Rialto Unified School District Report

Rialto Unified SchoolDistrict Special Education Review January 21, 2014 Joel D. Montero Chief Executive Officer January 21, 2014 Mohammad Z. Islam, Acting Superintendent Rialto Unified School District 182 East Walnut Avenue Rialto, CA 92376 Dear Superintendent Islam, In June 2013, the Rialto Unified School District and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for a review of special education. Specifically, the agreement stated that FCMAT would perform the following: Fiscal 1. Determine the district’s encroachment on the general fund and make recommen- dations for greater efficiency. 2. Examine the costs for Nonpublic Schools and Agencies and make recommenda- tions for greater efficiency. 3. Review the costs for all special education programs and services for students placed outside the district, and explore the cost effectiveness of developing program options within the district. 4. Review the due process requests and costs over the past three years and provide strategies for reduction in overall costs and requests. 5. Review the SELPA’s plan for the provision of mental health services pursuant to statutory requirements to transfer mental health services from county mental health to the district and review both the fiscal and programmatic impact. 6. Review the process and procedures for LEA Medi-Cal reimbursements and expen- ditures and make recommendations for greater efficiency. Special Education Transportation 1. Review the overall transportation special education delivery system, including but not limited to the role of the Individual Education Plan (IEP), routing, sched- uling, operations, staffing and cost containment. Fiscal crisis & ManageMent assistance teaM Program Efficiency Communication 1. Examine district infrastructure supporting special education programs and Parent Communication determine readiness to expand program capacity if needed. 1. Review the communication and problem solving models for parents to 2. Review the current organizational structure of the special education depart- build solid trusting relationships with the special education department. ment and compare with comparable size districts. Make recommendations to 2. Provide an analysis of parent input regarding the opportunities for parent ensure effective clerical and administrative efficiency. input into program and service development, district outreach and parent 3. Review the staffing assignment process for certificated and classified staff communication that currently exist and make recommendations for including tracking of resources, monitoring caseloads, position control and improvement, if needed. make recommendations for improvement if needed. 3. Review the current options for training available in the district for parents 4. Review the district’s philosophy, programs and procedures in special education of students with disabilities. to determine whether they are consistently aligned with the district’s mission 4. Review the district website link for special education and make recom- and beliefs and compliance with statutory regulations. mendations for improvement if needed to provide strength to the parent 5. Provide an analysis of all staffing ratios, class and caseload using statutory district relationship in special education. requirements for the provision of mandated special education programs and Interdepartmental Communication make recommendations for greater efficiency, if needed. 1. Review the communications system in place between special education and 6. Provide an analysis of all staffing and caseload for the following related services: Human Resources, Business, Transportation, Education Services, etc. and speech therapy, occupational and physical therapy, psychologists, behavior make recommendations to increase efficiency, if needed. specialists, adaptive physical education required by federal and state law and 2. Review the communication systems between special education and the prin- make recommendations for greater efficiency, if needed. cipals and staff at the school sites and make recommendations as needed. 7. Examine the use of 1:1 instructional aides and the procedures for identifica- 3. Define the systems in place for communication and approval between tion, placement and fading and make recommendations to improve efficiency. business and special education regarding budget increases required during Program Effectiveness the course of the school year. 1. Examine the district’s identification and exit rates for students with disabilities This report contains the study team’s findings and recommendations. to determine if the district exceeds the statewide, county or SELPA average. FCMAT appreciates the opportunity to serve the Rialto Unified School District and extends thanks to all the staff for their assistance during fieldwork. 2. Review the district’s compliance history; identify trends requiring training, monitoring and support. Sincerely, 3. Determine the extent to which students are educated in the Least Restrictive Environment in compliance with statutory requirements and make recom- mendations if needed. 4. Examine the extent to which students with disabilities are accessing the core curriculum and make recommendations for improvement if needed. Joel D. Montero 5. Analyze the overall achievement of special education students as a subgroup in Chief Executive Officer relation to Adequate Yearly Progress and targeted proficiency area in English/ Language Arts and Math and make recommendations, if needed. i TABLE OF CONTENTS Table of contents Foreword .................................................................................................iii Introduction ............................................................................................1 Executive Summary ..............................................................................5 Findings and Recommendations .....................................................7 Fiscal Issues ......................................................................................................7 Program Efficiency .......................................................................................21 Organizational Structure and Assignments ........................................25 Staffing Ratios and Caseloads ..................................................................31 Program Effectiveness ................................................................................43 Communication ............................................................................................53 Programs, Procedures, Mission, and Beliefs ........................................57 Special Education Transportation ...........................................................59 Appendices ............................................................................................69 rialto unified school district ii iii TABLE OF CONTENTS ABOUT FCMAT About FCMAT FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify, prevent, and resolve financial and data management challenges. FCMAT provides fiscal and data management assistance, professional development training, product development and other related school business and data services. FCMAT’s fiscal and management assistance services are used not just to help avert fiscal crisis, but to promote sound financial practices and efficient operations. FCMAT’s data management services are used to help local educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and share information. FCMAT may be requested to provide fiscal crisis or management assistance by a school district, charter school, community college, county office of education, the state Superintendent of Public Instruction, or the Legislature. When a request or assignment is received, FCMAT assembles a study team that works closely with the local education agency to define the scope of work, conduct on-site fieldwork and provide a written report with findings and recommendations to help resolve issues, overcome challenges and plan for the future. Studies by Fiscal Year 90 80 70 60 50 40 30 20 10 0 92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 fiscal crisis & ManageMent assistance teaM rialto unified school district seidutS fo rebmuN FCMAT also develops and provides numerous publications, software tools, workshops and professional development opportunities to help local educational agencies operate more effec- tively and fulfill their fiscal oversight and data management responsibilities. The California School Information Services (CSIS) arm of FCMAT assists the California Department of Education with the implementation of the California Longitudinal Pupil Achievement Data System (CALPADS) and also maintains DataGate, the FCMAT/CSIS software LEAs use for CSIS services. FCMAT was created by Assembly Bill 1200 in 1992 to assist LEAs to meet and sustain their financial obligations. Assembly Bill 107 in 1997 charged FCMAT with responsi- bility for CSIS and its statewide data management work. Assembly Bill 1115 in 1999 codified CSIS’ mission. AB 1200 is also a statewide plan for county office of education and school districts to work together locally to improve fiscal procedures and accountability standards. Assembly Bill 2756 (2004) provides specific responsibilities to FCMAT with regard to districts that have received emergency state loans. In January 2006, SB 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to those types of LEAs. iv 1 ABOUT FCMAT INTRODUCTION Since 1992, FCMAT has been engaged to perform nearly 850 reviews for LEAs, including school Introduction districts, county offices of education, charter schools and community colleges. The Kern County Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D. Montero, Chief Executive Officer, with funding derived through appropriations in the state Background budget and a modest fee schedule for charges to requesting agencies. Located in San Bernardino County, the Rialto Unified School District has a general education enrollment of 26,485 students with approximately 3,083 identified for special education. As a member of the East Valley Special Education Local Plan Area (SELPA), the district participates in regionalized programs and services. The district also enrolls approximately 133 of its severely disabled students in the special education programs of the San Bernardino County Office of Education. With rising costs of special education and the impact on the unrestricted general fund, the district has requested a comprehensive review of special education efficiency and effectiveness in all program areas including transportation. In July 2013, the district entered into an agreement with the Fiscal Crisis and Management Assistance Team (FCMAT) for a review of special education. The study agreement specifies that FCMAT will perform the following: Fiscal 1. Determine the district’s encroachment on the general fund and make recom- mendations for greater efficiency. 2. Examine the costs for Nonpublic Schools and Agencies and make recommen- dations for greater efficiency. 3. Review the costs for all special education programs and services for students placed outside the district, and explore the cost effectiveness of developing program options within the district. 4. Review the due process requests and costs over the past three years and provide strategies for reduction in overall costs and requests. 5. Review the SELPA’s plan for the provision of mental health services pursuant to statutory requirements to transfer mental health services from county mental health to the district and review both the fiscal and programmatic impact. 6. Review the process and procedures for LEA Medi-Cal reimbursements and expenditures and make recommendations for greater efficiency. Special Education Transportation 1. Review the overall transportation special education delivery system, including but not limited to the role of the Individual Education Plan (IEP), routing, scheduling, operations, staffing and cost containment. fiscal crisis & ManageMent assistance teaM rialto unified school district 2 3 INTRODUCTION INTRODUCTION Program Efficiency Communication 1. Examine district infrastructure supporting special education programs and Parent Communication determine readiness to expand program capacity if needed. 1. Review the communication and problem solving models for parents to 2. Review the current organizational structure of the special education depart- build solid trusting relationships with the special education department. ment and compare with comparable size districts. Make recommendations to 2. Provide an analysis of parent input regarding the opportunities for parent ensure effective clerical and administrative efficiency. input into program and service development, district outreach and parent 3. Review the staffing assignment process for certificated and classified staff communication that currently exist and make recommendations for including tracking of resources, monitoring caseloads, position control and improvement, if needed. make recommendations for improvement if needed. 3. Review the current options for training available in the district for parents 4. Review the district’s philosophy, programs and procedures in special educa- of students with disabilities. tion to determine whether they are consistently aligned with the district’s 4. Review the district website link for special education and make recom- mission and beliefs and compliance with statutory regulations. mendations for improvement if needed to provide strength to the parent 5. Provide an analysis of all staffing ratios, class and caseload using statutory district relationship in special education. requirements for the provision of mandated special education programs and Interdepartmental Communication make recommendations for greater efficiency, if needed. 1. Review the communications system in place between special education 6. Provide an analysis of all staffing and caseload for the following related and Human Resources, Business, Transportation, Education Services, etc. services: speech therapy, occupational and physical therapy, psychologists, and make recommendations to increase efficiency, if needed. behavior specialists, adaptive physical education required by federal and state 2. Review the communication systems between special education and the law and make recommendations for greater efficiency, if needed. principals and staff at the school sites and make recommendations as 7. Examine the use of 1:1 instructional aides and the procedures for identifica- needed. tion, placement and fading and make recommendations to improve efficiency. 3. Define the systems in place for communication and approval between Program Effectiveness business and special education regarding budget increases required during the course of the school year. 1. Examine the district’s identification and exit rates for students with disabilities to determine if the district exceeds the statewide, county or SELPA average. Study Team 2. Review the district’s compliance history; identify trends requiring training, monitoring and support. The study team was composed of the following members: 3. Determine the extent to which students are educated in the Least Restrictive Environment in compliance with statutory requirements and make recom- William P. Gillaspie, Ed.D. JoAnn Murphy mendations if needed. FCMAT Deputy Administrative Officer FCMAT Consultant 4. Examine the extent to which students with disabilities are accessing the core Sacramento, CA Santee, CA curriculum and make recommendations for improvement if needed. 5. Analyze the overall achievement of special education students as a subgroup Leonel Martínez Trina Frazier* in relation to Adequate Yearly Progress and targeted proficiency area in FCMAT Technical Writer Administrator English/Language Arts and Math and make recommendations, if needed. Bakersfield, CA Fresno County SELPA Fresno, CA fiscal crisis & ManageMent assistance teaM rialto unified school district 4 5 INTRODUCTION EXECUTIVE SUMMARY Tim Purvis* Mike Rea* Executive Summary Director, Transportation Executive Director Poway Unified School District West County Transportation Agency Procedural inconsistencies, ineffective communication systems, and poor data management have Poway, CA Santa Rosa, CA resulted in numerous inefficiencies throughout the Rialto Unified School District. There is also a systemic lack of focus on instruction and lack of guidance from the highest level of leadership. Anne Stone Matt Doyle, Ed.D.* The district’s projected 2013-14 unrestricted general fund contribution for special education has FCMAT Consultant Executive Director, Special Education increased by $1,932,642 from the 2012-13 school year. The projected increase is due to salary Mission Viejo, CA Vista Unified School District and benefit increases, nonpublic school costs, and other increased operating costs. Vista, CA Nonpublic school costs are $1,493,996 annually and continue to rise. In addition to referrals to *As members of this study team, these consultants were not representing their respective the special education local plan area (SELPA), the district has developed an internal referral for employers but were working solely as independent contractors for FCMAT. nonpublic school (NPS) placements. However, the number of students in nonpublic schools has not decreased. Therefore, the only option in reducing nonpublic school costs is to provide appro- priate programs to meet these student needs. FCMAT estimates that the district could realize an Study Guidelines estimated cost savings of $172,110 by creating at least two district-operated alternative programs to serve 20 students instead of placing them in NPSs. FCMAT visited the district on October 14-18 and 28-31, 2013 to conduct interviews, collect data and review documents. This report is the result of those activities and is divided into the Invoices received by the district indicate that the San Bernardino County Office of Education following sections: serves 133 district students with moderate to severe disabilities. The district does not have the capacity to meet the needs of these students. However, with proper planning, staffing and access I. Executive Summary to appropriate facilities, the district could save approximately $34,198 per class if some county II. Fiscal Issues office programs were returned to the district. III. Program Efficiency District administration and clerical support in special education are below comparable size districts, which has affected efficiency, responsiveness and compliance with state and federal laws IV. Organizational Structure and Assignments for disabled students. District staff at all levels expressed concerns about programmatic issues in special education and systemic issues related to trust, accountability and decision-making V. Staffing Ratios and Caseloads in other central office departments. Staff indicated that there is a systemic lack of focus on VI. Program Effectiveness instruction, which has affected the overall achievement of special education students. The overall academic achievement of the district’s disabled students subgroup is below state and county aver- VII Communication ages in the percentage of those proficient in English/language arts and math. VIII. Programs, Procedures, Mission, and Beliefs Special education is treated as a separate entity and as a result, has been disconnected from the Education Services Department, which has affected overall efficiency and effectiveness in student IX. Special Education Transportation achievement. Special education should return to the supervision of education services to ensure it X. Appendices is aligned to standards-based curriculum, assessments and necessary staff training. The district is overstaffed in certificated and classified staffing positions in most areas of special education. In this report, FCMAT recommends a number of staffing reductions that could yield an estimated cost savings of $1,001,127. The district transports more than 20% of its special education students, which is double the average transport rate of 10% found in other districts studied by FCMAT. The district should consider the criteria established by individualized education program (IEP) teams to determine the need for transportation as a related service of special education and which students can ride a regular bus. Since 2010-11, the special education transportation contribution from the unrestricted general fund has grown steadily, increasing to more than $2 million in 2013-14. In this report, FCMAT provides a detailed analysis of the transportation fleet, maintenance and operating procedures and makes several recommendations to improve overall efficiency. fiscal crisis & ManageMent assistance teaM rialto unified school district 6 7 EXECUTIVE SUMMARY FISCAL ISSUES Findings and Recommendations Fiscal Issues The Rialto Unified School District tracks its unrestricted general fund contribution based on the actual revenue received and expended. Excess costs are defined as those that are in excess of the average annual per student expenditure in a local educational agency (LEA) during the preceding school year for an elementary school or a secondary school student, as may be appropriate. (34 CFR 300.16) A review of the district’s unrestricted general fund contribution including transportation and students enrolled in the San Bernardino County Office of Education programs indicates that an increase of $1,932,642 is projected in the general fund contribution for the 2013-14 school year. This projected increase is primarily because of increases in salaries, benefits, operating expenses, transportation, and nonpublic school costs. Changes in the general fund contribution over the last three years as reported by the district are detailed in the table