 68 had
nonsevere disabilities. Removing the 29 students with low-incidence disabilities, FCMAT
estimates that 182 disabled students could be considered for transfer to services provided by the
school districts. Of these, 68 had nonsevere disabilities; 14 with other health impairments; 53
with specific learning disabilities and one with a speech/language disability. Unless these disabili-
ties have resulted in extraordinary educational needs, most of the 68 students could probably be
provided services in district-operated classes. Forty-five of the remaining 114 students exhibited
serious emotional disturbance; 42 were mentally retarded; 21 displayed autistic mannerisms;
and six were multidisabled. This number does not represent the county office’s 46 Early Start
students.
TOTAL NUMBER OF DISABLED STUDENTS
Students That Could Be Transferred
13.7 percent Students with Low-Incidence Disabilities
86.3 percent
Soquel Elementary School District 57
TRANSFER OF PROGRAMS
The North Santa Cruz County Schools may pursue the possibility of serving some or all the 68
nonsevere students, and the districts may serve the 114 students with severe disabilities. If these
changes occur, there should be a high level of openness for all concerned including the parents
of district students in county office programs, the county office and its staff, and district staff.
This will be particularly sensitive since students will be served by another school district. It is
important for parents and school board members to clearly understand the collaborative nature
of these programs.
If North Santa Cruz County Schools moves toward transferring programs, it should consider
hiring one additional full-time program specialist. This individual should have expertise in the
nature and needs of students with moderate to severe disabilities, including autism, emotional
disturbance and behavior management, developmental delays, and medical fragility. In addition,
the program specialist should be knowledgeable in curriculum and program planning for these
students.
The responsibilities of this employee would include planning for program transition, organizing
and/or providing training for district staff, conducting transfer IEP meetings for all students,
monitoring and implementing programs for the students transferred, assisting with CAPA
testing, assisting with classroom behavioral issues, and serving as liaison for any county office
services.
FCMAT conducted an analysis of the comparative budgets, the unduplicated counts of pupils
with disabilities, and other reports from the county office and school districts. The data is as fol-
lows:
District 5001 5710 5730 5750 5770 Total
Unspecified Infant Preschool Severely Nonseverely
Disabled disabled
Santa Cruz COE $8,393.40 $18,301.25 $52,416.16 $36,347.35 $8,438.05 $35,896.37
Scotts Valley $1,809.71 - $15,873.45 $20,697.26 $11,858.00 $15.323.39
Santa Cruz City Schools $3,455.43 - $5,182.06 $34,713.45 $7,218.13 $13,715.49
Bonny Doon $1,087.72 - (6,827.10) $12,894.67 $12,564.09 $12,764.89
Happy Valley $2,133.36 - - - $15,351.02 $12,367.37
Live Oak $2,764.91 - $3,221.13 $4,930.69 $9,772,976 $11.222.26
Soquel $1,700.25 - $7,303.72 $18,076.55 $7,072.00 $10.210.97
Pacific $1,088.01 - - - $8,524.15 $9,156.41
San Lorenzo Valley $3,072,38 - $2,216.02 $13,324.76 $4,820.32 $8,798.71
Mountain $1,204.06 - - - $6,698.14 $7,567.29
In 2008-09, the county office served 278 students with disabilities at a cost of $9,929,190 or
$35,896 per pupil. The districts’ expenditures per pupil ranged from $7,567 to $15,323.
The county office expended $5,197,671 for services for 143 students with severe disabilities for
a per-student rate of $36,347. The other regional program provider, Santa Cruz City Schools,
expended a total of $3,749,053, or $34,713 per student, for its 108 students with severe disabili-
ties. The next highest expenditure-per-student rate for disabled students was Scott Valley with
a cost of $20,697. Compared to Scott Valley, the expenditure rates per severely disabled student
for the two current regional program providers were 176 percent greater for the county office and
58 Fiscal Crisis & Management Assistance Team
TRANSFER OF PROGRAMS
168 percent greater for Santa Cruz City Schools. This strongly suggests that the county office’s
cost per severely disabled student are comparable to that of other providers.
