Oxnard Elementary School District Report

Oxnard Elementary School District Special Education Review November 5, 2009 Joel D. Montero Chief Executive Officer November 5, 2009 Anthony Monreal Ed.D., Superintendent Oxnard School District 1051 South A St Oxnard, CA 93030 Dear Superintendent Monreal: In August 2009, the Oxnard School District entered into an agreement with the Fiscal Crisis and Management Assistance Team (FCMAT) for a study to complete the following: 1. Conduct a comprehensive review of the district’s special education budget, fiscal information, program structure and offerings with an emphasis on program quality and cost effectiveness. 2. Conduct a review of current practices and compliance with laws and regulations, and an assessment of the governance and management structure of the special education division. 3. Data will also be collected and analyzed to frame a set of essential questions or prob- lem statements. Interviews will be conducted with key district staff. A final report will be written and provided to the district also with a board presentation on the findings and recommendations of the special education department This report contains the study team’s findings and recommendations. We trust this information will be beneficial to all concerned. Thank you for allowing us to serve you, and please give our regards to all the employees of the Oxnard School District. 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: Larry E. Reider - Office of Kern County Superintendent of Schools TABLE OF CONTENTS i Table of Contents Foreword ...........................................................................iii Introduction ...................................................................... 1 Executive Summary ......................................................... 3 Findings and Recommendations ................................... 5 Fiscal Review ............................................................................................................................................5 Program Review .................................................................................................................................13 Current Practices and Compliance Review ..........................................................................21 Governance and Management Structure ............................................................................27 Appendix ..........................................................................29 FOREWORD iii 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 adequately 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 dis- tricts could meet their financial commitments on a multiyear basis. AB 2756 provides specific responsibilities 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. 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 Total Number of Studies....................743 Total Number of Districts in CA ..........982 Management Assistance.............................705 (94.886%) Fiscal Crisis/Emergency ................................38 (5.114%) Note: Some districts had multiple studies. Districts (7) that have received emergency loans from the state. (Rev. 1/22/09) Oxnard Elementary School District seidutS fo rebmuN Fiscal Crisis & Management Assistance Team INTRODuCTION 1 Introduction Background Located in Ventura County, the Oxnard Elementary School District has an enrollment of 15,400 K-8 students served at 16 elementary and three intermediate schools. Eight-six percent of the school population is Hispanic with 45.7% indentified as English language learners. The special education population represents 9.6% of the school population. In August 2009, the Oxnard Elementary School District requested that FCMAT assist the district by developing a report on the Special Education Department. The study agreement specifies that FCMAT will perform the following. 1. Conduct a comprehensive review of the district’s special education budget, fiscal information, program structure and offerings with an emphasis on program quality and cost effectiveness. 2. Conduct a review of current practices and compliance with laws and regulations, and an assessment of the governance and management structure of the special education division. 3. Data will also be collected and analyzed to frame a set of essential questions or problem statements. Interviews will be conducted with key district staff. A final report will be written and provided to the district also with a board presentation on the findings and recommendations of the special education department Study Team The study team was composed of the following members: William P. Gillaspie, Ed.D. JoAnn Murphy FCMAT Chief Management Analyst FCMAT Special Education Consultant Sacramento, CA Santee, CA Leonel Martinez Anne Stone FCMAT Public Information Specialist FCMAT Special Education Consultant Bakersfield, CA Mission Viejo, CA Carolyn Nunes FCMAT Special Education Consultant Mission Viejo, CA Oxnard Elementary School District 2 INTRODuCTION Study Guidelines FCMAT visited the district from September 14-18, 2009 to conduct interviews from district staff, collect data and review documents. This report is the result of those activities and is divided into the following sections: • Executive Summary • Fiscal Review • Program Review • Current Practices and Compliance Review • Governance and Management Structure Fiscal Crisis & Management Assistance Team ExECuTIvE SummARy 3 Executive Summary The Oxnard Elementary School District requested that the Fiscal Crisis and Management Assistance Team (FCMAT) study the district’ s special education programs in four areas: fiscal, program, current practices and management structure. The special education program’s encroachment on the general fund was 46.8% in the 2008-09 fiscal year. According to maintenance-of-effort documents, the projected encroachment or contribution from the unrestricted general fund for 2009-10 is 27%. The district plans to use the maximum allowable amount of funds from the American Recovery and Investment Act of 2009 (ARRA) to adjust maintenance of effort for the 2008-09 fiscal year. These funds are one-time monies that must be distributed by the 2010-11 fiscal year. The district has not developed an expenditure plan for these resources. The superintendent and administrators of special education, educational services and business should consider developing a comprehensive expenditure plan for ARRA funds that will not encumber the district in future years and adheres to legal guidelines for appropriate expenditures. Special education’s role and function affect every school and department in the district