below. Changes in the District General Fund Contribution over Three Years Percentage of General Amount of General Year Fund Contribution Fund Contribution 2011-12 24.6% $5,707,576 2012-13 21.4% $5,120,571 2013-14 (projected) 29% $7,053,213 Source: District Document Titled Contribution from Unrestricted General Fund to Restricted Programs Nonpublic Schools Education Code 56034 defines a nonpublic school (NPS) as follows: (a) private, nonsectarian school that enrolls individuals with exceptional needs pursuant to an individual education program and is certified by the department. It does not include an organization or agency that operates as a public agency, an affiliate of a state or local agency, including a private, nonprofit corporation established or operated by a state or local agency, or a public university or college. A nonpublic, nonsectarian school also shall meet standards as prescribed by the Superintendent and Board. The East Valley SELPA negotiates NPS contracts and develops individual service agreements for SELPA students served in an NPS. The SELPA receives invoices for these students, reviews them for accuracy, and dispenses funds to the NPS. Funding for the NPS placements comes from the following three sources: • Each member district is allocated a percentage of out-of-home funds received from the state based on the district’s average daily attendance (ADA). • Expenditures for the educational portion of the NPS placement over the district’s out-of- home allocation become the responsibility of the district. fiscal crisis & ManageMent assistance teaM rialto unified school district 8 9 FISCAL ISSUES FISCAL ISSUES • The SELPA expends educationally related mental health services funds to cover the When developing alternative programs, it is important to ensure that students will receive a district’s room and board fees for students in a residential program and for any mental comparable program that would enable them to remain in or return to the district. A review of health costs for residential and day NPS programs. the more than 40 students in an NPS found that at least eight to 10 each in middle school and high school could be appropriately served in an intensive district program. These classes could Special education does not notify the Business Department about potential changes in the also provide an appropriate placement for some students who enroll in the district with NPS on district’s responsibility for NPS placements. There is a lack of communication between the their IEPs or would be referred by the district for an NPS placement. Special Education and Business departments in developing the budget. Business first learns of additional costs when notified by the SELPA. Staff indicated that the district’s financial respon- The highest cost of developing an alternative program is staffing. The district indicated that facilities, sibility for these programs has increased significantly, and the district received this information materials, and supplies are available for additional classes. District staff estimated that each class would from the SELPA at the end of the quarter. require a teacher, two 6.5 hour aides, and a portion of a behavior specialist and counselor, but addi- tional psychologists, speech therapists or adaptive physical education staff would not be needed. The table below compares the cost of the district’s educational portion of NPS placements. The mental health costs of these placements are reviewed later in this report. In the past three years, Since these are new district programs, the district could also determine whether Medi-Cal and/ the SELPA has included revenue limit funds in this calculation, but this was not included in the or educationally related mental health services funds could be allocated to support these classes. 2013-14 projections. Possible changes in the cost of transporting these students were not included in this estimate, Comparing the Cost of the NPS Placements and salaries were based on average salaries by title, including benefits, as provided by the district. Instructional assistants were calculated at 6.5 hours, rather than the district’s current practice of 3.5 hours, to more closely align the program to an NPS program. Annual Daily Out-of- +/- District The average cost of a nonresidential NPS placement in 2012-13 was used for comparison Attendance Total Cost of Revenue Home Additional purposes. Based on the data provided to FCMAT, this average was $31,375. The NPS cost for 20 (ADA) Placement Limit Revenue Expenditure students would therefore be $627,500. 2010-11 38.38 $1,196,017 $191,470 $599,756 + $404,791 Potential Cost and Savings of District Classes for Students in an NPS 2011-12 38.31 $1,202,151 $189,137 $536,819 + $476,195 2012-13 41.85 $1,400,518 $208,869 $642,956 +$548,693 Percentage Average salary with ben- Staff FTE efits 2013-14 to date 43.69 $1,493,996 0 $642,956 +$851,040 Teacher 2 $187,303 Source: East Valley SELPA Documents Titled East Valley SELPA NPS Costs Instructional Assistants 4 at 6.5 hours $99,064 In 2013-14, the district will receive local control funding formula (LCFF) funds (the state’s new Behavior Specialist 0.5 $48,601 funding model for K-12 school districts, which replaces the prior revenue limit funding model) Counselor 0.8 $95,422 for students in nonpublic school placements. An additional calculation using the 2012-13 District level support (may include a new position) 0.25 $25,000 revenue limit rate of $4,990 and the 2013-14 projected ADA found that the district could Total $455,390 receive an additional $218,013 in LCFF funds to support these placements. This would reduce the district’s additional expenditure from $851,040 to $633,027. This is $84,334 more than the Projected NPS Cost 20 students at $31,375 $627,500 district’s responsibility in 2012-13. Projected Savings for two classes of ten students each $172,110 The SELPA has a process and procedure for referring a student for NPS placement, and staff Source for District Costs: District Documents of Staff Salaries with Benefits indicated that in the past year, the district has developed its own procedure in this area. In prior years, students were referred for an NPS without a behavior support plan or consideration of all Recommendations district resources. Staff also perceive that since the district began using the referral procedure, the number of district students in NPS placements has decreased; however, this is not the case. The district should: Some staff members stated that the district’s special education programs would not be appro- 1. Continue to include all revenues and expenditures when developing and priate for current NPS students. With the SELPA’s assistance, the district is in the process of monitoring the special education budget. developing a pilot program for emotionally disturbed students, but this program would not take the place of an NPS, according to staff. 2. Involve the Special Education Department in initial budget development. At least monthly meetings should be scheduled with the Business Department and Special Education to monitor all special education revenues and expen- ditures. At these meetings, Special Education should provide the Business Department with documentation that supports budget changes. fiscal crisis & ManageMent assistance teaM rialto unified school district 10 11 FISCAL ISSUES FISCAL ISSUES 3. Continue the procedures of having the SELPA negotiate NPS contracts and 2. Determine whether it is cost effective to develop programs and hire staff to monitor individual service agreements. provide the other services being received through an NPA or independent contractor. 4. Monitor and adjust the budget accordingly when students enter or exit from an NPS placement. 3. Monitor the cost of NPAs, independent contractors, and out-of SELPA students monthly to ensure that the district budget reflects changes in these 5. Develop a process for tracking students who are referred to an NPS to deter- services. mine the specific reasons for the referral and develop district programs and services to appropriately support those students in the district. County Office of Education 6. Develop classes for students who are in an NPS to return to the district and The SELPA has a procedure for referring students to county office programs and, with the students who would be sent to an NPS to stay in the district. member districts and the county office, developed rates for these programs. According to staff, 7. Ensure that newly developed classes for students in NPS placements are suffi- students are not referred to a county office program unless the services cannot be provided by the ciently staffed for the level of students being served. district. Once a student is referred to and accepted by the county office, contact between the staff Nonpublic Agency (NPA) members of the two agencies is limited. One psychologist was recently assigned to attend the county office’s triennial IEP meetings, but district staff do not generally attend annual IEP meet- Education Code requirements for nonpublic agencies (NPAs) are the same as for NPSs. ings. Education Code 56365(a) requires an NPA to do following: Some district staff members perceive that the county office staff determines acceptance of a ...be under contract with the local educational agency to provide the appropriate special student in a county office program. When the county office staff determines that a student is education facilities, special education, or designated instruction and services by the indi- not appropriately placed in its program, the student is returned to the district through the IEP vidual with exceptional needs if no appropriate public education program is available. process. District staff members believe they have no alternative to accepting a student who is The district and SELPA provided FCMAT with NPA, independent contractor, and out-of- returned from the county office program. SELPA costs. In 2012-13, the total cost for these categories of services was $398,553. Some severely disabled students served by the county office integrate with the students on the Students attending programs in another SELPA through an inter-SELPA agreement accounted regular education campus where the program is located. However, this is inconsistent and is most for $97,517 of this total. These placements reportedly occurred because the district did not have often prompted by the individual principal and the county office teacher(s). an appropriate program for these students. A district must notify the local SELPA of its intent to begin operating classes for students in the A specialized service, auditory verbal therapy, accounted for $21,095 of this total. The district county program by December 1, with an implementation date of July 1. A district can notify the recently hired staff with the skills necessary to assess and provide this type of therapy, potentially SELPA that it will operate one class, several classes or all classes. reducing the reliance on NPAs. Before deciding whether to operate programs now run by the county office, districts should The remaining $279,941 provided assessments or services required through mediations or resolu- consider the many and varied services and items involved in operating special education tion meetings. programs for severely disabled students. They should also consider the fact that the fiscal impact of operating their own special education programs and services extends beyond salary and benefit Although the district processes contracts for some NPAs and independent contractors, the costs. Program considerations are an integral part of any decision. Business Department does not receive timely information about additional NPA or out-of- SELPA costs that need to be monitored. The SELPA processes some of these agreements, but the A district should first determine if the number of students is sufficient to warrant the district Business Department becomes aware of them only when notified by the SELPA. operating programs. In 2012-13, the district was billed for 133 students in county office special day classes (SDCs) at $19,999 per student, according to SELPA data. This rate included the Recommendations related services of speech, adaptive physical education and health. The following table separates the 2012-13 county program students by disability and grade levels so that the district can The district should: consider which groups, if any, it may consider when developing district classes. For example, the small number of hard-of-hearing/deaf students may not be sufficient, while the higher number of 1. Compare the cost and program effectiveness of district speech therapists with students with intellectual disabilities may be. contracted positions to determine whether the district should hire its own therapists or continue contracting. fiscal crisis & ManageMent assistance teaM rialto unified school district 12 13 FISCAL ISSUES FISCAL ISSUES Rialto Unified students in County Office Classes by 2012-13 Grade Level • Planning for program transition, organizing and/or providing training for district staff, and Disability conducting transfer IEP meetings for all students. • Monitoring and implementing programs for the students transferred. Preschool Grades K-5 Grades 6-8 Grades 9-12 Transition Autism 8 15 9 12 1 • Assisting with classroom behavioral issues and serving as liaison for any county office Deaf/Hard of Hearing 4 4 0 1 0 services. Intellectual Disability 5 8 8 26 5 The district will also need to increase the capacity of its general education teaching staff to work Multiply Disabled 5 7 5 4 0 with these students. The better prepared all parties are, the more successful the program transfers Orthopedically Impaired 5 0 0 3 0 will be. Other Health Impaired 0 1 0 1 0 In the following table, FCMAT completed a calculation for one class of 10 students. An indi- Speech/Language 0 1 0 0 0 vidual calculation should be made for each class that the district will consider operating. Each Visually Impaired 1 0 1 0 1 level and type of class is unique, and therefore, the staff listed below may be greater than some Totals 28 36 23 47 7 classes would require, but insufficient for others. Staff costs are an average. This calculation used the Schools Services of California, Inc. recommended ratio of 10 students with one teacher and Source: SELPA Document Titled East Valley SELPA 2012/13 Fee for Service P-2 Final two aides. Additional support services were included, and instructional assistants were calculated for 6.5 hour positions. Changes in the cost of transporting these students were not included nor *There were a total of 141 students during the school year, however, billing was based on 133 students. was the cost of any additional staff such as occupational therapists or administrative support since A district should also consider other factors, including facilities, supervision, curriculum and that depends on the specific classes that would be operated. assessments. Since the classes housed in the district include students from outside the district, it The cost of one class operated by the county office was based on the 2012-13 rate of $19,999 would need to consider whether to serve those students or have them transported elsewhere to per student or $199,990 for a class of 10 students. The district would receive revenue limit (now continue receiving services from the county office. Because Rialto Unified students are served in LCFF) funding for those students. For purposes of this calculation, the 2012-13 revenue limit county office classes housed in other districts, another factor is the impact on the county office of rate of $4,990 per student was used for a total of $49,900. The district could therefore realize an education of returning these students to the district. estimated savings of $34,198 per class; however, this amount does not include transportation, The district also lacks a sufficient number of appropriately qualified staff to meet the needs of occupational therapists or any additional district level staff. these students. In addition to qualified teachers of students with severe disabilities such as autism, District Staffing Costs in Comparison with the 2012-13 County SDC Billing intellectual disability, and emotional disturbance, staff for related services would be necessary. Rate of $19,999 per Student The district’s speech therapy staff could not absorb the level of service required by this population without additional personnel. Other related service personnel would be needed such as physical Percentage Average Salary with and occupational therapists, adaptive physical education therapists, nursing and specialized Staff FTE Benefits services personnel. While the county office staff would have some transfer rights, current teachers Teacher 1 $93,651 may not wish to transfer. In some of the related service areas, county office staff would experience Psychologist 0.1 $12,335 reduced caseloads, and the service could continue to be provided by those staff for a fee. Speech Therapist 0.2 $29,616 If the district considers operating these programs, it should ensure the process includes a high Nurse 0.2 $21,193 level of openness for all concerned, including the parents of district students in county office Adaptive Physical Education 0.1 $9,365 programs, the SELPA, the county office and its staff, and the district. Instructional Assistants 2 @6.5 hours $49,532 The district may need to consider hiring one additional part-time or full-time program specialist Staffing cost for district program $215,692 or coordinator depending on the number of students/classes the district will operate. That indi- Additional Revenue Limit for 10 students at $4,990/student $49,900 vidual would need to have expertise in moderate to severe disabilities, including autism, multiple Balance for district program $165,792 disabilities, behavior management, developmental delays, and medical fragility. Also needed Cost for 10 students in COE program at $19,999 per student $199,990 would be knowledge in curriculum and program planning for these students. Difference -$34,198 The responsibilities of this staff member would include but not be limited to the following: Source for District Costs: District Documents of Staff Salaries with Benefits (The total cost does not include transportation, occupational therapists, district level support, materials or assessment services. fiscal crisis & ManageMent assistance teaM rialto unified school district 14 15 FISCAL ISSUES FISCAL ISSUES Recommendations k. Review the SELPA staffing policy and state regulations for credentialed and clas- sified staff. The district will need to determine the following: The district should: • Whether staff will retain their seniority date and classification. 1. Continue using the referral process for county office programs. • Whether the position will be offered to the person currently assigned to 2. Monitor the county IEPs and attend annual and triennial IEP meetings to the program, provided he or she is appropriately credentialed. increase the district’s knowledge of the services required for these students. • Whether the district will follow normal hiring procedures if that person 3. Ensure that decisions for students in county office programs are made collab- does not apply for the position. oratively with the district and county office. • When the district will begin providing health benefits to transferred employees at the district rate. 4. Meet with the site principals who have county office classes on their sites to establish a process and expectations for those students to be integrated into l. Meet with staff and affected county office employees and representatives to keep the school. them informed of the transfer’s progress and include them in planning. 