The county office expended $2,233,365 for unspecified support services or $8,393 per pupil,
more than twice the amount per pupil expended by Santa Cruz City Schools. This difference
reflects these student’s needs, which require more labor-intensive services and a greater variety
of related services. In fact, many of these students receive three or more services in areas such as
speech, physical therapy, occupational therapy, adaptive physical education, behavior manage-
ment, health and nursing, and specialized health care. These students also have a higher need for
one-on-one assistance from instructional aides.
When compared to five other county offices, the Santa Cruz County Office of Education’s costs
per student are within the normal range as shown below.
County Office Cost Per Pupil
Ventura $37,160.82
San Joaquin $36,425.96
Santa Barbara $36,075.54
Santa Cruz $35,896.37
Los Angeles $32,763.54
Contra Costa $26,780.00
Student needs will still need to be met even if districts begin providing these services.
Consequently, the districts may see an exponential increase in per-pupil costs. After a transfer
of services, the districts probably will not receive sufficient funding to cover the full impact of
increased costs. In addition, cost containment and consolidation of resources may be hindered if
the programs are distributed throughout the county.
The districts have an insufficient number of appropriately qualified staff members to address the
needs of these students. Staff members that perform related services will be necessary in addition
to qualified teachers of students with severe disabilities such as autism, mental retardation, and
emotional disturbance. Without additional personnel, the current level of speech therapy services
could be insufficient. Other related service personnel such as physical and occupational thera-
pists, adaptive physical education therapists, nursing and specialized services personnel would
also need to be on staff.
The districts have limited direct experience with severely disabled students. In addition to having
qualified special education staff members, districts will need to train their general education
teaching staff to work with these students. Program transfers stand a better chance of success
when all parties are adequately prepared.
If North Santa Cruz County Schools opts for this change, it should develop a long-term plan for
the transfer of program operations for students with severe disabilities. A change of this magni-
tude should not be attempted in one or two years. With thorough preparation, the earliest that
any program should be transferred would be the 2012-13 school year, with the process continu-
ing over two or three years. However, consideration could be given to transferring students with
nonsevere disabilities as early as 2011-12.
Soquel Elementary School District 59
TRANSFER OF PROGRAMS
Recommendations
The district should:
Determine whether the districts can fiscally and logistically provide appropriate programs for
the special-education students to be transferred.
Develop a long-term systematic plan for transferring program operations from the county
office to the districts when appropriate.
Establish and utilize ways for those affected by the transfers to be involved in planning and
implementation, especially parents and teachers.
Develop and implement an appropriate supervision and support system with a sufficient
number of knowledgeable supervisory staff and program specialists.
Develop and adopt the policies and operational regulations/procedures necessary to educate
the transferred students before they are actually transferred.
Preschool Services
In the table titled “Cost per Student Per Student By Goal Summary” above, Goal 5730 rep-
resents the expenditure rate per student for the preschool population. There is clearly a great
disparity among SELPA members regarding these rates.
Services for disabled preschool children were largely provided by the county office in years past,
but school districts gradually assumed a much larger role.
The funds available to provide these services come from the following sources:
• Two federal grants
• Some proportion of the AB 602 base funding based on the relative value of instructional
personnel service units for this population when the J-50 funding model was converted
to the AB 602 funding model
Whatever additional program resources individual providers opt to dedicate to serving this
population
Given the limited nature of the resources and the expanding role that districts are playing in
providing preschool services, North Santa Cruz County Schools should re-evaluate its allocation
of these resources and develop a service design that uses available resources for the benefit of all
SELPA members.
Recommendations
North Santa Cruz County Schools should:
1. Review the current allocation of preschool resources to achieve greater equitability
among the providers.
2. Develop a multiyear plan for districts to assume responsibility for these services while
recognizing that because of some disabilities, the need for regional programs operated by
the county office and/or specified school districts will continue.
60 Fiscal Crisis & Management Assistance Team
TRANSPORTATION
Transportation
Of the 13 SELPA local educational agencies (LEAs), six provide or contract for some special
education transportation services. The five school districts operating their own special education
transportation program are as follows:
1. Live Oak School District, K-8
2. San Lorenzo Valley Unified
3. Santa Cruz City Schools, K-5 and Santa Cruz High School District, 6-12*
4. Scotts Valley Unified
5. Soquel Union Elementary, K-8
*Santa Cruz City Schools and Santa Cruz High School District have a common school board and
administrative support unit.