as well as the administrative structure. The district lacks consistent communication between departments. As a result, departments operate in isolation, creating redundancy and inefficiency. There is no systematic communication for planning, monitoring, goal-setting, and problem-solving, which affects cost-effectiveness and efficiency on many levels. The Special Education Support Program is used to develop Individualized Education Programs (IEPs), but this system does not interface with the district’s Zangle student information system. This creates a serious data management problem for the Special Education Department. Ongoing communication is needed between Special Education and Instructional Technology departments to ensure there is method of allowing information to flow or be integrated between systems. At present, the Special Education Department cannot provide accurate data to the Special Education Local Plan Area (SELPA), district or school sites regarding students and programs. This has hindered the department’s credibility and ability to appropriately plan programs and services. The Special Education Department does not communicate a consistent message about procedures and compliance with state and federal laws. The staff does not meet, so teachers must rely on e-mails for direction regarding procedural changes. No training is provided, and there is no system for monitoring the implementation of procedural change. As a result, a number of procedural problems have prompted serious compliance issues. These include delays in service to students, denial of Free Appropriate Public Education (FAPE), staff members without caseloads, personnel who have no assignments when school starts, and general education teachers who have no knowledge of the disabilities of students in their classes. Oxnard Elementary School District 4 ExECuTIvE SummARy The district should realign its organizational structure to clearly define the position(s) that has overall responsibility for special education, support special education and consult with teachers. This will increase efficiency and effectiveness in the department. Fiscal Crisis & Management Assistance Team FISCAL REvIEW 5 Findings and Recommendations Fiscal Review Budget Development, Monitoring and Review The Oxnard Elementary School District Budget Department is responsible for budget development, monitoring and review of the special education budget. This occurs with little or no involvement from the Special Education Department. As a result, the special education administrative staff does not understand budget development or how to access the financial data to monitor its own department budget. No one in the Special Education Department can enter purchase orders into the software used by the Business Department despite the fact that a clerk had some training in using the financial reporting software. The Special Education staff does not know how to extract preset financial activity reports or create reports using the software. Instead, the staff manually computes and tracks information that is available through the software reporting system. This results in a duplication of effort and inefficient use of district resources. Special Education contracts with the nonpublic schools and agencies and monitors the invoices from those entities. Attendance verification is an essential part of monitoring, and this is also performed manually. In past fiscal years, meetings were scheduled between the Business and Special Education departments; but were cancelled by the Special Education Department because of program needs and IEP attendance at the school sites. This hindered communication between both departments regarding fiscal issues and caused additional issues. For example, the Business Department is not notified of situations in which required costs for special education services are not budgeted. These costs may include such things as pending litigation, nonpublic school/agency placements, or staffing. Effective communication between both departments is essential to making timely budget adjustments. Recommendations The district should: 1. Provide special education administrators with training in budget development and monitoring on the financial reporting software. Oxnard Elementary School District 6 FISCAL REvIEW 2. Provide a special education staff member with training in using the appropriate financial reporting software. The district should also ensure the software is used to enter all invoices and purchase orders, monitor budgets, and extract or develop financial reporting requirements. 3. Streamline the system for monitoring student attendance for nonpublic schools and agency services. 4. Hold required monthly meetings that include the Special Education and Business departments. The agenda for these meetings should include the following: a. Budget development b. Budget monitoring c. Maintenance-of-effort reporting d. Extended school year e. Nonpublic school (NPA)/nonpublic agency (NSA) contracts, including individual service contracts and monthly invoices. f. Additional staff requests g. New NPS/NPA placements, county office placements, upcoming due process or complaint issues. Due Process The Individuals with Disabilities Education Act (IDEA) provides for mediation and due process to resolve disputes related to the education of children with disabilities. This is to ensure that each child receives a Free Appropriate Public Education (FAPE) tailored to his/her unique needs. In the 2008-2009 fiscal year, two due-process cases and two California Department of Education complaints were filed against the district. All four cases resulted in settlement agreements costing the district considerable dollars. The cost to resolve these disputes was $46,186, and this amount does not include staff time or legal fees for the district’s attorney. The documented issues that initiated these cases were as follows: • Nonresponsiveness to parent requests • Denial of FAPE • Not providing the parent with appropriate documentation when denying assessment Corrective actions to resolve these issues included the following: • Providing staff training • Holding IEP meetings Fiscal Crisis & Management Assistance Team FISCAL REvIEW 7 • Providing additional assessments • Providing additional services • Paying legal fees to the parent’s attorney or advocate Fewer due process cases and complaints are filed against Oxnard Elementary than would be expected for a district of this size. This statement is based on data from other FCMAT reviews and informal surveys of SELPA directors. Although these particular issues were resolved, it is important to monitor these types of