5. Begin discussions with parents and staff if the transfer of programs is consid- m. Determine the actual cost for each class based on all staffing information includ- ered. If the district decides to establish programs for students in county office ing psychologists and nurses, facilities, materials, equipment, maintenance, etc. SDC classes, the following list will help with a successful transition. n. Train site administrators and site staff in disability awareness. a. Develop a listserv, which is a list of e-mail recipients who can share questions and o. Train administrators in any areas of additional responsibility regarding trans- answers regarding special education issues, to keep parents informed. ferred programs. b. Schedule meetings with parents to keep them informed of the transfer and ad- p. Include the county office staff in these trainings as appropriate. dress their concerns. The first meeting should occur before the district submits the letter of request to the SELPA to prevent any perception that the district is q. Hold IEP meetings 30 to 45 days before transfer for each affected student to proceeding without parent knowledge. prevent any misunderstandings regarding the continuation of the student’s IEP. c. Work with the county office and SELPA, to determine exactly which students Due Process attend classes that are requested for transfer and the specific staff (teachers and aides) assigned to each program. Education Code 56501(a) states the following: d. For each of these students, develop a matrix that includes his or her IEP goals, The parent or guardian and the public agency involved may initiate the due process the amount of time for each student’s related services, the service setting, any ad- hearing procedures prescribed by this chapter under any of the following circumstances: ditional aide time, and whether transportation is required. (1) There is a proposal to initiate or change the identification, assessment, or educa- e. Determine which are not district students and decide whether the district will tional placement of the child or the provision of a free appropriate public education form a regionalized program, which could require a memorandum of under- to the child. standing (MOU) with the sending districts, or the students will transfer to (2) There is a refusal to initiate or change the identification, assessment, or educa- another county office class. In either case, include the parents of those students tional placement of the child or the provision of a free appropriate public education in the parent meetings and the listserv. to the child. f. Finalize which facilities will be used for each class. (3) The parent or guardian refuses to consent to an assessment of the child. g. Review the cost of transporting the identified students to determine how they (4) There is a disagreement between a parent or guardian and a local educational will be transported. agency regarding the availability of a program appropriate for the child, including the question of financial responsibility, as specified in Section 300.148 of Title 34 of h. Complete an audit of all materials and equipment in each class. the Code of Federal Regulations. i. Determine whether the district would want the materials and equipment to In calculating the cost of due process, the district should consider the amount the district remain with the class. contributes to the SELPA for support with due process and the additional costs that may occur j. Develop an agreement with the county office to maintain the materials and in settlement agreements. equipment, as appropriate. fiscal crisis & ManageMent assistance teaM rialto unified school district 16 17 FISCAL ISSUES FISCAL ISSUES In 2012-13, each SELPA member district contributed $56.18 per student based on the 2011-12 • The Business Department is not provided with timely information on the potential cost December California Special Education Management Information System (CASEMIS) count. of due process settlements so that the budget can be appropriately adjusted. This fee provided the district with support in preventing and preparing for due process as well as the attorney fees incurred from a filing. Any student’s services that were agreed upon as a Recommendations result of a filing were the responsibility of the district. In 2012-13, Rialto Unified contributed The district should: $127,472.42 for SELPA support and $70,597 for additional services. The district had eight due process cases in 2011-12, 10 in 2012-13, and eight so far this year, 1. Continue using the SELPA services for alternative dispute resolution and due including two initiated by the district. This number represents less than 1% of the total number process. of special education students in the district. Although the actual number of due process filings 2. Develop a process to monitor IEPs for compliance and to ensure the services is low, staff indicated that the Special Education Department is frequently called on to attend listed on them are provided to the student. IEP meetings that have advocates or attorneys present. The costs listed in the following table as reported by the district do not include staff time in preparing for and attending meetings. 3. Encourage parents and staff to participate in alternative dispute resolution Three-Year Comparison of Due Process Costs to develop trust and reduce the need for filing due process requests. Parents and staff should be trained in alternative dispute resolution so that they better Parent SELPA understand the process. Date # Filings Attorney Attorney Services Total 4. Include site staff, as appropriate, in mediations and resolution meetings to 2011-12 8 $5,000 $54,988 $5,060 $65,048 ensure that sites understand how their role affects the process outcome. 2012-13 10 $31,800 $44,721 $70,597 $147,118 5. Ensure that all special education staff have been trained in writing compliant 2013-14 8 0 0 $35,100 $35,100 IEPs. Source: SELPA Documents Titled East Valley SELPA Claim Experience Reports 6. Ensure that every general education teacher has information regarding special Although the documentation provided to FCMAT indicates the primary reason for requesting education students in his or her class, including the student’s goals, accom- a due process hearing is placement, other underlying issues may be the actual reasons. These modations/modifications, disability strategies, and behavioral issues including include the following: behavior plans. • Parents do not trust that the district will agree to provide a student with the required 7. Ensure that every site administrator has information on all special education services or the services on an IEP. students at his or her site and in particular, information on behavior plans. • The district special education staff is unable to monitor IEPs for compliance and ensure 8. Develop a spreadsheet to include all pertinent areas of potential and actual services are provided as written. due process filings, as well as any complaints that may be filed, so that costs • Although the district has access to alternative dispute resolution through the SELPA, can be tracked and issues determined and remedied. many parents do not know about it or trust it. The district’s special education staff have 9. Provide this spreadsheet to the Business Department at the proposed monthly not had training in alternative dispute resolution or facilitated IEPs. meetings recommended in this report so the special education budget can be • Site administrators and special education teachers are rarely involved in mediations or adjusted as needed. settlement agreements and therefore have little understanding of why a settlement was necessary and how they could prevent procedural errors that can affect the outcome of a Mental Health due process hearing. The additional costs of mental health and residential services have transferred to school districts • Special education teachers have not had sufficient training in writing compliant IEPs through Assembly Bill (AB) 114. On June 30, 2011, Assembly Bill 114, Chapter 43, Statutes of 2011 although this is available through the SELPA. was signed into law. Under AB 114, several sections of chapter 26.5 of the California Government • Special education students are integrated to varying levels at the school sites. Some Code were amended or rendered inoperative, ending the state mandate on county mental health agen- general education teachers are not given sufficient information regarding the special cies to provide mental health services to disabled students. With the passage of AB 114, school districts education students in their classes, and some site administrators may not be aware of or are now solely responsible for ensuring that disabled students receive special education and related do not follow a student behavior plan. services, including some services previously arranged for or provided by county mental health. • The district does not track due process filings or complaints. Developing systems to address problems is difficult without specific data regarding issues, sites, staff, etc. fiscal crisis & ManageMent assistance teaM rialto unified school district 18 19 FISCAL ISSUES FISCAL ISSUES The SELPA has a comprehensive plan to provide mental health services according to the statutory Recommendation requirements. The SELPA hired staff to provide a therapeutic level of support, and the district The district should: staff indicated they were satisfied with these services. The plan includes a clear referral process to access SELPA support, which includes documentation of the services provided by the district 1. At the monthly meetings mentioned above, closely monitor the residential before the referral. placements and mental health costs of all students in nonpublic schools and The total amount of the mental health funds received by the SELPA are allocated to each district make budget adjustments to the amount the district will receive as changes based on the formula agreed upon in the SELPA allocation plan. Nonpublic school costs for occur. outpatient counseling, case management, day treatment, residential room and board, residential counseling, and visits/transportation are deducted from the district’s total allocation. Regional Medi-Cal program costs are also deducted. The remaining funds are distributed to the district to provide Through the Medi-Cal local education agency (LEA) billing option, a district may submit claims the required district-level support. to California Medi-Cal for covered services provided to eligible children enrolled in special The district does not monitor the cost of the mental health portion of the residential placements, education programs. This program is a way for school districts and/or county offices of education but receives this information from the SELPA. If there are additional costs from placements to receive federal funds to help pay for health-related special education and related services. during the school year, the Business Department lacks the information necessary to make any The district indicated that several changes were recently implemented regarding the district’s budget adjustments until the end of each quarter. participation in the program. The Medi-Cal billing agent was changed to Practi-Cal, and another Three-Year Comparison of Mental Health NPS and Regional Program Costs district staff member was assigned to monitor revenue and expenditures. The district also recently included transportation, wheelchair buses, and behavior specialists in Medi-Cal billing. Case Day Room Residential Residential Visits/ Regional Year Outpatient Management Treatment & Board counseling monitoring travel Program Total Speech therapists, nurses, psychologists, health aides and other related service staff are authorized 2011-12 $28,182 $205 $41,895 $278,191 $78,292 $14,693 $6,085 $94,171 $541,714 to provide data for Medi-Cal eligible students. The district is working closely with the billing 2012-13 $6,842 $137 $26,494 $54,593 $54,589 0 0 $181,189 $323,844 agent to ensure that all appropriate staff are included in this process. 2013-14 $13,364 0 $26,665 $103,447 $6,075 0 $7,000 $217,060 $373,611 Speech therapists reportedly had difficulty accessing online billing this year. Because training in Source: SELPA Documents Titled East Valley SELPA NPS and Mental Health Cost Summaries online submission has not been successful, the documentation to date is not complete; however, Data for 2013-14 is projected additional training is scheduled to correct the problem. The district has determined that its portion of educationally related mental health services funds will The district has a collaborative as required under the Medi-Cal local education agency billing support the behavior specialist, behavior analyst, behavior support aide, and counselor positions option, and FCMAT reviewed documentation confirming the collaborative and its members. The as well as a portion of the school psychologists and the psychologist intern. The following table documentation further confirmed that expenditures were for supplemental staff and material/ compares the amount of educationally related mental health services funds the district has supplies and therefore within Medi-Cal guidelines. received and is projected to receive for the district mental health program to the NPS/regional The budget documentation provided to FCMAT includes Medi-Cal carryover funds of approxi- program costs. mately $450,000. Staff stated that the district estimates revenue of approximately $350,000 per Disbursement of Mental Health Funds from 2011-12 with 2013-14 year if all billing is completed as planned, and the budget provided indicated expenditures of Projections $459,000. A portion of the carryover would therefore be expended unless estimated revenue is increased. The collaborative is determining how much should be reserved in carryover and how Total NPS/ much could still be expended. Total Mental Regional Program Balance for dis- Year Health Revenue Costs trict programs Recommendations 2011-12 $1,623,829 $541,714 $1,082,115 2012-13 $1,834,392 $323,844 $1,510,548 The district should: 2013-14 $1,833,764 $373,611 $1,460,153 1. Ensure Medi-Cal revenue is maximized by having all appropriate staff submit Source: SELPA Documents Titled East Valley SELPA NPS and Mental Health Cost Summaries billing information completely and timely. 2. Continue to ensure the revenue expended is for supplemental staff and mate- rials that support the staff generating the Medi-Cal revenue. 3. Ensure carryover is reduced, but a sufficient amount remains to provide the current level of staffing and support. fiscal crisis & ManageMent assistance teaM rialto unified school district 20 21 FISCAL ISSUES PROGRAM EFFICIENCY Program Efficiency District Infrastructure Staff and administration interviewed by FCMAT expressed significant concerns regarding programmatic issues in special education and systemic issues throughout the district. Special education staff indicated there is an absence of trust in the central office because of its significant lack of decision-making, accountability and guidance. Staff perceive that the central office is unwilling to put anything in writing and commit to a decision. School site administrators lack the training and support necessary for successful special education programs. Administrators are not provided with any training in special education, and changes in program delivery are made with no preparation or training for administrators to support the change. The district has a systemic lack of support for acquiring the expertise necessary for the Special Education Department to operate efficiently and effectively. The Special Education administra- tion spends much of its time attending IEP meetings and dealing with compliance issues, leaving little time to focus on curriculum and instruction in special education classrooms. This is partially because of the limited number of special education administrative staff. The district has an overall lack of capacity to provide adequate training/professional development for special education and site administrators, certificated and classified staff. This is a systemic issue that was mentioned by all representative staff interviewed. The district does not provide the support necessary for staff to effectively carry out its responsibilities. Because of the shortage in the number of special education administrators, classrooms receive few visits and little district support. The district recently began holding articulation meetings, but not all the staff attend; some arrive late, others leave early, and there are no consequences for nonattendance. Designated instructional services (DIS) staff participate in little training. Continuing training is crucial to maintaining current best practices and enabling staff to practice in a legally defensible manner. Because the field of special education continually changes, providers such as speech language pathologists (SLP) and school psychologists should participate in continuous training. This improves their practice and helps the district be proactive and avoid unnecessary litigation. The special education staff and school site staff are not trained in supporting special needs students with behavior problems. All staff needs training in this area. Students are frequently sent to the office because personnel do not know how to effectively deal with their behavior. None of the staff has been trained to de-escalate and deal with behavior problems and create safer class- rooms. The Special Education Department is frequently reactive instead of proactive; however, all the departments and sites overwhelmingly stated that this is a systemic issue and not specific to special education. Many districts and school sites across the United States address schoolwide behavior by adopting the Positive Behavioral Interventions and Supports (PBIS) framework. This is an evidence-based framework that provides schools with a three-tiered system of support that mirrors the three tiered Response to Intervention (RtI) model. The district has begun to implement this frame- work. Staff indicated that instructional assistants are not appropriately trained to work with special needs students nor are they given time to meet with their assigned teachers and teams to debrief, solve problems, and receive feedback and support. Teachers need training on effectively using fiscal crisis & ManageMent assistance teaM rialto unified school district 22 23 PROGRAM EFFICIENCY PROGRAM EFFICIENCY their instructional assistants and providing constructive feedback and redirection when necessary. General education should take the lead in implementing interventions. To ensure success, the They also need assistance in developing their role as classroom instructional leaders. district should join in a collective effort by all staff members, general and special education, to address students’ academic and behavioral needs. The district has no master plan for training instructional assistants. The Special Education Department should assess the instructional assistants’ performance and determine the training Many staff computers lack the capacity to support some of the programs needed to function needed by staff. Coverage issues can make it difficult to release instructional assistants from the efficiently. Staff access to technology is limited, and some technology is antiquated. This should classroom, so online courses may be a viable option. be evaluated to improve the district’s overall infrastructure. The SELPA offers training; however, staff is not always given the opportunity to attend, and requests are sometimes denied. The SELPA staff development calendar includes training that Recommendations could benefit the Rialto Unified staff. The district should: The Special Education Department is developing a procedural manual. This manual should 1. Continue to include the Special Education Department in the overall struc- outline the roles and responsibilities of the district and site administrators, teachers and desig- ture of the district, including representation on the cabinet. nated instruction providers. It should include policies and procedures for referral, assessment, IEPs, placements, annual, and triennial reviews. This document should also be available online 2. Schedule monthly standing meetings between the Special Education, Human for all staff to access, including principals. It should be updated when laws change, and all staff Resources and Business departments to discuss budgets, vacancies and staffing should be directed to the online changes. Periodic advisories should be sent to all staff when needs. issues arise that require additional explanation. Formal training should be provided on proce- dures when there are issues related to systemic compliance. 3. Develop a strategic plan for special education programs that can be used to improve instruction. The Special Education Department does not send a representative to all the IEP meetings of students who are placed in county-office-operated regionalized programs. Annual IEPs are 4. Provide staff with Pro-ACT training, which is specialized training for positive especially difficult for district representation to attend. One factor affecting attendance is that behavioral interventions, in dealing with student behavior and creating safer the district sometimes does not receive adequate notice of the IEPs from the county office. The classrooms. school psychologist assigned to the nonpublic schools is responsible for attending county office IEPs; but cannot attend all of them because of his schedule. The district should consider dividing 5. Continue implementation of the Positive Behavioral Interventions and these IEPs between the administrative staff to ensure appropriate coverage. Supports framework to address student behavior school/districtwide. Because the two systems used by the district to track student data are incompatible, they must be 6. Provide training opportunities for designated instructional staff. maintained manually, which can lead to increased human error and inefficiency. The districtwide 7. Provide regularly scheduled training and support for instructional assistants. system used is Synergy and the Special Education Department uses District Administration, which is the IEP software system implemented SELPA-wide. The district should develop a means 8. Consider offering online training to instructional assistants to decrease the to upload the information to allow compatibility between the two systems. amount of time they are away from the classroom. The district is partially implementing an RtI model and professional learning communities; 9. Consider making time for classroom staff to meet (including instructional however, they are implemented inconsistently districtwide and lack a master plan for guidance. assistants) to debrief, plan, strategize and provide feedback on classroom Staff’s knowledge of these models varies greatly throughout the district; some school sites are functioning. partially implementing both programs, while others are not implementing them at all. The district does not ensure that the sites have access to and are implementing state-approved supple- 10. Train teachers to utilize instructional aides and provide them with direction/ mental intervention programs, which are a major component of a tiered model. The district supervision. also does not consistently use universal screening to accurately identify students and provide appropriate instruction. Universal screening and progress monitoring are essential for accessing 11. Complete the procedural manual and make it available online for all staff. academic and behavioral performance levels and evaluating the effectiveness of instruction and 12. Regularly update the manual on and notify staff when updates are made. intervention. 