The Scotts Valley Unified School District contracts for transportation through a private contrac-
tor, Student Transportation of America, STA. The Santa Cruz County Office of Education
incorporates transportation for six students with the same provider, but it does not physically
provide any school bus transportation.
The county office eliminated its in-house transportation program in the 1990s because of escalat-
ing excess-cost charge-backs to the contracting districts, and the districts assumed responsibility
for their own special education transportation. All districts reinstituted or increased existing
special needs transportation support and reclaimed responsibility for their own reimbursement
on the state TRAN report.
All five SELPA districts with special education transportation programs are small to moderate in
size. Most participant districts have experienced declining enrollment and reduced or eliminated
their nonmandated home-to-school transportation programs.
Operations and Efficiency
The county office and six school districts that do not receive a state reimbursement for transpor-
tation and rarely provide transportation services are as follows:
1. Santa Cruz County Office of Education (contracts for six students to receive transporta-
tion through their nonpublic contract provider)
2. Bonny Doon Union Elementary School District, K-6
3. Delta Charter School
4. Happy Valley Elementary School District, K-6
5. Mountain Elementary School District, K-6
6. Pacific Collegiate Charter
7. Pacific Elementary School District, K-6
Soquel Elementary School District 61
TRANSPORTATION
These districts occasionally have students require special education transportation. In that case,
individual arrangements are made that include parent in-lieu contracts, district employee assign-
ments, other parent contracts, and the use of taxi cabs.
The SELPA districts that receive a state reimbursement for home-to-school transportation and/or
severely disabled/orthopedically impaired (SD/OI) students are as follows:
1. Live Oak School District, K-8
2. San Lorenzo Valley Unified
3. Santa Cruz City Schools, K-5 and Santa Cruz High School District, 6-12
4. Scotts Valley Unified
5. Soquel Union Elementary, K-8
Some districts that receive state apportionments for both home-to-school and SD/OI special
education transportation do not provide regular education transportation. However, they protect
this apportionment by claiming their non-SD/OI special education students under home-to-
school state apportionment revenue. This is becoming more common and is acceptable under
California Education Code Section 41850.
Each district supporting a special education transportation program has varying encroach-
ments on the general operating fund. The State Department of Education ceased fully funding
transportation in 1977 and capped LEA reimbursements in the 1982-83 school year. Since then,
school districts have reduced or eliminated their nonmandated home-to-school transportation
programs.
Numerous school districts transport only students requiring transportation as a related support
service according to their Individualized Education Programs (IEPs). Some continue to transport
home-to-school regular education students in small numbers. According to data from the 2008-
09 state TRAN reports, the transportation services of the above five districts encroach on their
general funds by the following percentages:
1. Live Oak School District, K-8=5.7%
2. San Lorenzo Valley Unified=62.7%
3. Santa Cruz City Schools, K-5 and Santa Cruz High School District, 6-12=35.3%
4. Scotts Valley Unified=89.7%
5. Soquel Union Elementary, K-8=22.9%
The special education transportation encroachments of four of the five districts are significant,
with Scotts Valley reaching nearly 90% encroachment. Each school district has curtailed trans-
portation services to minimal levels, with many transporting only their mandated, IEP required
special education students.
Supervisory and vehicle maintenance positions were often reduced or eliminated, and transporta-
tion oversight tasks are performed by other support staff members or by a contractor as in the
case of Scotts Valley Unified. Most SELPA districts providing transportation support services
operate minimal service for only those students requiring transportation service. They have few
options for further reductions.
62 Fiscal Crisis & Management Assistance Team
TRANSPORTATION
The Live Oak and Soquel districts operate with low encroachment percentages. Some SELPA
districts may have had higher state reimbursement amounts then others and may have used their
home-to-school reimbursements to decrease their special education transportation expense using
the approach described above.