events to avoid similar problems with other special education students. The district participates in the Special Education Self-Review this year and can use this opportunity to monitor these issues and avoid systemic compliance problems. Recommendations The district should: 1. Use the self-review to determine whether the issues resolved in the settlement agreements occur with other district special education students. If so, these issues should be resolved with procedural change, staff development and monitoring. Nonpublic Schools (NPS) A nonpublic school is nonsectarian, certified by the State Department of Education, and under contract with the district to provide the appropriate facilities, special education, and designated instruction services that are required by the individual with exceptional needs when no appropriate public education program is available. Oxnard Elementary contracts with five nonpublic schools. The districts’ anticipated total cost for students attending a nonpublic school is $547,522, which is less than most districts of similar size based on other FCMAT studies and informal surveys of SELPA directors. Only .2% of special education students attend a NPS. Twenty-six preschool and kindergarten students are housed at one facility. The estimated cost to educate these 26 students at the nonpublic school is $212,850 for the 2009-10 fiscal year. With this number of students in one program, it may appear beneficial for the district to begin operating a comparable program. However, it may be more efficient and educationally appropriate to continue the current placement. In determining the cost effectiveness of operating district programs, the assistant superintendent of educational services, the Special Education Department, and the Business Department should consider the availability and cost of the following: • Facilities • Appropriate credentialed and certificated staff Oxnard Elementary School District 8 FISCAL REvIEW • Support staff and administration • Materials • Transportation Eight district students also attend four different nonpublic schools. Although the students’ disabilities differ, they all have significant behavioral issues. The IEP team determined that these issues required services that could not be provided by the district. The estimated cost for these eight students is $334,672 for the 2009-10 school year. The number of students attending the four nonpublic schools is insufficient to develop a district program. The special education manager attends IEP meetings for these students and included general transition language in their IEPs. However, the IEPs do not include a comprehensive plan to return students to a district program. Recommendations The district should: 1. Continue attending every IEP meeting for students placed in a nonpublic school to monitor the appropriateness of placement and services. 2. Schedule a meeting with the appropriate district administrators to determine the cost per student of providing a district program for the 26 preschool and kindergarten students. Determine when it would no longer be cost-efficient and educationally appropriate for the district to continue contracting with the NPS. 3. Develop and include in the IEPs of the eight older students a detailed plan for each student to return to a district program. Nonpublic agencies (NPA) Nonpublic agencies are certified by the State Department of Education, nonsectarian, and under contract with districts to provide the appropriate special education designated instruction and services. These services are required by the individual with exceptional needs when no appropriate public education program/service is available. Nonpublic agencies may provide services in areas such as occupational therapy, speech therapy or behavior. The district has five nonpublic agency contracts for students, providing the following: • Services to a student with a cochlear implant • Training for teachers who work with deaf/hard-of-hearing students • Occupational therapy sessions Fiscal Crisis & Management Assistance Team FISCAL REvIEW 9 • Mental health prereferral services • Inclusive education support and training The total cost of these NPA agreements is $112,955. Based on other FCMAT reviews and informal surveys of SELPA directors, the number of contracts and total cost are less than than most districts of similar size. Recommendations The district should: 1. Monitor each of nonpublic agency contracts to ensure that these services cannot be provided by either the current staff or additional staff members if this option would be cost-effective and educationally beneficial. Transportation Most special education students are expected to utilize the same methods as their peers without disabilities to travel to and from school. However, some special education students require specialized transportation. When this occurs, transportation is included in the student’s IEP as a related service. Specialized transportation is provided as a related service when the following criteria are met: • The student’s special day class (SDC) program is not located at the home school and no regular education buses available to transport the student. • The student is in a wheelchair and requires a specialized bus. • The student is unable to ride the regular education bus because of other issues outlined in the IEP. The Special Education Department has a specific form that is completed by the student’s case carrier when the IEP team determines that transportation is a related service. This form is forwarded to a clerk in the Special Education Department, who verifies information and forwards it to the Transportation Department. Transportation arranges boarding and delivery and contacts the school and the family. FCMAT found that it is highly unusual for transportation service to be removed from an IEP once it is included on the document. The initial request form is not completed yearly although the IEP team addresses transportation needs at every annual IEP team meeting. The Transportation Department transports 325 of the 400 students who are in special day classes. The statewide average for specialized transportation is 10-12% of the total special education count. Oxnard transports approximately 21% of special education students. This higher percentage may be due to the following factors: Oxnard Elementary School District 10 FISCAL REvIEW • SDC classes are located at various sites in the district, and students may need to be transported from their home school to access the program. • Once transportation is included on a student’s IEP, it is not removed even when the student no longer requires specialized transportation. The district provides transportation directly or through a contract with Durham Transportation Company. Only six routes are considered as being exclusively for special education transportation. Three routes are exclusively for regular education and 25 are a combination of regular and special education. The district receives $218,000 for specialized transportation and expends the same amount. It is important for all special education costs to be budgeted to special education. In some cases, a student receiving transportation services moved and notified the Transportation Department, which modified its schedule accordingly. However, neither the school nor the Special Education Department was notified about the address change. This has not occurred when a student moved from the district. Recommendations The district should: 1. Review the placement of all special day classes and assignments to ensure that all SDCs student are placed as close as possible to their home schools. 