13. Train staff in the procedures to follow when systemic issues arise. The district should clearly define the research-based interventions it will support and provide staff with a means to implement, measure academic growth, and make educational decisions. 14. Ensure attendance at IEP meetings for students placed in county office Extensive training, data collection, monitoring, access to resources and materials, and consistency programs by dividing the responsibility of attending meetings among admin- are necessary at the district level for all school sites to succeed. istrative staff. fiscal crisis & ManageMent assistance teaM rialto unified school district 24 25 PROGRAM EFFICIENCY ORGANIZATIONAL STRUCTURE AND ASSIGNMENTS 15. Consider developing a means to upload the information from the two Organizational Structure and Assignments student information systems (Synergy and the Web IEP program/DA) to allow compatibility between the two systems. The following table compares the district’s administrative and clerical staff with that of similarly sized districts. FCMAT found that Rialto Unified has fewer administrative and clerical staff 16. Develop a master plan for the implementation of RtI and professional in special education than comparable districts and is inadequately staffed. Efficiency has been learning communities. compromised in a number of areas by a lack of staff in these areas. These include ineffective interdepartmental and school site communication, lack of support, increased expenditures, lack 17. Ensure all staff members are extensively trained in assessments, data analysis, of goals and objectives, and a lack of appropriate training for special education and school site programs, and research-based instructional practices and strategies. staff. Although it is a difficult fiscal time for the state’s public schools, the district should consider 18. Ensure all staff members can access scientifically researched-based instruction increasing the number of administrative and clerical staff. Otherwise, efficiency and program and interventions. effectiveness will continue to be compromised. The department’s administrative structure previously included program specialists, but these 19. Ensure the staff has appropriate state-approved supplemental intervention positions were eliminated. At least two coordinator positions should be added to provide the programs for tiers II and III. appropriate support and infrastructure and increase efficiency. The senior coordinator position 20. Ensure that universal screening tools are utilized. should be reclassified as a director position, become a member of the cabinet, and report to the assistant superintendent of educational services. 21. Ensure a progress monitoring system is regularly implemented. An additional secretary III will be necessary to provide the needed infrastructure. At present, 22. Evaluate technology and computer capacity throughout the district. A master two secretaries are assigned to the school psychologists. Reassigning these two secretaries to the plan should be developed to identify the greatest technological needs. coordinators and redefining their duties would be more efficient. 23. Develop a clearly defined collaboration/meeting schedule for Educational Administrative Staff Comparison to Comparable Districts Services and Special Education staff that includes topics such as staffing, core Rialto Vista San instructional program implementation, training, and parent communication Unified Redlands Unified Ramon Colton and involvement. 26,485 Unified 25,642 Valley Joint Administrative Staff ADA 21,379 ADA ADA 30,738 ADA 23,172 ADA 24. Consider transferring the special education program to the Educational Student Services Sr. Director .30 Services Department to ensure greater alignment to core instructional Special Education Director 1.0 1.0 2.0 1.0 programs and training. Program Specialist 2.0 25. Review the communication systems between special education and the Special Ed. Program Supervisors 5.0 5.5 principals. One way to accomplish this would be to send periodic advisories Special Ed. Principal 1.0 to all general and special education staff via e-mail quarterly regarding special Special Education Sr. Coordinator 1.0 education issues and interventions. Special Education Coordinator 2.0 5.0 1.0 Teacher on Special Assignment 2.0 Budget Analyst 1.0 Office Supervisor 1.0 Administrative Assistant 1.0 1.0 Secretary III 1.0 1.0 2.0 Secretary II 2.0 Secretary I 2.0 3.0 Office Secretary 7.0 Compliance Support Secretary 1.0 CASEMIS Clerk 2.0 Clerk III 2.0 1.0 Clerk II 2.0 1.0 Receptionist 1.0 Note: San Ramon Valley is a single-district SELPA fiscal crisis & ManageMent assistance teaM rialto unified school district 26 27 ORGANIZATIONAL STRUCTURE AND ASSIGNMENTS ORGANIZATIONAL STRUCTURE AND ASSIGNMENTS Job descriptions need to be updated. A review of these documents found that they do not reflect Although reports should be regularly disseminated and discussed with the special education and the roles and responsibilities of the Special Education Department staff. The department should general education staffs, these documents are not frequently run, and special education data is work with the Human Resources Department to revise job descriptions so that they reflect not easily available through the district system. Some caseload information requested by FCMAT current roles, responsibilities and duties. was manually gathered during the interview period because it did not exist beforehand. Reports run for some caseloads did not match the information provided during the study, and the class If the district decides to take back severe programs from the county office, it would need addi- size data generated was inaccurate. None of the three different documents provided matched. tional administrative support. Manually compiled data is often inaccurate or outdated, which leads to making decisions subjectively rather than objectively through the use of data. Gathering data manually is also time- Recommendations consuming and inefficient. The district should: Special education administration should create and monitor the following data monthly: 1. Reclassify the senior coordinator position to a director reporting to the assis- 1. Caseloads and class sizes for all service providers and teachers using a data- tant superintendent of educational services. base. Lists by school and providers should be developed, and this information provided to special education staff and school site principals at least monthly. 2. Add at least two coordinator positions to provide the appropriate support and infrastructure and increase efficiency 2. The number of instructional assistants and 1-to-1 instructional assistants, especially any new staff and their specific assignments. 3. Increase clerical staff by adding a secretary III position. 3. All DIS caseloads. 4. Work with Human Resources to revise the job descriptions of special educa- tion clerical staff and administration. This data should be provided monthly to the cabinet, special education staff and principals. 5. Reassign the two secretaries from the school psychologists to the coordinators The district has established three levels of instructional assistants to support special education and redefine their duties. programs and students. Instructional assistant Is help classroom teachers with instructional activi- ties, instructional assistant IIs work with students in special education RSP or SDC programs, 6. Consider adding additional administrative support if the district decides to and instructional assistant IIIs work with those who are in programs for the severely disabled or take back programs for severe students from the county office. multiply handicapped. Instructional assistants are part-time, most for three hours per day, and it is difficult to retain Staffing Assignment employees in these positions. Staff stated that as many as 50 positions can be vacant at any given The inconsistency between data from the Special Education and Human Resources depart- time, sometimes remaining unfilled for extended periods, which creates a burden on programs ments is evident in a number of staff categories. These include mild to moderate teachers and and staff. Existing staff frequently fill the vacant positions, but the district must pay Public instructional assistants, resource specialist program (RSP) teachers and instructional assistants Employees’ Retirement System (PERS) benefits if they remain for a certain number of days. A and speech and language pathologists. However, some staff members are included on the Special high number of vacancies also leads to frequent “bumping” and moving. This lack of consistency Education caseload lists, but not on the list for the Human Resources Department. Some and turnover is inefficient for all the departments involved in the process and does not benefit instructional assistants on the Special Education assignment chart are assigned to teachers that students and programs. Further, the district lacks strong recruiting for vacant instructional assis- do not appear on the lists of Special Education caseloads or the Human Resources Department. tant positions. Therefore, the number and names of special education staff are inaccurate, instructional assistant The Special Education Department does not monitor position control. A formal written proposal assignments cannot be tracked, and caseload data is erroneous. This also indicates that staff are is not mandatory when requests are made for additional staff, including instructional assistants. not efficiently monitored. The district should have a formal request process that includes justification from special educa- The inconsistency between department staff lists and assignments indicates significant inef- tion and clearance from the Finance and Business Department and the cabinet when a new ficiency. A system should be established to ensure that the lists are consistent in staff names and position is requested or an existing position needs to be filled. An efficient and timely process is FTEs. This discrepancy recurs throughout special education programs except in moderate to especially important for part-time positions because of the difficulty in filling them. The Human severe program staffing, where the departments’ data sources are more closely aligned. Resources Department does not work with local community colleges and universities to recruit instructional assistants. This is often an excellent way to solicit candidates. The California Special Education Management Information System can generate reports on the identification and exit rates of special education students, trends in disability areas, high-inci- Staff indicated that special education vacancies are not posted or filled in a timely manner, dence areas and data by grade, disability, and ethnicity. The administrative staff may lack the time preventing the district from acquiring the best candidates. All districts recruit for positions in to continuously monitor this data, but not doing so is an inefficient way to operate programs. spring, and Rialto Unified misses this crucial window because of inefficiencies. When positions are not posted in a timely manner, vacancies exist for longer periods of time, making it necessary fiscal crisis & ManageMent assistance teaM rialto unified school district 28 29 ORGANIZATIONAL STRUCTURE AND ASSIGNMENTS ORGANIZATIONAL STRUCTURE AND ASSIGNMENTS to hire substitutes. These employees are typically not as effective as regular, trained classroom 3. Provide this data monthly to the cabinet, special education staff, and princi- staff, nor are they usually familiar with the students, their goals, the curriculum, or class routines. pals. It is not unusual for a substitute instructional assistant to have no previous experience with 4. Ensure the staff entering the data is trained to perform this task accurately disabled students. As a result, the district must invest time to hire and train new staff in following and efficiently. classroom/school routines and dealing with individual students. Hiring full-time assistants may be more efficient and effective in classes for the autistic and emotionally disturbed because of the 5. Create a database that aligns with the Human Resources Department system severity of student needs. Having numerous vacancies is these classes can be difficult for students to track placement and movement instead of relying on manual entry. and staff. 6. Conduct a needs assessment with the special education staff to determine the The district reportedly has no substitute pool for teachers and instructional assistants, which is reason for the high turnover among instructional assistants, and implement a inefficient. Substitutes should be trained in the skills and knowledge necessary to support the system to reduce the amount of time necessary to fill vacant positions. unique needs of students and classrooms. The following steps may help the district build a pool of skilled and well trained substitutes: 7. Establish a pool of substitute instructional assistants that can be used when staff is absent or vacancies exist and are in the process of being filled. 1. Determine the number of substitutes needed and recruit the appropriate amount to cover the average daily use of substitutes. Determining the average 8. Follow the steps outlined in this report to create and maintain a pool of quali- daily use can be accomplished by analyzing the annual substitute history. fied substitutes. The district should improve its recruiting timeline and take the steps mentioned above to fill vacancies. 2. Strengthen substitute screening, interviewing and selection. 3. Conduct thorough reference checks. 4. Maximize preparedness by developing strong and structured orientation and training. The orientation should include more than paperwork. It should teach substitutes about the different types of disabilities they will encounter in the special education classroom. Substitutes should be trained in classroom management, instructional skills, positive interactions, and expectations. They should be offered access to training in the district and SELPA. 5. Designate a site staff member to check on the substitutes during the day. 6. Develop a substitute teacher and instructional assistant guide. 7. Develop a substitute teacher folder and checklist. 8. Develop a substitute feedback form. The district’s recently established personnel services request process needs improvement. The process is utilized when new staff or replacements are requested to fill vacancies. The school sites responsible for generating these requests do not always use the appropriate budget coding. They also use the code of another department’s (Special Education) budget, which can create problems. Recommendations The district should: 1. Ensure that special education administrators continually monitor caseloads, class sizes, data and trends. 2. Use data to drive staffing decisions, especially when any growth is needed or requested. fiscal crisis & ManageMent assistance teaM rialto unified school district 30 31 ORGANIZATIONAL STRUCTURE AND ASSIGNMENTS STAFFING RATIOS AND CASELOADS Staffing Ratios and Caseloads FCMAT has significant concerns about the conflicting data that was provided to the team regarding staffing ratios and caseloads. This creates major efficiency issues. The district operates special education programs and provides services for students with severe and nonsevere disabilities. One hundred and thirty-three of the district’s special education students are served by county office regionalized programs. The Rialto Unified Special Education Department has established district caseload ratios for its programs and has a memorandum of understanding (MOU) with its certificated bargaining unit for SDC class special education, which states the following: Whereas the Rialto Education Association and Rialto Unified School District have engaged in discussions relative to the class sizes in Special Day Classes, the following has been agreed to for the 2013-2014 school year. A. Every effort shall be made to keep preschool and grades K-5 self-contained Special Education classes students at fifteen (15) students or below. In the event the number of students exceeds the number above, the parties (including the affected teacher) agree to discuss options and apply resolutions, including but not limited to, the fol- lowing: 1. Transferring students to another class or school site. 2. Granting overtime hours instructional aides assigned in the classroom. 3. Providing an additional instructional aide in the classroom. 4. Opening another class at the site or another site when appropriate. B. Every effort shall be made to keep single special education periods at the Middle School at eighteen (18) or below and special education periods at the High School at twenty (20) or below and evenly distributed among SDC special education teachers. In the event the number of students exceeds the numbers above, the parties, (includ- ing the affected teacher) agree to discuss options and apply resolutions, including, but not limited to, the following: 1. Mainstreaming students when appropriate. 2. Revising the master schedule if possible. 3. Opening another class at the site. 4. Providing an additional instructional aide during the affected period. 5. The parties agree to revisit the issue of special education class sizes after this MOU expires. The district operates special day class (SDC) programs for students with mild to moderate disabilities and those with moderate to severe disabilities. Moderate to severe SDCs serve students who are developmentally delayed, multiply handicapped, emotionally disturbed, and autistic. The district also operates mild to moderate SDCs and RSPs. Rialto Unified also provides itinerant services to district students. These services include adaptive physical education (APE), teachers for the visually impaired (VI) and teachers for the deaf and hard of hearing (DHH). Other providers, including two autism specialists, are provided by the SELPA for district use as needed. fiscal crisis & ManageMent assistance teaM rialto unified school district 32 33 STAFFING RATIOS AND CASELOADS STAFFING RATIOS AND CASELOADS The district employs a total of 328 instructional assistants, according to the data provided by the FCMAT found that district programs are loaded at lower levels than the district MOU Special Education Department. Of the 328 instructional assistants listed in the special education maximum in several instances. All moderate to severe SDCs have an average of four instructional documents, 50 are assigned 1-to-1. These will be covered in a separate section of this report. Most assistants per classroom, and an additional 29 1-to-1 instructional assistants are assigned to instructional assistants work three hours a day, and most SDC and RSP coverage consists of two to students in moderate to severe classrooms. This increases the adult to student ratio per classroom. four, 3-hour instructional assistants working in the classroom throughout the school day depending Most instructional assistants who work in moderate to severe district SDCs do so part-time for on the specific classroom staffing. Creating some full-time positions for the intense classes such as three hours per day. This means an average of four different instructional assistants work in a autistic and emotionally disturbed programs may be more cost-effective and efficient. classroom each day. The School Services recommendation for two instructional aides is based on two full-time aides. Moderate to Severe Special Day Class Caseloads The district MOU for the 2013-14 school year indicates maximum class sizes of 15 students per Although most of these assistants works three hours per day, approximately 20 of the 98 work elementary school (K-5) SDC, 18 students per middle school, and 20 per high school SDC. The more than three hours. Of these, most work 3.5 hours, and approximately six work four to six Education Code does not indicate maximum caseloads for special day classes; however, School hours. Services of California, Inc. (SSC) has developed recommended caseload guidelines using data Functional Skills (Developmentally Delayed)-Preschool collected throughout the state. These guidelines are used across the state as the standard of prac- The district MOU has no class size maximums for preschool. School Services recom- tice for efficient special education staffing. mends a caseload ratio of one teacher and two instructional assistants to a class of FCMAT used district data to analyze class and caseload size using statutory requirements for 10 to12 students with moderate to severe developmental delay. The district’s average mandated services and statewide guidelines and to compare with district MOU maximums. The caseload for teachers is higher than these guidelines, with an average of 20 students per following table is organized by SDC type and shows a class size comparison with district MOU teacher. The average number of instructional assistants is four per class, and one 1-to-1 maximums and SSC guidelines. These caseload comparisons are divided by program, grade level position is assigned to students in these classes. clusters, number of students, and total classroom staffing, including instructional assistants and Severe Multiple Disabilities (Multihandicapped) staff to student ratios. The elementary multihandicapped average class size is 12 students, which is lower than Comparison of Moderate to Severe Classified and Certificated Staffing & Caseloads the district MOU maximum of 15 and more than the School Services recommended No. of SSC RUSD # 1:1 guideline. The middle school average class size is 15 students, which is less than the Teacher No. of Instructional RUSD Recommended MOU Teacher district MOU maximum of 18 students per class and