Cooperation
Except for a county office transportation program that was disbanded in the early 1990s, there are
few cooperative efforts between districts. While districts such as Live Oak and Soquel combine
extended school year students for efficiency, all five SELPA districts with transportation programs
work independently of one another. The student load factor (the total number of students divided by
school buses reported on the State TRAN report) could be improved through cooperative efforts,
any attempt to create a joint venture would probably be highly resisted by organized labor because of
Senate Bill 1419. This legislation resulted in Education Code section 45103.1, ED45103.1, making it
generally prohibitive to contract with another public or private entity for existing services if these were
not in place before the creation of SB1419 in 2002. However, since Scotts Valley Unified contracts for
all its special education transportation services, other LEAs in the area could competitively respond to
any requests for proposals to perform their transportation requirements.
Scotts Valley Unified is centrally located and close to the more urban area of the city of Santa
Cruz for easy access. Each SELPA district’s buses have a low student load factor. This suggests
a lack of efficiency created by any one district’s inability to sufficiently load its own buses with
students, stay within a reasonable student ride time, and meet county office and district bell
schedules. These schedules all generally start within 30 minutes of each other. The student load
factors for each SELPA district with a transportation program are as follows:
1. Live Oak School District, K-8=7.3 students average per run
2. San Lorenzo Valley Unified=9.0 students average per run
3. Santa Cruz City Schools, K-5 and Santa Cruz High School District, 6-12*=2.7 students
per run
4. Scotts Valley Unified=3.0 students per run
5. Soquel Union Elementary, K-8=10.0 students per run
Scotts Valley Unified should explore potential increased efficiency and savings that could be
attained by contracting with a neighboring school district such as San Lorenzo Valley Unified
or Santa Cruz City Schools. A cooperative contract between Scotts Valley Unified and one other
school district could create increased school bus equipment efficiency for both school districts as
well as result in operational savings for both entities.
Recommendations
The SELPA school districts should:
1. Continue to explore ways to cooperate by assisting each other with transportation needs.
2. Encourage Scotts Valley Unified to determine whether neighboring SELPA districts are
interested in responding to its request for proposal for transportation services.
Soquel Elementary School District 63
TRANSPORTATION
Communication
Communication should be more open and inclusive between the SELPA and its member districts
that provide special education transportation services. Meetings to discuss transportation were
implemented in the past, but ceased as county office leadership changed. Meetings between the
SELPA and its participants should be led by the SELPA and address common interests and chal-
lenges.
Transportation providers are seldom directly contacted to discuss potentially contentious IEPs.
As a result, critical decisions are sometimes made without consulting providers.
Recommendations
The SELPA should:
1. Implement and facilitate a formal SELPA transportation governance committee com-
posed of transportation providers, and schedule regular meetings to discuss common
interests.
2. Involve transportation providers in potentially contentious IEP meetings when key trans-
portation decisions will be made.
County Office and District Special Education Program Bell
Schedules
A review of SELPA district and county office bell schedules for special education programs found
that they all start between 8 a.m. and 8:30 a.m., many between 8 a.m. and 8:15 a.m. Therefore,
the five SELPA districts attempt to provide transportation to the county office and other district
programs within 30 minutes. A staggered bell schedule would allow transportation providers to
use their fleets more efficiently and optimize existing resources, allowing some to reduce routing.
Field interviews indicated that the closeness of county office start times presents a serious chal-
lenge and is a major factor in the inability to increase student load factors on specific bus runs.
Some districts believe they use more buses because they have insufficient time to perform second
or third runs. In addition, reasonable ride times would be exceeded if they attempted to increase
passenger counts to serve several programs starting simultaneously or within 30 minutes of each
other. The SELPA should initiate discussions to determine the benefits of staggering county
office start and end times
The lack of a common calendar between the county office and districts exposes districts to
increased costs. Minimum days with early dismissal times are not calendared collectively. This
prevents districts from saving on labor costs by temporarily ceasing operations when they are not
needed since some programs remain in operation and require transportation.