2. Develop a policy that clearly specifies when a student can ride the regular education bus and when transportation is no longer considered a related service. 3. Review with all case carriers the eligibility criteria for the related service of transportation. 4. Require that the request for transportation forms be completed at every annual IEP. 5. When appropriate, ensure that the IEP for a student receiving specialized transportation includes goals to enable the student to travel to and from his or her school in the same manner as their peers without disabilities. 6. Evaluate the way special education transportation costs are allocated to ensure that all costs are budgeted to special education. 7. Develop a method of communication between the school sites, Special Education and Transportation so that all address changes for student boarding and delivery are immediately transmitted to all three entities. Fiscal Crisis & Management Assistance Team FISCAL REvIEW 11 Medi-Cal/MAA The Medi-Cal Administrative Activities (MAA) Program offers federal reimbursement for a portion of the costs related to specific, approved activities. These activities must be necessary for the proper and efficient administration of Medi-Cal and for specific special education services to students. The district bills for both through a private vendor. The district also has a collaborative that reviews the income received from these two sources and advises the district on how income should be distributed. The collaborative is required in the regulations. The collaborative and the previous administration determined that the district would take a conservative approach to Medi-Cal billing by restricting this practice to IEP students. The collaborative also decided that funds received would be expended for counselors and outreach specialists. Neither of these are billable positions for Medi-Cal. Recommendations The district should: 1. Review the composition of the collaborative so that the current administration knows the members and the collaborative knows its defined roles. 2. Review with the collaborative all Medi-Cal funding options to determine whether the district can bill in any other areas. 3. By the first day of school, provide all staff members that can bill for MAA with a calendar showing when MAA documentation is collected. 4. By the first day of school, provide all staff members that can bill for MAA with information regarding activities that qualify under MAA regulations. 5. Review how funds from these two sources are expended to determine whether the current method is the most effective one or whether funds can be expended to generate additional dollars. Oxnard Elementary School District 12 FISCAL REvIEW Fiscal Crisis & Management Assistance Team pROGRAm REvIEW 13 program Review Communication County and school district superintendents, school principals and general educators from throughout the state are playing a larger role in special education. The reasons include to ensure all students receive an effective education and to monitor expenditures from the general fund. Communication and collaboration between all schools and departments is essential to ensure fiscal efficiency. Oxnard Elementary has systemic inconsistencies in communication between departments at the district level, and there are no systems to facilitate collaboration. The district does not make it a priority to hold regular meetings between departments. Scheduled meetings are often cancelled because of other priorities. The special education director does not have read-only access to human resources or business systems. The Special Education Department frequently experiences several problems in attempting to provide accurate data to other departments. However, efforts to work with the Instructional Technology Department to correct these problems have been limited. The district has had three directors of special education in the last three years, and the position is unfilled at present. Staff members are concerned about the high turnover in this position. The frequent change of leadership has also has led to inconsistent practices and procedures as well as eroded confidence in the district’s vision regarding special education. Special education roles and responsibilities are unclear. For example, confusion arose recently over who heads special education and who implements and oversees the core curriculum for special education students. Staff members indicated they received conflicting information from different people in the department. Recommendations The district should: 1. Ensure that routine meetings are held that include the Instructional Technology and all department leads that have student data needs and responsibilities. These parties should develop routine student data reports, and provide leadership to ensure all district data is accurate. 2. Clearly define the roles and responsibilities of the special education staff and school site principals. Oxnard Elementary School District 14 pROGRAm REvIEW 3. Ensure the designated administrator in special education holds the staff members under his or her supervision accountable and provides them with the necessary support. 4. Establish monthly meetings with the Curriculum and Assessment departments to ensure that special education students access the core curriculum and that there is an ongoing plan for staff development for special education teachers in this area. 5. Consider including the special education administrator in the cabinet on a regular or as-needed basis to improve overall communication. 