more than the School Services Program FTE Students Assistants* Ratio Caseload Maximum Assistants guideline. The high school average class size is 13 students, which is significantly less Developmentally Delayed 20 Students 10-12 Students NA-applies than the district MOU maximum of 20 students per class and more than the School (Pre-K) 1 20 4 4 Assistants 2 Aides to K-12 only 1 Services guideline. Severe Multiple Disabilities 12 Students 8-10 Students Each elementary, middle and high school class has an average of four instructional Multi-Handicapped (K-5) 5 58 20 4 Assistants 2 Aides 15 5 assistants. The instructional aide staffing is aligned with the School Services recom- Severe Multiple mendation. Disabilities Multihandicapped 12 15 Students 8-10 Students Emotionally Disturbed (Middle School) 3 44 4 Assistants 2 Aides 18 6 Severe Multiple Elementary classes for the emotionally disturbed (ED) have an average of nine students, Disabilities much lower than the district MOU maximum of 15 students and within the School Multi-Handicapped (High 13 Students 8-10 Students School) 7 90 27 4 Assistants 2 Aides 20 7 Services guidelines. The middle school average number of students per class is 10, Emotionally 9 Students 8-10 Students which is much lower than the district MOU maximum and within the guideline. The Disturbed (ED) (K-5) 2 18 8 4 Assistants 2 Aides 15 2 high school average number of students per class is 10, which is much lower than the Emotionally district MOU maximum and within the SSC guideline. Disturbed (ED) 10 Students 8-10 Students (Middle School) 2 19 8 4 Assistants 2 Aides 18 2 Elementary, middle and high schools have an average of four instructional assistants per Emotionally ED class. The four positions provide the equivalent of two full-time instructional assis- Disturbed (ED) (High 10 Students 8-10 Students tant staff in the classroom throughout the school day. This may be an appropriate level School) 3 31 12 4 Assistants 2 Aides 20 6 of support depending on the intensity of student needs in the ED program. However, Autism Spectrum Disorders 6 Students 8 Students ED class also have additional 10 1-to-1 instructional assistants. If the district reduced (K-5) 2 12 7 4 Assistants 2 Aides 15 0 the number of 1-to-1 positions by half, it would capture a cost savings of $69,977. Source: School Services of California, 2011, district documents *SSC recommendations based on full-time equivalents of instructional assistants, district represents .5 part-time instructional assistants fiscal crisis & ManageMent assistance teaM rialto unified school district 34 35 STAFFING RATIOS AND CASELOADS STAFFING RATIOS AND CASELOADS Autism Spectrum Disorders The district mild to moderate SDC average class sizes for preschool is 17 students to one teacher. No district MOU maximums apply to preschool SDCs, but the preschool class size is higher Elementary autism classes have an average of six students per class, much lower than than recommended by School Services. the district MOU maximum of 15 students and below the School Services guideline of eight students. Autism classes have an average of four instructional assistants. According Average size for mild to moderate elementary school classes (K-5) is 15, which is within the to the data provided to FCMAT, no 1-to-1 positions are assigned to autism program district MOU maximum and above the School Services guideline. The district has an average students, which is unusual. of 16 students per middle school mild to moderate SDC, which is within the district MOU maximum and slightly higher than the School Services guideline. High school mild to moderate Overall, moderate to severe average class sizes are below the district MOU maximum in all SDCs have an average of 17 students, which is less than the district MOU maximum and higher programs; however, most are within the School Services guidelines. The equivalent of two than the School Services guideline. instructional assistants per classroom is also within these guidelines. These guidelines indicate one or two instructional assistants for each preschool mild to moderate Creating some full-time instructional assistant positions for intense classes such as programs for SDC with 10 to 12 students. School Services also recommends one instructional assistant per the autistic and emotionally disturbed may be more efficient and effective. These classes cannot elementary class with 12 students or middle/high school class with 12 to 15 students. The operate efficiently with frequent vacancies and a high number of substitutes. following summarizes the instructional assistants for mild to moderate SDCs. Recommendations Mild to Moderate Special Day Class Instructional Assistant (IA) Ratios The district should: # Mild to Moderate Average IAs per Level Classes Number of IAs class 1:1 IAs 1. Consider reducing the number of 1-to-1 instructional assistants in multi- Preschool 1 3 3 2 handicapped classes by at least half. K-12 37 79 2 16 2. Consider reducing the number of 1-to-1 instructional assistants in ED classes Source: School Services of California, 2011, district documents by at least half. Preschool classes have an average of three instructional assistants, with an average of two per mild to 3. Consider providing two full-time 1-to-1 instructional assistants in ED and moderate elementary, middle, and high school SDC. In addition 18 1-to-1 positions are assigned to autism SDCs instead of four part-time positions. individual students in mild to moderate SDCs, a high number that costs the district approximately $251,919 a year. The district could save approximately $125,959 by reducing that number by half. Mild to Moderate Special Day Class Caseloads The instructional assistant assignment list provided to FCMAT indicates the program and teacher to The district operates self-contained SDCs at the elementary, middle and high school level for which each position is assigned. Instructional assistants are assigned to eight teachers who are not on students with mild to moderate disabilities. The district MOU maximum SDC sizes apply to these the special education caseload list or the Human Resources Department’s staff list. Because of this, it classes. The Education Code does not indicate maximum caseloads for mild to moderate SDCs; was not possible to accurately divide instructional assistant ratios by grade level clusters, so they were however, School Services has developed guidelines. The following table shows a summary of mild to calculated as an overall K-12 ratio. Not knowing instructional assistant assignments is inefficient and moderate class sizes and compares them to MOU maximums and the School Services guidelines. can be costly to the district. Mild to Moderate Special Day Class Size Ratios The Special Education Department does not maintain up-to-date and accurate class loadings and instructional assistant assignments, nor does it regularly communicate with Human Resources. School Services The Human Resources list includes vacancies, and the special education lists do not; the district Total Total Recommended RUSD MOU should have consistency in the data that is gathered and used for staffing decisions. Because the Level Teacher FTE Total Students Ratio Guideline Maximum data provided to FCMAT for the mild to moderate SDC assignments is unreliable, this analysis Pre-K 1 17 (two sessions) 1:9 NA Applies to K-12 only provides only an estimate of instructional assistant staffing in this area. This is an area of ineffi- K-5 13 189 1:15 1:12 15 ciency that the district should closely examine and develop systems and processes for monitoring Middle School 11 175 1:16 1:12-15 18 staff assignments and caseloads. High School 13 225 1:17 1:12-15 20 Source: School Services of California, 2011, district documents Recommendations The district should: 1. Develop a system for monitoring and tracking mild to moderate SDC caseloads including teachers, number of students per class, and instructional assistants. fiscal crisis & ManageMent assistance teaM rialto unified school district 36 37 STAFFING RATIOS AND CASELOADS STAFFING RATIOS AND CASELOADS 2. Regularly monitor teacher assignments, class sizes and instructional assistants assignments found that 24 are listed as assigned to teachers who are not on the Special Education and align with the Human Resources Department data. resource specialist caseload list, and 16 are assigned to teachers who are not on the Human Resources Department’s list. 3. Evaluate the need for 18 1-to-1 instructional assistants and consider reducing The inconsistency between the data sources provided by the district indicates that instructional the number by half if appropriate. assistant assignments, teacher assignments, and caseloads are monitored inefficiently. In addition, the number of instructional assistants assigned to the resource program is significantly higher Resource Specialist Programs (RSP) than recommended by School Services guidelines. Education Code 56362 indicates that the maximum caseload for resource specialist teachers is The district spends approximately $946,248 per year in salaries and benefits for 102 part-time 28 students. District data, summarized in the following table, indicates that a total of 19 FTE instructional assistants assigned to the resource specialist program. The Education Code requires RSP teachers work at the elementary school level, with an average of 19 students per teacher. only 80% of the resource specialists to have an instructional aide. The district provides 100% This caseload ratio is significantly lower than the maximum amount allowed by Education Code. of the RSP teachers with aides. By implementing this requirement, the district could reduce the District middle and high school RSP teachers maintain average caseloads of 26 students, which is instructional aide support for RSP programs by 18 positions, which would yield an approximate slightly less than the statutory maximum caseload of 28. The overall district caseload ratio is one savings of $251,919. teacher to 23 students and falls below the Education Code maximum. Comparison of Resource Specialist Caseloads to Education Code Caseload Recommendations Guidelines. (E.C. 56362) The district should: Education Code Total Guideline Ratio Total 1. Develop a system for monitoring and tracking RSP teachers, caseloads and Teacher Total Total (FTE to Student Instructional instructional assistant assignments in the resource program and regularly Level FTE Students Ratio Caseload) Assistants monitor this data. Elementary 19 370 1:19 1:28 2. Consider reducing the number of RSP teacher FTEs so it more closely aligns Middle/High 26 678 1:26 1:28 with the Education Code, particularly at the elementary level. Total 45 1,048 1:23 1:28 102 Source: California Education Code 56362, district documents 3. Consider reducing the number of instructional assistants assigned to RSP teachers by 18 positions. If the district increased RSP caseloads to the Education Code maximum, it could reduce the number of teacher FTEs from to 45 to 37, for a total savings of eight FTE. Because the average Designated Instructional Services (DIS) cost of RSP teacher salary and benefits is $93,651 this would save the district $749,208. Because of logistics, student needs, and the unique programming structure at the middle and high The Special Education Department does not maintain separate caseload lists for monitoring schools, it may not be feasible to make a reduction of this size while maintaining appropriate all designated instructional services (DIS) caseloads weekly to monthly. The department can course offerings and class sizes. However, the district should make a reduction at the elementary process these lists through a computerized system; however, up-to-date individual lists should be school level, where caseloads are significantly below the Education Code maximum. One teacher maintained and updated weekly. There are discrepancies between the computerized reports and should be assigned to two sites to reduce the number needed. the caseload lists. FCMAT compared the resource specialist program teacher caseload data with the list of resource The district has one behavior analyst and a behavior aide, but no behavior team. The teachers teachers provided by the Human Resources Department and found it did not match. Three struggle with the behavioral needs of the students, and the suspension rate is reportedly high. A teachers on the Special Education caseload data did not appear on the Human Resources teacher behavior team can support crisis intervention and ensure that behavior support plans are devel- list, and approximately four teachers on the latter list were not on the former list and have oped and monitored. The district needs two additional behavior specialists and two instructional unknown caseload amounts. As a result, these four teachers were not included in the caseload assistants who are highly trained in behavior management to provide support districtwide. ratio calculation. This suggests that the caseload ratios are inaccurate and could be lower or Mental health funds may be used to fund these positions. higher than indicated in the above table. The Special Education and Human Resources depart- District caseloads for speech language pathologists (SLPs) were compared to the recommended ments should regularly communicate all data sources to ensure that staffing lists can be aligned. Education Code maximums (EC 56363.3[K-12] and 56441.7 [ages three to five]) and are These discrepancies indicate a significant area of inefficiency in the special education program outlined in the following table). Comparisons to Education Code maximums were made for that needs to be closely examined and addressed. kindergarten through 12th grade and preschool since there are different maximums for these two A total of 102 instructional assistants are assigned to the resource program, according to data grade level groups. provided to FCMAT. Two are assigned as 1-to-1 aides. Almost all the resource teachers are assigned two instructional aides per day, and most work part-time. A review of instructional aide fiscal crisis & ManageMent assistance teaM rialto unified school district 38 39 STAFFING RATIOS AND CASELOADS STAFFING RATIOS AND CASELOADS Speech Language Pathologist Caseload Comparison Each psychologist is assigned to various school sites, where they maintain a worksite office. In addi- tion, all school psychologists are provided with a desk and workspace at a central office. Providing District each school psychologists with another office/work space in a district centralized location is inef- Total Caseload Ratio Average Ed. Code Guideline ficient since the school sites are not spread across an unusually large geographic area. Instead, one (Total FTE to Total Caseload Ratio Ratio (FTE to workstation could be set up at the central office and shared by the psychologists on an as-needed Provider Student Caseload) Student Caseload) basis. Test scoring programs and other needed materials could be located at a shared workstation. Speech-Language Pathologist (SLP) K-12 14.75:777 1:53 1:55 SLP Two secretaries are assigned to the school psychologists. The psychologists’ work and role Preschool 2:82 1:41 1:40 typically do not require the support of a secretary except when ordering testing materials and supplies, and this would not require two full-time secretaries. Utilizing the secretaries to support Source: Ed Code 56563.3 for ages five to 22 and 56441.7 for ages three to five, district documents. the special education coordinators would be a more appropriate use of their time. The Education Code maximum for SLPs serving K-12 students is 55. District data indicates that The following indicates the district’s caseload ratios of DIS providers. The district provides APE, it has 14.75 FTE SLPs serving K-12, and two are contracted through an NPA. The district case- VI teachers, and DHH teachers, and the SELPA provides occupational therapists, physical thera- load average for SLPs is 53 and falls within the Education Code maximum. The Education Code pists and two autism specialists. maximum caseload for SLPs serving preschool students is 40, and the average district caseload is Designated Instructional Service (DIS) Provider Caseload Comparison 41, consistent with the Education Code maximum. Speech and language assignments are unevenly distributed. Caseloads should be regularly moni- District Total Caseload SSC Guideline tored and leveled so that the distribution of responsibilities is spread evenly across SLPs. Ratio (Total FTE District Ratio to Total Student Average (FTE to Student The staff reported that caseloads are sometimes not leveled. Leveling is a method that uses a Provider Caseload) Caseload Ratio Caseload) chart to assign each student receiving speech and language services with a factor of 1, 2, or 3, Adaptive Physical Education (APE) 5:165 1:33 1:45-55 depending on the level of services provided, type of disability, and grade level. The factors are Visually Impaired Itinerant (VI) 1:7 1:7 1:10-30 totaled to determine caseload sizes. Each speech and language therapist is assigned a propor- Deaf & Hard of Hearing Itinerant 1:14 1:14 1:20-30 tionate share of the total services provided. Deaf & Hard of Hearing Itinerant-NPA .30:4 1:13 1:20-30 The average salary and benefits for an SLP is $90,157, which is not higher than any other district Source: School Services of California, 2011, district documents in the area. The district does not pay less to contract with an NPA for SLP services. The district pays $85 per hour for NPA SLP services, however, it pays on average $70 per hour to its district The Education Code does not include maximum caseloads for the DIS providers listed in the speech therapists. Therefore, it would not be cost-efficient to use contracted services instead of above table; however, School Services guidelines are used as the standard of practice for efficient hiring to fill positions. special education staffing. The following table indicates the district school psychologist staffing ratio compared to the School Services’ recommended number of APE teachers to students is 45-55, and district APE statewide average established by California Education Facts (CalEdFacts). The Education Code teachers have a caseload ratio of one teacher to 33 students, much lower than the recommended has no guideline for determining school psychologist staffing ratios. The standard of one school number. The district could reduce the number of APE teachers to 3 FTEs instead of 5 by aligning psychologist to 1,466 K-12 students was published in California Education Facts (CalEdFacts) with the School Services recommended caseload of 55. Based on the district average salary of for 2010-11. According to district data, school psychologist caseloads average one school $86,931 for APE teachers, this would result in a cost savings of approximately $173,862. psychologist to 1,765 students. APE teachers have from 30 minutes to three hours each day for office/assessment. One teacher School Psychologist Caseload Comparison has three hours of office/assessment time built into his schedule three days of the week, and another teacher has a one-hour prep period daily in addition to office/assessment time. Two APE FTEs by District District CalEdFacts teachers have site time with no caseload students scheduled each day. Some APE teacher sched- Provider Category Enrollment Ratio Staffing Ratio ules also indicate that their workday starts at 6:30 a.m. and 7 a.m. on school sites where school School Psychologists 15 26,485 1: 1,765 1:1,466 does not begin until 7:25 a.m. or later. Their day is scheduled to end at 1:30 p.m. or 2 p.m., and Source: California Education Facts (CalEdFacts) 2010-11, district documents students at most sites do not finish their school day until 1:45 p.m. at the earliest and later for middle and high schools. The 15 district school psychologists are on a separate management salary schedule from other special education providers. All school psychologists work 1 FTE. Half their salary is paid from It is unclear how these teachers can attend after-school IEP meetings when staff workdays are special education and the other half from educationally related mental health services and the scheduled to end as early as 1:30 p.m. or 2 p.m. Some IEP meetings can take place during the general fund. school day; however, it is often necessary to hold them after school. This is an inefficient and ineffective use of time and creates fiscal inefficiencies. The district should evaluate this area and take steps to increase efficiency in staffing and provision of services and scheduling. fiscal crisis & ManageMent assistance teaM rialto unified school district 40 41 STAFFING RATIOS AND CASELOADS STAFFING RATIOS AND CASELOADS One VI teacher has a caseload of seven students, and the School Services guideline is 10-30 The district has an informal procedure of requesting additional instructional assistants; however, students per teacher. some staff indicated that these guidelines are not always followed, and a few staff were unaware of them. The Special Education Department does not evaluate the ongoing need for instructional One DHH teacher has a caseload of 14 students compared to the School Services guideline of aides assigned to the classrooms or to specific students. When an IEP team determines that 20-30 students. Four district students require auditory verbal therapy (AVT), but the closest additional support is warranted, the team does not include a fading plan for these services. Lack location to obtain this service is Long Beach, which would require a long travel time for one and of effective departmental and district communication plays a large role in these inconsistencies. half days a week and be costly for the district. Instead, the district contracts with a qualified NPA SLP for .30 FTEs at a cost of $95 per hour. This is more cost effective and eliminates travel time The district has not implemented an articulated system of assigning and fading 1-to-1 instruc- for district staff and students. tional assistants. The lack of fully implemented policy and procedures increases the potential for adversarial IEPs because no structure exists to guide decisions when a 1-to-1 instructional Recommendations assistant is requested or recommended. The IEP team does not include a fading or exit plan for services when it determines that placement of a 1-to-1 instructional assistant is appropriate. The district should: Because policy and procedures are followed inconsistently, teachers are unclear on when they can decline a request. Once a 1-to-1 aide is assigned, the Special Education Department does not 1. Regularly maintain and monitor current and accurate caseload lists. re-evaluate to determine if the position is still necessary for the student to benefit from education. 