SELPA districts that provide transportation to county office and district programs keep students
on buses until the program start time because the program staffs will not accept responsibility
until then. Many district and county offices stipulate in their contracts that students are to be
accepted at a delivery time that is 10 to 15 minutes before the start time. This ensures program
minutes are achieved and allows for transportation providers to gain route time for the next tier
or bus run.
64 Fiscal Crisis & Management Assistance Team
TRANSPORTATION
Staggered bell schedules and earlier drop-off times allow for an increased delivery window for
the providers’ next bus run. The SELPA should facilitate discussions with the county programs
to arrange for acceptable program delivery windows. In addition, the SELPA districts providing
transportation services should work with each other to stagger their district bell schedules and
acceptable student delivery times.
Recommendations
The SELPA should:
1. Facilitate discussions on behalf of their participant districts to work with the county
office in staggering program start/end times to best meet the needs of the districts.
2. Work with the county office to implement a reasonable student delivery time that is 10
to 15 minutes before each county-office program start time.
3. Encourage all participant school districts to work with their leadership to cooperatively
design a countywide school district bell schedule.
4. Take the lead in advocating for a countywide master calendar for all SELPA participants.
Soquel Elementary School District 65
TRANSPORTATION
66 Fiscal Crisis & Management Assistance Team
APPENDICES
Appendices
A. Sample Tables and Forms
B. SELPA Funding Model Overview
C. Los Angeles County Office of Education Training
D. Study Agreement
Soquel Elementary School District 67
APPENDICES
68 Fiscal Crisis & Management Assistance Team
APPENDICES
Sample Tables and Forms
Sample Treasurer’s Report
North Santa Cruz County SELPA
Treasurer’s Report
SELPA Revenue and Expenditures
Beginning Balance and Revenue
Beginning Balance, July 1, 2009 $0.00
Revenue $0.00
Less Funding Transfer from SELPA to SCCOE Operated ($0.00)
Programs
Total Beginning Balance and Revenue for 2009-10 $0.00
Expenditures
Computer Software $0.00
I/P Copier Charges $0.00
I/P Advertising (i.e. Position Openings) $0.00
Other Supplies and Operating Expenses $0.00
County/District Contracts $0.00
Medical Services (if applicable) $0.00
Total Expenditures for 2009-10 $0.00
Ending Balance, June 30, 2010 $0.00
2009-10 SELPA Grants and Revenue $0.00
Percentage of Ending Balance to SELPA Grants & Revenue 0%
Soquel Elementary School District 69
APPENDICES
Sample “Off-the-Top” Funding Model Table
Santa Cruz County Office of Education
Off-the-Top Model
Santa Cruz County Office of Dec 1, 2009 Amount Per Total Cost of
Education Pupil Count Student Service
PROGRAM COSTS $0.00
0 $0.00
Severely Disabled (SH) Center
Severely Disabled (SH) Integrated $0.00
0 $0.00
Site
Non Severe (if applicable) 0 $0.00 $0.00
Vocational Education (ATP) 0 $0.00 $0.00
Emotionally Disturbed (ED) 0 $0.00 $0.00
Autism 0 $0.00 $0.00
Early Start Program 0 $0.00 $0.00
Resource Specialist Program (RSP) –
0 $0.00 $0.00
Court Community (if applicable)
FTE of
Amount per
Service
__ FTE
ITINERANT COSTS Provided
$0.00
Adapted Physical Education (APE) 0 $0.00
Speech & Language (SL) 0 $0.00 $0.00
Deaf & Hard of Hearing (DHH) 0 $0.00 $0.00
Orientation and Mobility (OM) 0 $0.00 $0.00
Orthopedically Impaired (OI) 0 $0.00 $0.00
Visually Impaired (VI) 0 $0.00 $0.00
Services Provided by District Dec. 09 Amount Per
Name Pupil Count Student