6. Ensure that the Special Education Department is held accountable for sending a consistent message regarding procedures and guidelines and responsiveness to school sites. Culture Staff members from throughout the district indicated that special education is considered to be separate from general education and lacks support from a few principals. The staff receives little training on behavior management and other pertinent issues. As a result, students with behavioral or academic issues are referred to and placed in special education. District personnel at all levels also indicated that special education students are never transferred from the program. FCMAT reviewed the identification rates for the district’s K-8 students using data submitted to the Special Education Local Plan Area (SELPA). Preschool students are not included in this calculation. The data was compared with state statistics and indicates that the district does not overidentify special education students. However, this analysis does not address the disproportionate number of English learner students in special education. Special Education Identification Rates School Year (K-8) Enrollment % SPED Oxnard %% SPED State 2006-07 1492 9% 10% 2007-08 1428 9.3% 10.3% 2008-09 1350 9.6% 10% Additional concerns about the number of English learners receiving special education focus on delays in academic skills. The English Learner Services Department provided a detailed analysis of the number of district students who are English learners and receive special education as shown in the following table. Fiscal Crisis & Management Assistance Team pROGRAm REvIEW 15 The data indicates that half the school population and 55% of special education students are identified as English learners. Because of significant issues regarding the accuracy of special education data, FCMAT was unable to determine whether the district overidentifies English learners for special education. However, the information in the following table indicates that some schools indentify more English learner students for special education than others. Review of English Learner Students Represented in Special Education by School School Percentage of EL Percentage of special education in total school students that are ELs Brekke 46% 55% Chavez 67% 68% Curren 58% 58% Drillfill 69% 82% Elm 72% 38% Frank Intermediate 35% 58% Fremont Intermediate 24% 45% Harrington 64% 89% HaydockIntermediate 23% 38% Kamala 67% 60% Lemonwood 69% 56% Marina West 46% 49% Marshall 34% 45% McAulife 27% 32% McKinna 70% 88% Ramona 78% 72% Ritchen 33% 32% Rose Ave 51% 64% Sierra Linda 48% 50% Note: This chart was prepared by the district EL Department using special education numbers from the end-of - year (08-09) printouts and English learner percentages taken from the 08-09 R-30 report Recommendations The district should: 1. Define the role and mission of special education so that they align with the district philosophy. The district should also determine how programs and services will be developed, supervised and supported. 2. Define the roles of principals and the special education staff. 3. Consider initiating strategic planning that includes all affected parties to clearly define special education’s roles in the district structure and eliminates barriers that separate the general and special education populations. Oxnard Elementary School District 16 pROGRAm REvIEW 4. Review the special education data in the area of speech and language to determine whether English-learner students are overidentified as speech impaired. This will not be possible until the district can produce accurate special education data. . 5. Provide speech therapists with training to ensure that entrance criteria are not biased for English learners. Academic Performance Index (API) The API is a single number that ranges from 200 to 1000 and reflects a district or subgroup’s academic performance level based on the results of statewide testing. Its purpose is to measure the academic performance and growth of schools or subgroups. Special education in Oxnard Elementary meets the criteria of a subgroup for API calculations. FCMAT used this data as one measure to examine program quality. A review of the 2008-09 Growth Performance Index Report from the California Department of Education indicates that special education students as a subgroup of the total school enrollment did not demonstrate growth for this school year. However, the subgroups of socioeconomically disadvantaged students and English learners demonstrated growth for that year. This data will assist the district in developing a plan to address program development for the district’s special education programs. State Accountability Academic Performance Index (Oxnard Special Education) Subgroup Number of Students 2009 2008 Base 2008-09 Included in API Growth Growth Socioeconomically 8,921 690 681 9 Disadvantaged English Learners 6237 669 653 16 Students with 1000 554z 569 -15 Disabilities Some district schools met the growth target for API. A breakdown of district and school performance in this area was provided by the California Department of Education and is attached as Appendix A to this report. Student access to the core curriculum can contribute to student performance on statewide testing. Some staff members indicated that special education students do not have access to the core curriculum for the following reasons: . • The district lacks a uniform system of supports for special education teachers using the core curriculum. • Staff development has not been provided for special education teachers in differentiated instruction within the core curriculum. Fiscal Crisis & Management Assistance Team pROGRAm REvIEW 17 • There is no accountability for use of the core curriculum in special education class. • Some schools have limited access to core curriculum materials. Recommendations The district should: 1. Review the API growth target included Appendix A, which is attached to this report, and meet with principals to discuss strategies on how to help special education students meet these targets. 2. Closely evaluate the schools that met growth targets in special education and determine to what extent access to the core curriculum was an issue. 