2. Consider creating a behavior team. The Special Education Department provides no training or routine guidance for 1-to-1 assistants. 3. Consider hiring NPA SLPs as attrition occurs with the SLP staff. The department should determine the 1-to-1 assistants’ performance and the training needed by the staff. The district also does not have a master plan for training 1-to-1 assistants. 4. Ensure SLP caseloads are leveled. The department has not assigned a specific staff member to review aide use, analyze student 5. Consider utilizing one shared school psychologist workstation at the central needs, and monitor 1-to-1 assignments. Policies and procedures should clearly define who is office instead of providing each psychologist with a second workspace. responsible for these tasks. The Special Education Department has no database that aligns with 6. Consider reducing the number of APE teachers to align with the School the Human Resources Department to track the placement and movement of instructional assis- Services caseload ratio guidelines. tants. Instead, this is accomplished manually, which impedes efficiency. When a 1-to-1 position becomes vacant or a new position is created, it frequently is filled with a part-time instructional 7. Consider evaluating APE teachers’ schedules so that they more closely align assistant. This creates major vacancy issues for instructional assistants and hinders the instruc- with school site schedules. The district should ensure these teachers spend tional program. adequate time at school sites where they have students on their caseloads. Strictly following policies and procedures provides an opportunity to clearly define the role of the 8. Consider reorganizing the APE teachers’ schedules to omit the school sites special education director, special education staff, and school site administrators. Guidelines can where they have no students on their caseloads. assist district staff when they are challenged by parents and advocates who request these services 9. Consider decreasing the amount of time each day that some APE teachers and promote a focus on students at IEP meetings. The development and implementation of spend in the office, and increasing their time with students. guidelines should be followed by extensive training. Administrators, general and special educa- tion staff should attend mandatory training on using the guidelines. 1-to-1 Instructional Assistants Once policy and procedures are implemented, a review of all instructional assistant placements FCMAT was unable to determine the exact number of district 1-to-1 instructional assistants, but should be conducted to utilize these resources more effectively. the cost for these employees was approximately $699,775 this fiscal year based on the provided Guidelines assist staff with the following decisions: information. 1. Determining the need for additional 1-to-1 assistants. Throughout California the number of districts utilizing instructional assistants, 1-to-1 and special circumstance instructional assistants has significantly increased over the past few years. 2. Determining alternatives to 1-to-1 instructional assistants. This has affected special education budgets and contributions from the unrestricted general fund; 3. Evaluating the continuing need for these services. especially in situations where the services aren’t warranted or monitored and create a sense of dependence. One strategy in determining whether these services are appropriate is to implement 4. Determining when it is appropriate to add additional hours to an existing a policy, procedures, and guidelines while strictly monitoring these services to prevent them from instructional assistant’s contract. being provided unnecessarily. Policy and procedure should include the following components: Many districts use the term special circumstance instructional aides instead of 1-to-1 assistants to indicate that an assignment is temporary. Transitioning or “fading” these services encourages 1. A determination of the appropriateness of assigning a 1-to-1 instructional student independence. assistant to a classroom/student. fiscal crisis & ManageMent assistance teaM rialto unified school district 42 43 STAFFING RATIOS AND CASELOADS PROGRAM EFFECTIVENESS 2. Determination of the need for 1-to-1 instructional assistant assignments Program Effectiveness within a step-by-step structured process. 3. Alternatives to using 1-to-1 instructional assistants. State Assessments FCMAT reviewed the overall student academic achievement for the special education subgroup 4. A determination of whether existing resources are being utilized. at Rialto Unified based on state achievement data from the California Department of Education 5. Incorporation of a fading plan. Standardized Testing and Reporting (STAR) system. These data include results from students in grades two through 11 on the following subtests: 6. Evaluation of the continuing need for 1-to-1 instructional assistants. • California Standards Test (CST) 7. Determination of when it is appropriate to add hours to an existing instruc- tional assistants’ schedule. • California Modified Assessment (CMA) • California Alternate Performance Assessment (CAPA) Recommendations • California High School Exit Exam (CAHSEE) The district should: • California English Language Development Test 1. Develop and strictly follow policy and procedures for the use of special An overview of these subtests can be found at the following Web address on the California circumstance instructional assistants rather than 1-to-1 positions along with Department of Education website: general instructional assistant guidelines. http://www.cde.ca.gov/ta/tg/sr/cefstar.asp 2. Develop and strictly follow policy and procedures to assist with assigning, California Standards Test and California Modified supporting, fading, and dismissing 1-to-1 instructional assistant services. Assessment 3. Develop policy and procedures to include the establishment of monitoring and fading plans at IEP meetings. This is important to promote independence The overall academic achievement for the district’s disabled students from 2011 to 2013 is of the students and to reduce dependence. It is also necessary for efficiency significantly below county and state averages in the percentage who were proficient in the English language arts (ELA) and mathematics subtests. Based on the Title I adequately yearly progress purposes. proficiency targets in ELA and mathematics, the disabled students subgroup had growth of 4. Provide mandatory training to special education staff and school site admin- approximately 2%, missing the federal targets by 25% (2011), 40% (2012), and 60% (2013). istrators on the policy and procedure for determining the need for 1-to-1 Student achievement was slightly higher on the California Modified Exam than the California instructional assistants (special circumstance instructional assistants). Standards Test. A significant gap (greater than 15%) exists between general education students and the special education student subgroup in English language arts and math. While this type of 5. Closely monitor the assignment of 1-to-1 instructional assistants and the gap is common in districts throughout the state, there is also a significant difference between the placement of the student to which they are assigned. state and district average for the special education subgroup in English language arts and math. 6. Evaluate the continuing need for 1-to-1 instructional assistants, and identify Student Achievement Results in Grades 2-11 (CST & CMA) % the specific administrator to analyze 1-to-1 use and student needs. The roles Proficient or Above of the special education director, special education staff, and school site staff % All District % Sp. Ed. Dist. % Sp. Ed. State should be clearly defined. Year ELA Math ELA Math ELA Math 7. Develop a master plan to address districtwide 1-to-1 assistant training needs. 2011 45.6 47.8 25.1 25.6 34.6 36.6 2012 47.2 48.8 27.6 27.6 35.7 37.2 8. Provide extensive training and routine guidance to the 1-to-1 assistants. 2013 45.9 49.6 27.4 27.4 35.1 37.3 9. Determine whether online courses are an efficient way to train 1-to-1 assis- Source: California Department of Education DataQuest - http://data1.cde.ca.gov/dataquest/ tants. 10. Ensure that the placement of 1-to-1 instructional assistants is appropriate for the student and staff. 11. Ensure that the Special Ed and Human Resources staffing databases for 1-to-1 instructional assistants match. fiscal crisis & ManageMent assistance teaM rialto unified school district 44 45 PROGRAM EFFECTIVENESS PROGRAM EFFECTIVENESS California Alternate Performance Assessment Academic Performance Index From 2011 to 2013, the overall academic achievement of the district’s disabled students on the – API Growth California Alternate Performance Assessment varied as compared to the state averages in the Year Overall District Sp. Ed. percentage of those students who were proficient in English language arts. Specifically, the district Dist. State level II (grade 2-3) student scores ranged from 15% below and 15% above the state average. The 2011 746 547 595 district Level III (grade 4-5) students scored between 5% and 10% below the state average over 2012 750 556 605 three years. The district Level IV (grade 6-8) students scores ranged from 18% below and 2% 2013 751 558 615 above the state average. The district Level V (grade 9-11) students scored between 8% below and 14% above the state average in the percentage of those students who were proficient over three Source: California Department of Education DataQuest - http://data1.cde.ca.gov/dataquest/ years. California High School Exit Exam The overall academic achievement in mathematics over a three-year period also varied as compared to the state average. Specifically, district level II students scored between 14% below Another component of the STAR system is tracking the achievement of high school students on and 2% above the state average over three years, and level III scored between 20% below and the CAHSEE. Similar to the achievement results for adequate yearly progress and the API, the equal to the state average over the same time period. Level IV showed improved achievement, district’s student achievement for the special education subgroup is well below state and county scoring 18% above or within 3% of the state average. Level V was similar to level IV, showing averages. District pass rates for the special education subgroup in English language arts and between 5% below and 15% above the state average in the percentage of those who were profi- mathematics over a two-year span (2012-13) was below state averages for the special education cient over three years. subgroup by approximately 19% and below county averages by 14% in English language arts and 5% in mathematics. However, Education Code Section 60852.3 allows for disabled students Student Achievement Results in Grades 2-11 (CAPA) % Proficient or with an IEP or 504 plan to be exempt from meeting the exam requirement to receive a diploma. Above, English Language Arts An overview of the CAHSEE exemption can be found on the following website: Level II Grade 2-3 Level III Grade 4-5 Level VI Grade 6-8 Level V Grade 9-11 http://www.cde.ca.gov/ta/tg/hs/cahseefaqexempt.asp Year Dist. State Dist. State Dist. State Dist. State California High School Exit Exam (CAHSEE) Combined 2011 70 85 74 84 80 78 70 78 Sp. Ed. Population Pass Rate 2012 95 80 77 82 52 70 84 79 Year % State % County % District 2013 83 84 79 86 63 75 95 81 Student Achievement Results in Grades 2-11 (CAPA) % Proficient or ELA Math ELA Math ELA Math Above, Mathematics 2012 39 41 34 35 20 33 Year Level II Level III Level IV Level V 2013 40 42 37 38 24 32 2011 52 63 52 72 83 65 63 68 Source: California Department of Education DataQuest - http://data1.cde.ca.gov/dataquest/ 2012 50 64 70 70 63 66 71 69 2013 67 65 55 65 69 64 86 71 California English Language Development Test Source: California Department of Education DataQuest - http://data1.cde.ca.gov/dataquest/ A third component of the STAR assessment system is English language development. The California English Language Development Test is designed to monitor the achievement of Academic Performance Index English language learners in acquiring English proficiency. District achievement for the special education subgroup over a three-year period was significantly disproportionate to all English The district overall Academic Performance Index (API) over a three-year period had minimal learners districtwide. Most special education English learners scored basic or early intermediate, growth, showing a five-point increase, 746 (2011) to 751 (2013). The API for the special educa- while most English learners who are not identified for special education services scored interme- tion subgroup increased by 11 points (547 to 558) in the same period. The discrepancy in API diate or early advanced. This data suggests that English learners who receive special education scores between the overall district API and special education subgroup API is 193 points (751 services are making significantly less progress in acquiring English as a second language than their vs. 558). When compared to the state API for the special education subgroup, the district is on general education peers. Further analysis is warranted to determine if English learners are appro- average 51.3 points below (48 points in 2011, 49 points in 2012, and 57 points in 2013). priately identified for special education services because of their language deficits. fiscal crisis & ManageMent assistance teaM rialto unified school district 46 47 PROGRAM EFFECTIVENESS PROGRAM EFFECTIVENESS California English Language Development Test (CELDT) Achievement Instruction and Intervention (RtI2) system that could reduce overidentification for special educa- (Initial and Annual) by Level tion by addressing student needs at the lowest level of intervention (Tier 1) in the least restrictive environment. The hallmark of a balanced instructional program is to have an ongoing formative Year % Not Sp. Ed. ELs % Sp. Ed. ELs and summative assessment system to monitor student academic growth to make adjustments in Level A EA I EI B A EA I EI B core instructional delivery as well as to target intervention based on student need. RtI is cited in 2010 12 33 33 13 9 3 12 31 31 23 the reauthorization of the Individuals with Disabilities Education Act (IDEA) of 2004 related to the determination of a specific learning disability and in 34 Code of Federal Regulations 2011 7 29 37 15 11 1 10 31 27 31 Sections 300.307, 300.309, and 300.311. The guide developed by the California Department 2012 7 32 37 15 9 2 12 32 28 25 of Education entitled “Determining Specific Learning Disability Eligibility Using Response to Instruction and Intervention (RtI2)” is available at the following Web address: Source: California Department of Education DataQuest - http://data1.cde.ca.gov/dataquest/ www.cde.ca.gov/sp/se/sr/documents/sldeligibltyrti2.doc‎ Program Improvement Status The district benchmark assessments used for grades 2, 3, 4, and 5 are based on an end-of-year As a result of the overall academic performance and that of the special education subgroup, assessment. The district uses the Illuminate Data & Assessment database to manage benchmark the district is in program improvement status, year 3, based on state and federal accountability assessments and analyze achievement data. This end-of-year assessment assesses the same stan- requirements for Title I. In addition to district program improvement status, 16 schools are in dards during the fall administration (Blueprint Benchmark Form A) and the spring administra- various levels of program improvement. The special education subgroup contributed to this status tion (Blueprint Benchmark 2). The overall student population in each grade level (2, 3, 4, and at each school. 5) shows significantly greater improvement than the special education subgroup in the total This data indicates that student achievement for the special education subgroup on state assess- percentage of students scoring at the mastery level in English language arts (as shown in the ments is of significant concern. State targets were missed by a wide margin and also fell signifi- following table). The special education subgroup in grades 2, 4, and 5 showed minimal increase cantly below the achievement of special education subgroups in the state’s surrounding districts. in this area. Except for grade 3, the achievement gap between overall and special education student achievement on the English language arts assessments is significant. Assembly Bill 484, signed into law on October 2, 2013, replaces the STAR assessment system with the California Measurement of Academic Performance and Progress assessment system District Blueprint Benchmark Assessments – Elementary English (information is available at the following website): Language Arts http://www.cde.ca.gov/ta/tg/sa/ab484qa.asp Sp. Ed Sp. Ed. Students Students This new system, which takes effect on January 1, 2014, proposes a radically new approach to All Students ELA All Students ELA ELA ELA Benchmark 1 Benchmark 2 Benchmark 1 Benchmark 2 % state assessments that includes Computer Adaptive Tests and performance tasks. The introduc- Grade (% Mastered) (% Mastered) % Increase (% Mastered) (% Mastered) Increase tion of the Usability, Accessibility, and Accommodations Guidelines; developed to accompany 2nd 18.55 36.43 17.88 6.29 11.49 5.2 the new Smarter Balanced Assessment Consortium state assessments; may be of greatest impor- 3rd 19.56 33.53 13.97 6.98 17.55 10.57 tance to the special education subgroup. Starting in spring 2014, disabled students (excluding 4th 27.79 37.51 9.72 11.69 14.52 2.83 those taking the California Alternate Performance Assessment) will be required to take the same 5th 39.05 52.08 13.03 12.20 16.33 4.13 assessments as those in general education. These new assessments will have accessibility and accommodation features. More information is available on the Support for Under-Represented Source: RUSD Benchmark Assessment Performance Summary Report 2012-13 page of the consortium website. District benchmarks in mathematics for grades 2, 3, 4, and 5 show a greater increase in student District Assessments mastery for all students than the special education subgroup. All students more than doubled the percentage gain of those scoring at the mastery level. As a result, there is a significant gap between The overall student academic achievement for the special education subgroup was also reviewed the all-student subgroup and the special education subgroup in mathematics as a result of these based on district benchmark assessments in grades 2 to 5, 6, 8, and 10. While the district uses assessments. the Dynamic Indicators of Basic Early Literacy Skills assessment as a benchmark exam for kindergarten and first grade, insufficient data was available for the special education subgroup. As a result, this report will not include an analysis of student achievement for special education students in kindergarten and first grade. Additionally, no data was available for kindergarten and first grade in mathematics, therefore, a comparative analysis could not be developed. The lack of achievement data for these two grade levels creates a significant inequity between general education and special education students. Gathering and analyzing student progress in foun- dational literacy skills and foundational mathematics is a key aspect of an effective Response to fiscal crisis & ManageMent assistance teaM rialto unified school district 48 49 PROGRAM EFFECTIVENESS PROGRAM EFFECTIVENESS One measure of an effective behavior system is the suspension expulsion rate. While the district District Blueprint Benchmark Assessments – Elementary Mathematics expulsion rate for students with special needs is within state targets, the suspension rate for the Sp. Ed. same subgroup is disproportionately high compared to all students. One example is the rate of All Students All Students Sp. Ed Students Students Math Math Math Math suspension by federal offense. For the all-student subgroup, 8,216 suspensions were recorded Benchmark 1 Benchmark 2 Benchmark 1 Benchmark 2 for the 2011-12 school year, approximately 15% of the total student population (although some Grade (% Mastered) (% Mastered) % Increase (% Mastered) (% Mastered) % Increase students are suspended several times). 