Deaf & Hard of Hearing (DHH) 0 $0.00 $0.00
(Preschool)
Deaf & Hard of Hearing (DHH) (K- 0 $0.00 $0.00
8)
Deaf & Hard of Hearing (DHH) (9- 0 $0.00 $0.00
12)
Orthopedically Impaired (OI) 0 $0.00 $0.00
Visually Impaired (VI) 0 $0.00 $0.00
Emotionally Disturbed (ED) 0 $0.00 $0.00
Total Student Costs Per District $0.00
before Revenue Offset
Revenue Generated per Pupil $0.00
Revenue Limit $0.00
Lottery Revenue $0.00
70 Fiscal Crisis & Management Assistance Team
APPENDICES
Instructional Materials $0.00
Sub-Total on Revenues Generated by $0.00
Pupil
Adjusted District Student Costs $0.00
Percentage of Special Education
Students being served compared to
total District K-12 ADA
Note: Additional costs currently being paid with Medi-Cal and MAA funds
Uncertain on the future of the continuation of receiving these funds
Over and above excess costs not included in actual costs above
Including but not limited to behavioral specialists, specialized physical health care, one-
on-one nurse support, one-on-one aide - transportation and or classroom support, OT/PT
services, medical consultation and Interpreters
Subject to updates – November 1 and April 1
Soquel Elementary School District 71
APPENDICES
Sample Form for Program Costs
SCCOE Operated Special Education
Chart of Programs/Services 2009/10
Admin Support Costs $0.00
Sub-Total Support Costs $0.00
DIRECT SERVICE COSTS
(Examples: ED & SH) Severely Disabled (SH) SDC $0.00
Vocational Education (ATP) SDC $0.00
Severe & Vocational Education (ATP) Instructional Aides $0.00
Intervention Services $0.00
Intervention Instructional Aides $0.00
RSP Court/Community (if applicable) $0.00
RSP Court/Community Instructional Aides (if applicable) $0.00
Speech $0.00
Speech Instructional Aides (if applicable) $0.00
Audiologist $0.00
Visually Impaired (VI) Itinerant Staff $0.00
Deaf & Hard of Hearing (DHH) Itinerant Staff $0.00
Orientation & Mobility (O&M) Itinerant Staff $0.00
Orthopedically Impaired (OI) Itinerant Staff $0.00
Adaptive Physical Education (APE) Itinerant Staff $0.00
Autism SDC $0.00
Autism Classified Instructional Aides $0.00
Nonsevere SDC (if applicable) $0.00
Nonsevere Instructional Aides (if applicable) $0.00
Early Start Program $0.00
Assistive Technology (AT) $0.00
Out of Home Care $0.00
Physical Therapy $0.00
Special Circumstance Instructional Aides (SCIAs) $0.00
Home Instruction $0.00
DIS Support to Special Day Class
Nurses $0.00
OT Services $0.00
Psychologists $0.00
Specialists $0.00
Extra Help Instructional Aides $0.00
Sub-Total Direct Costs $0.00
Total Administrative Support / Direct Costs $0.00
Contracted Services
72 Fiscal Crisis & Management Assistance Team
APPENDICES
Administrative / Direct Services $0.00
Program Operational Costs $0.00
Total SCCOE Budget $0.00
REVENUES – Revenue Limit $0.00
Preschool $0.00
J-50 Infant $0.00
Infant Part C $0.00
Soquel Elementary School District 73
APPENDICES
Sample Chart for Programs and Services
SCCOE Operated Special Education Programs
Chart of Programs/Services 2009/10
Setting/Program Center Name/Program Name
Administrative Staff FTE
Management Staff 0
Secretarial 0
Fiscal Analyst 0
Costs
Custodial $0.00
CENTER BASED
Staff to Student Ratio Number of Staff
Classes 0
Teachers 0
Instructional Aides 0
Enrollment 0
INTEGRATED SH
Elementary Staff to Student
Ratio
Secondary Staff to Student Ratio Number of Staff
Classes 0
Teachers 0
Instructional Aides 0
Enrollment 0
VOCATIONAL EDUCATION (ATP)
Staff to Student Ratio Number of Staff
Services/Classes 0
Staff/Teachers 0
Instructional Aides 0
Enrollment 0
Nurses ___ FTE
Psychologists ___FTE
Specialists ___FTE
SPEECH/LANGUAGE SERVICES
Specialists 0