3. Provide the special education staff with the necessary support and staff training in core curriculum areas. Management of Student Information Effective special education programming requires a thorough understanding of the data provided by the California Special Education Management Information System (CASEMIS). This system provides critical information on identification rates, exit rates, growth in specific disability areas, comparative data on special education enrollment by district, by county and the state. CASEMIS information is also used by the California Department of Education’s Special Education Department to measure a district’s annual performance on critical requirements in federal law for students with disabilities. A copy of the district’s most recent Annual Performance Measure is attached as Appendix B to this report. Because of technological difficulties, the accuracy of the current information the district provided to CASEMIS is in question. There are a number of issues concerning the systems used by the Special Education Department to gather student information that ultimately is exported to CASEMIS. These issues are as follows: • There is no interface between Zangle (the district student information system) and SEPS (the electronic IEP system used in the SELPA), resulting in data inconsistencies and decisions based on inaccurate numbers, which also affects staffing decisions. • Both Zangle and SESP data must be manually entered into CASEMIS software, which increases the possibility inaccuracy. The school and central office staffs are unable to identify the number of students receiving special education services Oxnard Elementary School District 18 pROGRAm REvIEW and their site locations, resulting service delivery delays. If the district could ensure that IEP information moved into CASEMIS and Zangle through the system it would be possible to eliminate one clerical position at an average savings of $30,000. • The district staff is unclear about the process and procedures required for data entry. The staff members assigned with this duty have not had adequate training, complicating the problem. • Because of the lack of interface and the electronic IEP inaccuracies in student demographic data, the letters sent to parents are frequently returned. • The special education staff can update demographic information in SESP, and this data is reportedly uploaded to Zangle but there is no indication that it is verified in the latter system. • Several district staff members collect and enter student data, resulting in fragmentation and the potential for inaccurate information. Recommendations The district should: 1. Work with the SELPA to ensure that information from the computerized IEP system does not have to be manually entered into either CASEMIS or Zangle. 2. Develop and provide the staff with training on appropriate processes and procedures for handling student data. These processes and procedures should be followed until an interface is developed between Zangle, SESP and CASEMIS. 3. Ensure that reports are generated and student information is matched to confirm that students are accurately accounted for in each student information system, and that accurate data is used for articulation planning. This process should be followed until an interface is developed between SESP and Zangle. 4. Provide the staff with training in using icons in the Zangle student system to identify students with current IEPs. 5. Ensure that the Instructional Technology Department works closely with the SELPA and the Special Education Department to develop an infrastructure for the interface between Zangle and SESP. 6. Provide staff members with training to ensure that accurate student data is entered until the interface is developed between Zangle and SESP. Fiscal Crisis & Management Assistance Team pROGRAm REvIEW 19 7. Ensure that all demographic information is entered only into Zangle when the interface is developed and that access to the related fields in SESP is prohibited. 8. Develop procedures to ensure that hard copies and electronic copies of IEPs match. Caseloads The ratio of district psychologists to students is 1:1,184. The ratio of psychologists to students based on the 2007-08 CBEDS count is 1:1,328. Aligning the psychologist ratio with the guidelines in the CBEDS could eliminate one psychologist for costs savings of approximately $96,000 per year. The statewide average ratio for nurses is 1:2,219. The district’s ratio is 1:5,183. In addition to general education duties, the nurses perform assessments, supervise and train unlicensed personnel to provide specialized health care, and provide training for special education students in specialized procedures. The district should re-evaluate its current staffing ratio in this area. The districtwide average of Adapted Physical Education (APE) caseloads is 26. Districts generally operate with average caseloads of 55 in this area. The district employs two full- time APE teachers and should consider eliminating one position for a potential savings of $68,596 per year. Recommendations The district should: 1. Consider eliminating one psychologist position to align this ratio with the common statewide practice. 2. Consider eliminating one APE teacher position to align this ration with the common statewide practice. 3. Re-evaluate the nursing ratio and consider alignment with the common statewide practice. Oxnard Elementary School District 20 pROGRAm REvIEW Fiscal Crisis & Management Assistance Team CuRRENT pRACTICES AND COmpLIANCE REvIEW 21 Current practices and Compliance Review Student Study Teams (SST) IDEA is a federal education grant program enacted in 1975 to improve educational opportunities for children with disabilities. When it was reauthorized in 2007, concerns were raised about the method of identifying children for special education services. Instead of initiating early intervention, the model essentially waited for a child to fail before he or she was identified for services. As a result, IDEA 2007 emphasized early intervention for all at-risk students. New models of SSTs have emerged as data driven-methods of assessing student needs, providing research-based interventions, performing ongoing monitoring and promoting increased student achievement for students at risk. The SST is a function of general education at each school site and includes several members from the school such as the principal, psychologist, general education teachers and parents. The district is considering changing the SST process to align with reauthorized approaches to early intervention outlined in IDEA. Twelve sites were trained starting in 1999, but no recent training has been provided. Schools have experienced turnover among principals and other staff members since then. SST meetings are held at school sites, but processes and procedures are inconsistent. No one at the district level monitors SST implementation. Staff members indicated that in most cases, the SST reviews accommodations and determines whether a child should be referred for special education. The staff considers SSTs to be the method of placing students in special education. Students with behavioral issues are often referred to special education because the school site staff does not believe it has the skills, support or responsibility to serve these students. Recommendations The district should: 1. Provide the schools with clear guidelines on the purpose and methods of the new SST model. 