2nd 14.97 49.39 34.42 9.30 23.73 14.43 3rd 18.22 45.23 27.01 6.90 20.71 13.81 The special education subgroup had 1,532 suspensions in the same period. While 11% of the 4th 23.55 45.83 22.28 12.61 21.43 8.82 total student population is identified as having an IEP, students with special needs represent 18% 5th 20.87 42.79 21.92 7.32 18.75 11.43 of the suspensions by federal offense. Students with special needs are four to five times more likely to be suspended than a typical district student. A review of the suspension data found Source: RUSD Benchmark Assessment Performance Summary Report 2012-13 that these results hold steady. Suspensions due to defiance show a disproportionate percentage of students with special needs. Of the total number of students suspended for this reason in District benchmark data for secondary schools was reviewed for grades 6, 8 and 10. This achieve- 2011-12 (4,188), 18.2% had special needs (763). This is significant since many special education ment data shows similarities with the elementary benchmark achievement data. Specifically, students have some type of behavioral goals included in their IEP. significant achievement gaps exist between the all-student population and special education subgroups. However, only one benchmark data point was available at the time of this analysis. Certificated Staff Interviews The difference in achievement at the mastery level was between 7% and 24% in English language arts. For mathematics, one benchmark assessment was available for each grade level (sixth grade FCMAT interviewed 15 certificated teaching staff members during this study, including general general math, eighth grade algebra, and 10th grade geometry). Tenth-grade geometry was 1.83% education, resource specialists, and special day class teachers. The interviews consisted of 20 higher for disabled students than all students. closed- and open-ended questions that related to multiple aspects of the instructional program in kindergarten through grade 12. A few general themes surfaced related to teaching and learning, District Blueprint Benchmark Assessments – Secondary English Language and they are outlined by topic below. Arts & Mathematics Sp. Ed. English Language Arts (ELA) All Students Sp. Ed. All Students Students ELA Students ELA Math Math All resource program teachers and general education teachers were familiar with and consistently Benchmark Benchmark Benchmark Benchmark Grade (% Mastered) (% Mastered) % Difference (% Mastered) (% Mastered) % Difference used the district-adopted core instructional program in English language arts for their respective 6th Q2 12.74 5.26 7.48 29.36 14.16 15.2 grade levels. They also indicated that they received training in using the English language arts 8th Q3 51.01 23.64 27.37 19.87 9.29 10.58 program, but this occurred many years ago. SDC teachers were not as familiar with the core 10th Q3 60.86 36.94 23.92 23.02 24.85 -1.83 English language arts program and did not indicate consistent use in their classrooms. Most teachers indicated they use other supplemental materials in planning and delivering lessons in Source: RUSD Benchmark Assessment Performance Summary Report 2012-13 English language arts, including sight word lists, adaptive readers, fluency readers, vocabulary worksheets, Read Naturally, skill-based computer programs, Reading A-Z, and Language! ELD Graduation Rate workbooks. District graduation rates for disabled students fell significantly below typical peers, measuring Mathematics 22.4%, 27.9%, and 28.9% below in 2011, 2012, and 2013, respectively. These rates are within the state targets (indicator 1 of District Level Special Education Annual Performance report, Teachers had inconsistent knowledge of the district-adopted core instructional program in California Department of Education). mathematics. Many teachers were not familiar with the name of the district’s core mathematics program. Many indicated they use other supplemental resources during math instruction such Suspension Rate as manipulatives, algebra tiles, black line masters, Singapore math, Basics 2 curriculum, assorted website resources, and ancillary materials that go with the district core instructional program. One of the core components of an effective RtI2 system is the use of positive behavioral supports. The document available at the following Web address includes more information on RtI2: Professional Development and Collaboration http://www.cde.ca.gov/ci/cr/ri/rticorecomponents.asp, in2. All teachers indicated that they received at least some level of professional development in The Individuals with Disabilities Education Act (IDEA) of 2004 promotes the use of academic English language arts and mathematics, but most indicated that occurred many years ago. All and behavioral systems to ensure achievement for all students, including those with disabilities. teachers indicated they have opportunities to collaborate with their general education and special education colleagues either weekly or monthly. fiscal crisis & ManageMent assistance teaM rialto unified school district 50 51 PROGRAM EFFECTIVENESS PROGRAM EFFECTIVENESS Instructional Planning provides timely academic and behavioral supports starting in tier 1 (general education classrooms), progressing through consistent tier 2 interventions, Half the teachers interviewed indicated that they develop lesson plans one week before lessons. A and culminating with tier 3 interventions only after tier 1 and 2 supports few teachers indicated that they use a yearly unit plan to inform their lesson plan development. have been exhausted. Slightly less than half the teachers indicated they develop lesson plans on the day of the lesson or sometimes during the lesson itself. There was some indication that secondary special education 6. Ensure all students, including students in special education, participate in all teachers are confused about the role of the resource specialist in planning lessons that are deliv- district benchmark assessments (both formative and summative) in English ered in general education. language arts and mathematics, including students in kindergarten and first District Benchmark Assessment grade. 7. Develop and implement a districtwide collaboration procedure that uses state Two-thirds of the teachers indicated they administer the district benchmark assessments in English language arts and mathematics; however, less than one-third stated they use the English and district student achievement data (formative and summative) to drive language arts assessment data to inform their lessons. Slightly less than one-half of the teachers conversations and inform lesson design and delivery in all grades K-12. The indicated that they used the mathematics assessment data to inform their lessons. district should ensure that this procedure includes opportunities for special education staff to work in collaboration with general education staff. Strength of the Special Education Program 8. Audit all instructional program placement for English learners who have All teachers were asked to identify one or more strength(s) they felt exemplified the Special been identified for special education to ensure that they receive high quality Education Department. The responses were varied, with no clear theme. English language development instruction daily. 9. Audit the assessment process used for initial IEP identification to avoid overi- Weakness of the Special Education Department dentification of English learners for special education. All teachers were asked to identify one or more weakness of the Special Education Department. 10. Analyze the master schedule development procedure in secondary schools Two themes surfaced. Many indicated that overall communication from the district to the to address the ratio of diploma-bound vs. non diploma-bound tracts and to schools should be improved and that opportunities are needed for organized collaboration and ensure that students are placed in the least restrictive environment as much as training among special education staff. possible. Recommendations 11. Develop and actively promote the use of a positive behavior support program throughout the district to proactively address maladaptive behavior at the The district should: lowest level. 1. Ensure that all students with special needs have access to, and use state- 12. Form a special education taskforce (composed of representatives from all approved, district-adopted core instructional materials in English language groups affected) to research exemplary special education programs and make arts and mathematics daily. recommendations that will lead to developing a special education strategic plan. This plan will define the service delivery model for supporting students 2. Ensure that all special education staff have access to updated training in using with special needs. supplemental instructional program materials in English language arts and mathematics that are aligned to the Common Core State Standards. 3. Audit the instructional program structure and curriculum guides for all self-contained special day classrooms districtwide to determine the level of coherence and alignment to state expectations for students with significant disabilities. 4. Ensure high expectations are identified and maintained for disabled students to meet grade level standards provided they are given the necessary interven- tions, accommodations, and/or modifications. 5. Develop and implement a districtwide Response to Intervention plan that focuses on early identification of need through universal screening, and fiscal crisis & ManageMent assistance teaM rialto unified school district 52 53 PROGRAM EFFECTIVENESS COMMUNICATION Communication Interdepartmental Communication The district has no formalized systems for communication between Special Education, Finance, Human Resources or Education Services. Special education staff met with the Business Department during initial budget development to review the 2012-13 budget and determine whether increases would be needed in the 2013-14 budget, and if so, where. Because a special education budget normally fluctuates during the year, it is important for the Business Department to be aware of these fluctuations. Special education continued to meet informally with the Business Department in the past year regarding potential increases in the special education budget. Documentation for budget changes was not provided at these meetings, nor were the meetings regularly scheduled. Staff indicated the Business Department frequently was not aware of changes that significantly affected the Special Education budget until they were notified by the SELPA. The two departments should meet monthly to review staffing, nonpublic school placements, nonpublic agency services, out-of-district or out-of-SELPA placements, due process or complaints and mental health funding. This will ensure that the district does not rely on the SELPA for this information. These meetings should have agendas that are developed by both departments and are available for review 24 hours before the meeting. Summary notes of discus- sion and specific outcomes should be documented. According to staff, the Special Education Department historically has always been treated as a separate entity, and many district departments operate independently. This is further compli- cated by the fact that Special Education is under the Student Services Department instead of Educational Services. Special Education should be included in the district’s overall structure and be connected to the curriculum and instruction department. The Special Education and Curriculum and Instruction departments have little communication, but increasing this would require a cultural shift for the entire district. Communication between the Business, Human Resources and Special Education departments is inadequate. The three departments do not have monthly scheduled meetings to discuss issues such as vacancies, budgets, staffing needs, proposals for growth and reductions, and more effi- cient operation. The three departments formally meet once a year to develop the special educa- tion budget; however, they do not always coordinate staffing to ensure awareness and consistency. The Special Education Department lacks long-range staff planning, projections, and budget development. Parent Communication An extensive review of the district’s website to determine its impact on parent communication found that the site’s usability is lacking for an average parent who is moderately familiar with Internet navigation. While the district’s main Web page is presentable and has basic website links for interactivity, many of the parent links are difficult to find or broken. Furthermore, the links in the “PARENTS/GUARDIANS” drop-down menu do not provide sufficient narrative to enable a parent to fully understand the information provided. Of the 14 subtopics listed in the dropdown menu, three links were broken (Transportation, RUSD Parent Center, and Safety/Security). fiscal crisis & ManageMent assistance teaM rialto unified school district 54 55 COMMUNICATION COMMUNICATION Another aspect of the district’s website that could be difficult for parents to use is the Recommendations “DISTRICT ADMIN.” drop-down menu. Parents would respond more positively to a menu with an overview of the district’s different departments. Of the eight subtopics in the drop-down The district should: menu, only one (Ed. Services) has a narrative that parents can read on the purpose of the depart- 1. Develop a separate Web page as part of the district website dedicated to ment. Perhaps the single biggest omission on the district website is the complete lack of infor- providing parents with an overview of special education program services, the mation directly related to programs for special needs students. A robust, interactive Web page support structure, and parent involvement/education opportunities. dedicated to special education programs would help the parents of these students stay informed about programs and services. The district should also consider making computer stations avail- 2. Include on the page a section that directs parents to appropriate staff who can able at each school for parents and community members who lack access to the Internet. answer questions and/or address concerns. On October 15, 2013 FCMAT conducted three parent input sessions (morning, afternoon and 3. Provide an anonymous survey link for parents to voice their concerns, and evening) with 19 parents in attendance. In preparation for these sessions, 2,035 phone calls were provide input on program service and on topics for parent education. made to parents of disabled students through Parent Link and 86% were delivered successfully, with 14% that could not be delivered. 4. Restructure the overall website layout to include clearly defined department Parents in the focus group reported that many families lack computers or e-mail access; however, buttons (links) that bring parents directly to key information for each depart- the district reported that in a 2009 survey, 73% of parents had these. The district should ment. re-evaluate the status of parent access to computers and e-mail. 5. Establish new benchmarks that define parent access to e-mail and computers Parents were unaware of any options at the district or school sites for them to access the district in the district through updated information from parents. website; the district reported that the public have access to computers and Internet at the public 6. Ensure that parents are aware of options for public access to the Internet library located on the Carter High School campus. available in the district. Parents attending the focus session indicated that they have no opportunities to provide input to the district or participate in program development. Parents have little trust in the district and 7. Ensure that the Special Education Advisory Committee operates in alignment stated that they include advocates and attorneys in the IEP process because the schools do not with other district committees. seriously consider their opinions. 8. Complete and implement bylaws in alignment with other district parent The Special Education Advisory Committee operates as a district-sponsored advisory for special committees. education parents. However, parents complained that they do not have access to the committee to provide input; attendance is limited to board members. The committee is newly formed and 9. Provide a mechanism for parent input into the development of special educa- should follow all guidelines for district advisory committees, including finalization of the draft tion programs and services. bylaws. 10. Provide parents with the opportunity for input into parent training opportu- The committee has provided three parent training sessions, but the district has offered none on nities. support strategies for the home, the curriculum in general education classrooms, or the parent 11. Include the parents of special education students in parent education on the role in the IEP process. The district sponsors no support groups for the parents of students with Common Core State Standards. specific disabilities. In addition to the parent focus groups, FCMAT also offered parents the opportunity to provide 12. Develop options for parent support groups in disability areas. confidential written feedback. Parents indicated that they did not trust the district to deliver 13. Hold monthly meetings between Business, HR and Special Education depart- confidential feedback so the team made arrangements to receive them in person on October 31, ments. 2013. No written feedback was provided. 14. Transfer the Special Education Department to the Department of Educational Services. 15. Ensure special education administration is represented on the cabinet. fiscal crisis & ManageMent assistance teaM rialto unified school district 56 57 COMMUNICATION PROGRAMS, PROCEDURES, MISSION, AND BELIEFS Programs, Procedures, Mission, and Beliefs Procedural inconsistencies, ineffective communication systems, and poor data management have resulted in numerous inefficiencies throughout the district. There is also a systemic lack of focus on instruction and lack of guidance from the highest level of leadership. The district’s mission statement, “is to provide high levels of learning for all students and to inspire people to set goals that maximize their potential.” However, the mission is not consis- tently aligned with the programs and procedures in special education or the district as a whole. The district’s program delivery model at the secondary level was converted to what the district calls a collaborative model, but the site staff did not receive training or guidance when the conversion occurred. Staff is unable to explain this model. Middle schools and high schools operate mainly in a traditional framework of RSP or SDC programs. Although the district made some recent changes to its program model, most students are placed in one program or the other and do not have the opportunity to participate in a combination of programs depending on their academic, developmental, adaptive and social-emotional needs. This is not the most effective means of providing special education services. Throughout the state, middle schools and high schools are expanding their special education continuum to include programs such as learning centers, co-teaching, collaboration and push-in services. Some of these programs include providing special education teacher support inside the general education classroom for a period of time each day/week and pairing special educa- tion teachers with general education teachers to provide daily joint instruction. These teachers work with their counterparts in general education to provide assistance with accommodating curriculum, tests, homework and implementing classroom accommodations for special education students. The continuum includes flexibility that allows students to participate in a combination of service options depending on their individual needs rather than being limited to all special day class (SDC) or resource specialist program (RSP) services with mainstreaming. A combination of services may be provided to best meet the unique needs of each individual student. The certificated collective bargaining agreement includes language that would enable the district to expand its special education program continuum. It reads as follows: ARTICLE XVII: DISTRICT RIGHTS AND AUTHORITY It is understood and agreed that the District retains all of its duties, powers and authority to direct, manage, and control to the full extent of the law. Included in, but not limited to, these duties and powers are the exclusive right to: determine its organization; take appropriate legislative action; direct the work of its unit members; determine the times and hours of operation; determine the kinds of levels of services to be provided, and the methods and means of providing them; establish its educational opportunities of students; determine staffing patterns and the kinds of personnel required; maintain the efficiency of District operations; determine the curriculum; build, move or modify facilities; develop a budget; determine allocations; raise revenues; and to contract out services and/or work to be done in accordance with the law; and to take action on any matter in the event of an emergency. Although district exit rates are comparable to those of the SELPA, staff indicated they do not always transfer or “exit” students when they no longer qualify for special education. The Special Education Department does not use exit criteria guidelines to determine continued eligibility for special education services. The district should develop and implement exit or dismissal criteria fiscal crisis & ManageMent assistance teaM rialto unified school district 58 59 PROGRAMS, PROCEDURES, MISSION, AND BELIEFS SPECIAL EDUCATION TRANSPORTATION Special Education Transportation guidelines for efficiency and caseload purposes, and these should also be used to determine continued eligibility. This type of criteria is used for “fading” or dismissing students from services Of the district’s enrollment of 26,485 students, approximately 3,083 have an IEP based on the when the disability no longer exists or no longer adversely affects the student’s educational perfor- June 30, 2013 pupil count. Of those, approximately 305 are transported on 16 district-operated mance. Over time, this can lead to elevated student numbers for certain services. Some SELPAs routes. The San Bernardino County Superintendent of Schools transports approximately 296 and school districts use a dismissal criteria checklist to help with this process. students on a contract with a for-profit school transportation provider, First Student. Beginning Staff reported that Special Education job descriptions are out of date. Revised job descriptions with the 2013-14 school year, the district also has a contract with American Logistics to transport will facilitate the district’s ability to design more appropriate and efficient models of service approximately 25 students previously transported by the county office. delivery. The district should work with the certificated collective bargaining unit to revise these. School Transportation Finance Recommendations Before 1977, school transportation operational costs were fully reimbursed in California. After Proposition 13, the state slowly reduced the percentage of reimbursement. In the 1982-83 school The district should: year, the state capped the reimbursement at 80% of the reported costs for each school district. Over the years, an occasional cost-of-living adjustment (COLA) has been granted to the fund, 1. Ensure that the administration, teachers and service providers have the oppor- but it has been insufficient to keep up with the rising cost of providing pupil transportation in tunity to work collaboratively to realign programs. many school districts. On a statewide basis, this funding covers approximately 35% of reported 2. Develop exit/dismissal criteria guidelines for all special education services. costs. Because Rialto Unified grew significantly in the past 31 years, its funding is far less than the actual need. 3. Dismiss special education when a student no longer qualifies, using an exit/ Pupil transportation costs are reported in two resource areas in the California school accounting dismissal criteria. system. Resource 7230 is for regular home-to-school transportation, and resource 7240 is for 4. Address the staff perception regarding the inability to exit or dismiss students severely disabled/orthopedically impaired (SD/OI) transportation. Below is a snapshot of Rialto from IEPs when it is appropriate. Unified School District’s report. TRAN Data 5. Evaluate the option of using the learning center model to broaden the continuum of services available to students. 