74 Fiscal Crisis & Management Assistance Team
APPENDICES
Instructional Aides 0
Caseloads 0
AVG. Caseload 0
**___districts & ___charter schools
SPEECH SPECIALISTS
Autism 0
Caseloads 0
AVG. Caseload 0
Bilingual Assessor 0
AUDIOLOGIST
Caseloads 0
AVG. Caseload 0
VISUALLY IMPAIRED (VI)
Staff/Teachers 0
Instructional Aides 0
Tech Support 0
Caseloads 0
AVG. Caseload 0
DEAF & HARD OF HEARING (DHH)
Staff/Teachers 0
Instructional Aides 0
Caseloads 0
ORIENTATION & MOBILITY (OM)
Specialists 0
Instructional Aides 0
Caseloads 0
ORTHOPEDICALLY IMPAIRED (OI)
Staff/Teachers 0
Instructional Aides 0
Caseloads 0
AVG. Caseload 0
Soquel Elementary School District 75
APPENDICES
ADAPTED PHYSICAL EDUCATION (APE)
Specialists 0
Instructional Aides 0
Caseloads 0
AVG. Caseload 0
*Plus___for SD specially designed program
AUSTISM – SDC
Classes 0
Staff/Teachers 0
Instructional Aides 0
Classified 0
Enrollment 0
EARLY START PROGRAM
Coordinator 0
Certificated Staff 0
Instructional Aides 0
Classified 0
Students 0
ALL OTHER (i.e. PHYSICAL THERAPY, ETC.)
Staff 0
Students 0
Nurses ___ FTE
Psychologists ___FTE
**Speech pathologist support is reflected in the total Speech/Language
Services
76 Fiscal Crisis & Management Assistance Team
APPENDICES
Sample Chart for Summary of Classroom Costs
SCCOE Operated Programs
Summary of Classrooms Costs 2009/10
Center Name - Severely Disabled (SH) Salary
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Number of Classes ___
Total Salary $0.00
AVG Center Salary $0.00
School Name – Severely Disabled (SH) Integrated Sites Salary
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Total Salary $0.00
Number of Classes ___
AVG Integrated Sites Salaries $0.00
Instructional Aides ___ FTE $0.00
DIS Services & Operational costs per Class
Nurses ___ FTE $0.00
Occupational Therapist (OT) Services ___ FTE $0.00
Psychologists ____ days a week $0.00
Speech ___ FTE $0.00
Adaptive Physical Education (APE) ___ FTE $0.00
Low Incidence ___ FTE $0.00
Total $0.00
Severely Disabled (SH) Center Operational Costs $0.00
Severely Disabled (SH) Administration Costs $0.00
Administrator Costs $0.00
Severely Disabled (SH) Center Classroom Cost $0.00
Staff to Student Ratio 0:0 $0.00
Severely Disabled (SH) Integrated Classroom Cost $0.00
Staff to Student Ratio 0:0 $0.00
SCCOE Operated Programs
Summary of Classrooms Costs 2009/10
Soquel Elementary School District 77
APPENDICES
Emotionally Disturbed (ED) Classrooms Salary
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Number of Classes ___
Total Salary $0.00
AVG Class Salary $0.00
Instructional Aides ___ FTE $0.00
DIS Services & Operational costs per Class
Nurses ___ FTE $0.00
Occupational Therapist Services ___ FTE $0.00
Psychologists____ days a week $0.00
Speech Therapists (ST) ___ FTE $0.00
Adaptive Physical Education (APE) ___ FTE $0.00
Low Incidence ___ FTE $0.00
Physical Therapy (PT) ___ FTE $0.00
Total $0.00
Program Operational Costs $0.00
ED/SH Administration Costs $0.00
Administrator Costs $0.00
Program Classroom Cost $0.00
Staff to Student Ratio 0:0 $0.00
SCCOE Operated Programs
Summary of Classrooms Costs 2009/10
Vocational Education (ATP) Salary
Teacher Name $0.00
Teacher Name $0.00
Number of Classes ___
Total Salary $0.00
AVG Class Salary $0.00
Instructional Aides ___ FTE $0.00
DIS Services & Operational costs per Class
Nurses ___ FTE $0.00
Occupational Therapist Services ___ FTE $0.00
Psychologists ____ days a week $0.00
Speech Therapists (ST) ___ FTE $0.00
78 Fiscal Crisis & Management Assistance Team
APPENDICES
Adaptive Physical Education (APE) ___ FTE $0.00
Low Incidence ___ FTE $0.00
Physical Therapist (PT) ___ FTE $0.00
Total $0.00
Program Operational Costs $0.00