2. Provide the school staff with training on the guidelines. 3. Schedule ongoing trainings so that new staff members are appropriately trained. Oxnard Elementary School District 22 CuRRENT pRACTICES AND COmpLIANCE REvIEW 4. Monitor the process to ensure that SST meetings occur at the school sites by regu- larly collecting data from each SST team. This data should include the following: • The number of students discussed at the meetings • The interventions that each student was given • The number of students that were assessed for special education • The number of English-learner students that were referred for special educa- tion • The number of students assessed that qualified for special education. 5. Use the data from the monitoring system to enhance the SST process. 6. Provide training in behavioral techniques that are both schoolwide and classroom specific so that teachers are more confident in their skills to handle difficult stu- dent behavior. Staff Development Staff development opportunities for special education teachers, support staff members and general education teachers are inconsistent throughout the district. Some training has been provided to school teams implementing the “push in model.” This is a collaborative model of service delivery for special education services in the general education classroom. General education teachers have been trained to manage difficult students, meet special education regulations and comply with state and federal law. Staff meetings are scheduled for all special education teachers, psychologists and speech therapists; however, these meetings did not occur in the 2008-09 school year. These meetings are not mandatory because they occur outside the contract school day for some teachers. No surveys regarding staff development activities were sent to teachers this year. The SELPA provides an extensive list of training sessions for special educators, parents and regular education teachers. The district paid for any staff members who attended. However, it is unclear how parents who cannot afford the training fees are provided with the opportunity to attend. There was no system to share information learned from the training with other staff members. Fiscal Crisis & Management Assistance Team CuRRENT pRACTICES AND COmpLIANCE REvIEW 23 Recommendations The district should: 1. Conduct a survey of administrators, special educators and general education teachers to develop appropriate staff development activities. 2. Provide staff development at the monthly staff meetings. 3. Address staff requests for training in the following areas: • Response to Intervention • SESP (the electronic IEP system used in the district/SELPA) • Writing a compliant IEP • Differentiated instruction 3. Provide general education teachers with staff development in areas such as disability awareness, special education requirements, behavior management, dif- ferentiated instruction and data management. 4. Utilize staff members who attend SELPA trainings as trainers so that information can be disseminated throughout the district. 5. Develop a plan to ensure that time is dedicated for providing staff development for special education in instructional methodology and procedural compliance. 6. Consider time banking as a method of uniformly allotting time in the school calendar to release teachers for training. Having minimum days would be another option. Parent Communication Every district in the Ventura County SELPA is required to have a parent representative on the Community Advisory Committee (CAC). This individual is selected by the district and approved by the school board. Although a parent attends these meetings, there is no record that the board took action to approve this parent for the 2009-10 school year. Oxnard Elementary School District 24 CuRRENT pRACTICES AND COmpLIANCE REvIEW The district lacks a formal process for communicating with the parents of special education students. There are no parent forums and opportunities for parent training. Information regarding special education services, process and procedures is not provided to parents in a clear, consistent manner. The staff expressed concerns that parents may not understand their children’s rights regarding special education. The lack of communication was evident event for preschool students called the “Roundup,” which was held to screen preschool students who were referred to the preschool assessment team. In some cases, a full assessment will be completed at a later date. The meeting, which involved 23 families (with siblings), took place in a small classroom, but no one was there to direct families or explain the process. As a result they waited for hours as the children were called one at a time for prescreening. The assistant superintendent finally assigned district administrative staff members to organize the flow of students and families. Translation of IEP documents and reports are not provided to parents in a timely manner. Recommendations The district should: 1. Recommend to the board a parent representative to serve on the Ventura County SELPA. 2. Provide forums for parents to air their concerns on communication and develop strategies to provide more effective communication. 3. Develop a user friendly parent handbook to help parents in understand their child’s procedural rights. 4. Ensure that the program specialist is readily available to parents by phone or home visits to assist in communication. 5. Streamline the process for translating IEP documents and established parameters for completion. A time line of approximately seven to 10 days is recommended. Fiscal Crisis & Management Assistance Team CuRRENT pRACTICES AND COmpLIANCE REvIEW 25 6. Reorganize the preschool screening process. The district should consider having phone conferences with parents to review referrals and qualify students for the prescreening. A staggered schedule should be used to provide parents with a defined time frame for the screening. Staff members should be on site to address parent questions or concerns. Procedural Review Messages from the district to the school site administrators and staff are often inconsistent. Changes in procedures are sent to all staff members by e-mail without providing training or a process for monitoring implementation. FCMAT found that phone calls and e-mails are not returned in a timely manner, which has led to a lack of confidence in district administration and frustration among the staff at all levels. Because of the problems with data management in special education, teachers do not obtain their class lists in a timely manner. Three resource specialist teachers had no students assigned to them at the time of this review. During the 2008-09 school year, grade levels were changed in the special day classes and as a result teachers, did not know their grade-level assignments until they returned to school in August. General education teachers do not know that they have special education students in their class until four weeks after school starts. Even then, they receive only a list of names and no information on student needs or disability. There are significant delays in placements for students transferring to the district. It sometimes takes up to three or four weeks for a new student to be placed. These issues can create compliance concerns. Students with disabilities are entitled to a FAPE. It is well documented that the current database system for managing student information in special education is ineffective, and this is addressed by FCMAT in this report. However, the district must make it a priority to address delays in service to students with IEPs, the lack of critical instructional information for teachers, inconsistent procedural guidance and the absence of important IEP information for general education teachers. Recommendations The district should: 1. Ensure that special education administrators participate in meetings with princi- pals to provide updates regarding any new information related to special educa- tion and review any procedural changes. Oxnard Elementary School District 26 CuRRENT pRACTICES AND COmpLIANCE REvIEW 2. Ensure that the special education administration provides consistent, clearly articulated and written procedural clarification regarding procedures. 3. Require special education administrators to provide teachers with class lists before the end of the school year. This notification should be provided either in person, in writing or documented via an e-mail receipt. 4. Develop procedures to ensure all general education teachers are informed about the IEP and disability area for the students they serve. A RSP at each school should meet with the general education teacher and review the IEP of each stu- dent. 5. Post the procedural handbook on the district Web site for quick access by all staff members. All procedural changes should be available in a timely and consistent manner but only after appropriate training and support have been provided. 6. Ensure that new students are placed in special education programs in a timely manner. Fiscal Crisis & Management Assistance Team GOvERNANCE AND mANAGEmENT STRuCTuRE 27 Governance and management Structure In reviewing the top administrative positions in the Special Education Department, FCMAT focused on ways to ensure consistent procedural accountability and oversight to restore confidence. The administrative duties in special education administration are divided by three positions. It is unclear who is in charge since conflicting messages are sent to the staff on this issue, and there is a lack of responsiveness to the school site staff. This has created an overwhelming sense of frustration on the part of the district and site staff. There is no clear vision for special education programs and services, and this has led to programmatic inconsistency. SDC class formation, caseload dissemination and the dissemination of critical program and instructional information for general and special education do not occur until one month after the start of school. The administrative resources in the Special Education Department should be redesigned to provide greater efficiency in direction and support to school sites and parents. Special education must take a leadership role and assume overall responsibility for program design, and curriculum standards. The district should consider the most effective organizational structure, and the appropriate staff to implement and manage the structure. A realignment of the special education organizational chart must clearly define the position in charge of special education, the position that supports special education and the position that consults and supports teachers. The position should meet the following criteria for successful reorganization: 1. A proactive approach and the ability to participate actively with other departments 2. Knowledge and experience in special education (instruction, curriculum, laws) 3. Strong communication skills 4. The ability to take initiative and interact with other departments and understand the value of this coordination. These abilities are important because special educa- tion touches all departments. 5. Strong organizational skills with consistent follow-through 6. Honesty and integrity 7. A collaborative leadership style Oxnard Elementary School District 28 GOvERNANCE AND mANAGEmENT STRuCTuRE Recommendations The district should: 1. Continue assigning oversight of special education to the director of pupil services under the direct supervision of the assistant superintendent of education services 2. Continue assigning direct responsibility for special education to the director of special education. 3. Maintain the program specialist position as a direct support role to school sites and principals. The program specialist should be bilingual to better assist parents and students. 4. Consider realigning the administrative duties outlined the following table. Realigned Duties for the Special Education Administrative Department Director of Pupil Services Director of Special Education Special Education Program Oversight Principal San Miguel Special Education Section 504 Evaluation of special education staff in cooperation with principals BART 6-8 Overall Special Education Services Response to Intervention (RTI) Transportation for Special Education Juvenile Court Schools Nonpublic Schools and Agencies Williams Textbooks SDC Class Placements Psychologists Autism Programming Nurses Inclusion Program Student Study Teams (SST) Instructional Aides Expulsion/Suspension IEP/Development/Monitoring Home Instruction Staff Development SARB Principal Support Interdepartmental Communication Fiscal Crisis & Management Assistance Team AppENDIx 29 Appendix A. Study Agreement Oxnard Elementary School District 30 AppENDIx Fiscal Crisis & Management Assistance Team AppENDIx 31 Oxnard Elementary School District 32 AppENDIx Fiscal Crisis & Management Assistance Team AppENDIx 33 Oxnard Elementary School District 34 AppENDIx Fiscal Crisis & Management Assistance Team