SH Administration Costs $0.00
Administrator Costs $0.00
Program Classroom Cost $0.00
Staff to Student Ratio 0:0 $0.00
SCCOE Operated Programs
Summary of Classrooms Costs 2009/10
Autism Classes Salary
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Teacher Name $0.00
Number of Classes ___
Total Salary $0.00
AVG Class Salary $0.00
Instructional Aides ___ FTE $0.00
DIS Services & Operational costs per Class
Nurses ___ FTE $0.00
Occupational Therapist Services ___ FTE $0.00
Psychologists ____ days a week $0.00
Speech Therapists (ST) ___ FTE $0.00
Adaptive Physical Education (APE) ___ FTE $0.00
Low Incidence ___ FTE $0.00
Total $0.00
Program Operational Costs $0.00
SH Administration Costs $0.00
Administrator Costs $0.00
Program Classroom Cost $0.00
Staff to Student Ratio 0:0 $0.00
SCCOE Operated Programs
Summary of Classrooms Costs 2009/10
Early Start Program Salary
Soquel Elementary School District 79
APPENDICES
Teacher Name $0.00
Teacher Name $0.00
Number of Classes ___
Total Salary $0.00
AVG Class Salary $0.00
Instructional Aides ___ FTE $0.00
DIS Services & Operational costs per Class
Nurses ___ FTE $0.00
Occupational Therapist Services ___ FTE $0.00
Psychologists ____ days a week $0.00
Speech Therapists (ST) ___ FTE $0.00
Adaptive Physical Education (APE) ___ FTE $0.00
Low Incidence ___ FTE $0.00
Physical Therapist (PT) ___ FTE $0.00
Total $0.00
Program Operational Costs $0.00
SH Administration Costs $0.00
Administrator Costs $0.00
Program Classroom Cost $0.00
Staff to Student Ratio 0:0 $0.00
80 Fiscal Crisis & Management Assistance Team
APPENDICES
Sample Forms for Special Day Class Loading
.Special Education Class Loading Recap
Month ___, Ending ____
Program Name (Number of Classes)
Site Name: Chrysalis Center (example) Grade Enrollment
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
SUBTOTAL (Max #) Total Enrollment
Program Name (Number of Classes)
Site Name: Santa Cruz City Schools Grade Enrollment
(example)
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
Teacher Name (Class) 0
SUBTOTAL (Max #) Total Enrollment
Number of Referrals
0 Total Referrals enrolled in Moderate/Severe Program
0 Total Referrals not enrolling in Moderate/Severe Program
0 Pending Referrals for Moderate/Severe Program
0 Total Referrals for Moderate/Severe Program
0 Total Referrals enrolled in Autism Program
0 Total Referrals not enrolling in Autism Program
0 Pending Referrals for Autism Program
0 Total Referrals for Autism Program
0 Total Referrals enrolled in ED Program
0 Total Referrals not enrolling in ED Program
0 Pending Referrals for ED Program
0 Total Referrals for ED Program
Soquel Elementary School District 81
APPENDICES
82 Fiscal Crisis & Management Assistance Team
APPENDICES
Soquel Elementary School District 83
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APPENDICES
84 Fiscal Crisis & Management Assistance Team
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APPENDICES
Soquel Elementary School District 85
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APPENDICES
86 Fiscal Crisis & Management Assistance Team
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109
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ADA
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APLES
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01/3/5
desiveR
APPENDICES
Soquel Elementary School District 87
APPENDICES
88 Fiscal Crisis & Management Assistance Team
APPENDICES
Soquel Elementary School District 89
APPENDICES
90 Fiscal Crisis & Management Assistance Team
APPENDICES
Soquel Elementary School District 91
APPENDICES
92 Fiscal Crisis & Management Assistance Team