2011-12 2011-12 2012-13 2012-13 HTS SD/OI HTS SD/OI 6. Implement exit/dismissal criteria guidelines. # Buses 33.8 43.0 30.8 40.9 7. Consider using the collective bargaining language to expand the district’s # Students 3084.5 359.7 3029.5 421.3 continuum of services as needed. # w/IEP 13.0 140.0 18.0 153.0 # Miles 294,881.7 297,250.6 287,227.3 316,841.0 8. Align the district’s mission with its programs and procedures. Revenue $601,818.00 $202,571.00 $604,336.00 $203,717.00 9. Provide site training regarding the collaborative model. Approved Cost $2,653,729.18 $2,165,798.24 $2,277,302.96 $2,360,517.27 Cost/Mile $8.84 $7.29 $7.93 $7.45 10. Update the job descriptions. Cost/Pupil $844.65 $ 6,021.12 $751.71 $5,605.60 District Contribution $2,051,911.18 $1,963,227.24 $1,672,966.96 $2,156,800.27 Source: District documents Home-to-school transportation can include nonsevere special education students. SD/OI data is intended to report students in wheelchairs and those who are more severe. In addition to the data that is specific to the district’s bus fleet, the district’s TRAN data includes data on buses, students, miles and cost for some students transported by the county office. The county office provides some transportation for the district on its contract with First Student and separates its excess cost projections for districts into two areas. One is based on students who are considered to be from the East Valley SELPA. Approximately 125 students are included on this spreadsheet (referred to as cost spreadsheet 271 and attached as part of Appendix A to this report). The second spreadsheet is for district transportation costs. This spreadsheet includes fiscal crisis & ManageMent assistance teaM rialto unified school district 60 61 SPECIAL EDUCATION TRANSPORTATION SPECIAL EDUCATION TRANSPORTATION approximately 170 students on (and it is referred to as cost spreadsheet 251 and attached to this tation requests are routed through one clerical person, and this is the person who has direct and report as part of Appendix A). The data from the second spreadsheet is included in the above constant contact with the Transportation Department. This single point of contact is ideal for TRAN data table. both departments. The district has not appropriately identified and separated resource 7230 and 7240 costs. This Approximately 20.3% of students with IEPs are provided with transportation, a rather high process has begun for the 2013-14 fiscal year, and it is expected that costs for each type of trans- percentage of students compared to other districts that FCMAT has studied. In many districts, portation will be more accurately identified for the 2013-14 fiscal year. Through the end of the the average is approximately 10% of students with IEPs. This indicates that psychologists and 2012-13 fiscal year, most district transportation costs were reported in resource 7230, with only IEP team members could provide more transportation service than necessary. the drivers’ salaries and benefits included in 7240 along with the student and cost data from The district provided its PowerPoint presentation titled “Special Education Department county office spreadsheet 251. Articulation IV 2013.” Included in that document are guidelines for IEP teams on providing Overall, the amount of 7240 contribution from the unrestricted general fund has steadily grown transportation as a related service. A best practice should be to utilize a more detailed decision as shown below: tree to help guide the IEP team in determining the least restrictive environment for students and the type of transportation service that best suits them. A sample decision tree is shown below: Year Amount 2010-11 $711,079 Is specialized transportation warranted? 2011-12 1,963,227 2012-13 $2,156,800 2013-14 $2,759,076* IEP and need-driven Program placement-driven *Budgeted amount Is it cost Should Ed Is it cost Does it meet efficient? Code 41850 efficient? the needs? This amount includes the costs of the district’s program and the county office program. (specialized transportation) Recommendation Yes be utilized? No Does it follow No Ed Code? The district should: Does it meet Yes 1. Continue to identify and separate resource 7230 and 7240 costs. the needs? No IEP and Transportation Requests Yes Before the beginning of each school year, the Special Education Department develops a spread- sheet with the most current information regarding students who require transportation service. Recommendation This spreadsheet includes the student name, home address and the program that the student will attend. It also includes all students who require transportation, except those who are “county” The district should: students and forwarded to the East Valley SELPA. The Transportation Department determines the students who will be transported by the department and those that will be forwarded to the 1. Adopt a decision tree to provide transportation as a related service and train county office. psychologists and IEP team leads to use it. The spreadsheet includes all the students who have an IEP and require transportation as a related service. The district transports the students who are less severe, and the county office Routing and Scheduling transports those who are more severe. The district provides SD/OI transportation to 306 students in the morning and 326 students During the school year, additions and deletions are communicated on a bus service request in the afternoon on 16 bus routes, an average bus loading of 19.75 students per route. This is form. These forms have more information that includes emergency contacts, the student’s high when compared to other districts that FCMAT has studied. This is primarily because of bell disability and the type of assistive equipment that is necessary. The Transportation Department time separation at schools that allows one bus to serve several schools in the morning and in the would benefit from including this information on the spreadsheet at the beginning of the school afternoon, picking up additional students for each grouping. Each bus route consists of several year. separate runs. In the morning each route has two or three runs, and the same occurs in the afternoon. The 2012-13 TRAN data indicates a cost per SD/OI pupil of $5,605. That number is When the district conducts an IEP, the psychologist is typically the lead district person in the incorrect because the district does not separate home-to-school and SD/OI costs appropriately. meeting. The psychologist usually enters the IEP information into the data system. All transpor- This data also includes costs for some students transported by the county office. fiscal crisis & ManageMent assistance teaM rialto unified school district 62 63 SPECIAL EDUCATION TRANSPORTATION SPECIAL EDUCATION TRANSPORTATION school year, the Transportation Department identified some “district” students (from the 251 The Transportation Department utilizes Edulog, a powerful computerized bus routing system, to spreadsheet) that would be transported on this contract, which stipulates a 3-hour base rate of its full capability. $180 per vehicle, or $230 for a vehicle with a lift gate. The rate is $30 for each additional half- District staff indicated they receive service complaints, particularly at the beginning of each hour and $60 for each additional hour. Aides cost an additional $21 per day, with an additional school year, usually about bus routes that run later than published times. These complaints are charge of $5 for every car seat and $5 for every safety vest. Twenty-five students are transported generally resolved within the first two to three weeks of school. This is normal for most school in the morning, and 27 in the afternoon. Regardless of the above contract rates, the current district special education transportation operations, and indicates a responsive transportation amount charged is $65 per each vehicle for the morning and $65 each for the afternoon or $130 staff. per vehicle, per day. The approximate vehicle loading is three students. The cost per student is Transportation requests that are received throughout the school year are generally scheduled and estimated to be $7,200 per student for the year, less than the cost charged by the county office on students are usually served within two or three days. This also indicates a very efficient staff and either spreadsheet, but more than the cost of the district providing the service on its own buses system. (based on the TRAN cost). The district does not have a global positioning system (GPS) installed on its buses. These systems American Logistics does not own or operate the vehicles utilized to transport district students, can locate buses, determine travel speed and document the time spent at each bus stop location but acts as a middleman. It receives the requests for transportation and contracts with a local or school. They also enhance responsiveness to parents and school officials as well as verify the transportation provider, which may be a cab company, to provide the service on its own equip- timeliness of route schedules. ment (sedans or minivans). The contract stipulates driver and vehicle minimum requirements to safeguard the district. School buses are statistically safer than any other vehicle on the road. If the Drivers receive 30 minutes to inspect buses and 15 minutes to sweep and clean them for each district can provide this service in a less costly manner on a safer vehicle, it should do so. route. They are also given 15 minutes for a morning break. Drivers may receive additional time (not on their regular contract) for bus washing (up to one hour per week) and fueling time, as The district receives monthly reports from the county office detailing the students that are trans- necessary. They may also have other drivers wash their buses if approved by the manager. Drivers ported for Rialto Unified, but the Transportation Department could not locate these lists. These do not accrue a right to a certain number of guaranteed hours annually. The routes are reset every documents should be reviewed to determine which students could be transported on existing year, and drivers bid for them based on their seniority position. routes. Assuming that the district decides to take responsibility for more of these students, the department would need to know them and their placements to plan for the necessary resources. The Transportation Department receives a spreadsheet at the beginning of each school year listing all the students who require special transportation. The department determines those who will At Rialto Unified, 20 regular education home-to-school routes transport approximately 3,000 be transported on district bus routes, and those who will be transported through the county students. The district also performs approximately 1,300 field trip moves (some require multiple office on First Student routes (the contract provider for the county office). The district serves buses) per year. less-involved students with its routes, and more severe students are transported on county office buses. Recommendations County office routes are developed by its employees, who utilize another powerful bus routing The district should: program, VersaTrans. 1. Consider purchasing and utilizing GPS technology on buses. The 271 spreadsheet is based on students who attend county office programs or programs that are not housed in the district. For these students, the district Special Education Department sends 2. Study and consider taking responsibility for transporting more district the transportation request to the East Valley SELPA, which makes the request to the county students from the 251 spreadsheet. office. The spreadsheet is a cost projection for the 2013-14 fiscal year. The estimated student count for the district is 125.25 and is based on the average of the mid-year student count from Staffing the prior school year. In this spreadsheet, the cost assigned to the district is $976,900.23. This is reduced by a share of the county office state school transportation revenue. The remainder of the The transportation department is staffed as follows: county office revenue is distributed to the West Valley SELPA. This spreadsheet indicates that the 1 FTE transportation manager expected cost is $7,799.60 per student for the year. 1 FTE dispatcher The 251 spreadsheet is composed of 170.75 students who attend district programs or noncounty 1 FTE bus driver trainer programs at an estimated service cost of $1,581,742.36. There is no state revenue for these students to reduce that cost. This spreadsheet indicates that the expected cost is $9,263.49 per 1 FTE transportation support technician student for the year. 1 FTE placement/transportation technician The district has begun an effort to take responsibility for more students represented on the 251 1 FTE transportation/garage support assistant spreadsheet. It has contracted with American Logistics, a nationwide transportation company, to transport approximately 25 on smaller, nonschool bus vehicles. At the beginning of the 2013-14 4 FTE mechanic III-heavy duty fiscal crisis & ManageMent assistance teaM rialto unified school district 64 65 SPECIAL EDUCATION TRANSPORTATION SPECIAL EDUCATION TRANSPORTATION 1 FTE mechanic II-automotive/small engine The district was recently awarded bus replacement grants from the South Coast Air Quality Management District for 16 older buses, 10 serving special education and the rest regular-educa- 38 bus drivers tion units. This a partial granting of the total number of buses pre-authorized for replacement by 7 substitute bus drivers the South Coast Air Quality Management District. Generous overlap in job descriptions allows for a great deal of cooperation among the office staff. The average fleet age of the school buses is 11.47 years, which makes for a relatively young fleet If the department adds special education bus routes in the future, more staff may be necessary that will further decrease in average age when the other grant buses are awarded and delivered. depending on the number of routes. At present; however, it has adequate office and shop staffing The Transportation Department maintains 223 other district vehicles for the maintenance and to accommodate up to approximately 10 additional routes. operations, grounds, food service, security and warehouse departments. These include pickup The mechanic III and mechanic II job descriptions include a requirement for possession and trucks, utility vans, forklifts, mowers, trailers and tractors. Small engine tools like trimmers maintenance of a Class B driver license. This license is necessary for a mechanic to test-drive and edgers are maintained by the Grounds Department. Each vehicle has a sticker placed near buses, drive them to outside shops, if necessary, and respond to accidents or breakdowns on the the odometer indicating when the next service mileage is due, and the operator is expected to road. However, the district indicated that only one mechanic possesses this license. It is impera- generate a work order when the vehicle approaches that mileage. The Transportation Department tive for all mechanics to have a Class B license. reported that many operators do not complete this task, and the department receives vehicles only when they experience a mechanical problem. When work is accomplished, labor time, parts The office staff does not meet regularly to discuss departmental issues and concerns or plan. and fluids are appropriately charged to the proper department. These types of meetings should occur regularly. Communication between the shop and office are important to obtain constantly updated information regarding the status of buses. Procedures on Because the district does not have electronic vehicle maintenance software, all work orders are communicating this information should be adopted. on paper, and the vehicle maintenance history is stored in file cabinets. The department does not generate management information reports for school buses or other district vehicles. As a result, Recommendations the district cannot make informed decisions about proper preventive maintenance or easily deter- mine the cost of maintaining certain vehicles. A large amount of parts are stored at the mainte- The district should: nance facility in several different storage rooms with no inventory of this stock or knowledge of its value. Judging from the dust and grime on many of the boxes, much of the stock has probably 1. Ensure all mechanics possess a valid Class B driver license. been on the shelves for years. Mechanics purchase parts; however, without an organized inventory 2. Hold regular department staff meetings, and adopt procedures on communi- system, they may buy parts that are already in stock because no one organizes and keeps track of cations between the shop and office. the district inventory. The district’s shelves could also store parts for vehicles it no longer operates. The district should consider purchasing a vehicle maintenance software system. Vehicle Maintenance and Fleet Title 13 of the California Code of Regulations, Section 1232 requires school buses to be inspected every 45 days or 3,000 miles, whichever comes first. The district has a practice of The California Highway Patrol Motor Carrier Inspector Division must annually inspect every inspecting the buses every 30 days, primarily because it has no way to easily verify daily mileage. school bus. The division also annually performs other inspections and issues a report entitled, This is one way to remain in compliance with the regulation for buses that may travel more than “Safety Compliance Report/Terminal Record Update”, more commonly referred to as the 3,000 miles in 45 days. However, the district can also collect mileage from at least one other “terminal grade.” As a part of this inspection, it randomly inspects buses, vehicle maintenance source; drivers report their mileage daily, and the bus driver trainer logs those mileages every day. records, driver time records, driver DMV pull notice records, and federal drug and alcohol The mileage for many vehicles is also entered into the electronic fueling system (but this is not a testing records. FCMAT reviewed the June 11, 2012 and July 9, 2013 terminal grade and found requirement for all vehicles). the district consistently receives the CHP’s highest grade of “satisfactory.” This reflects a vehicle maintenance program that complies with laws and regulations. Each school bus preventive maintenance inspection takes approximately two hours to perform, excluding any needed repairs. The difference between performing inspections every 30 days and The district lists 59 school buses on its fleet list, approximately 23 designated for special educa- every 45 days results in the need for four additional inspections every year for every bus. This tion transportation use. This provides for an adequate number of spare buses. Thirty-six buses amounts to approximately 472 additional work hours or approximately 59 work days per year. are designated for regular education home-to-school transportation and field trips. Because the This practice is in excess of the regulation and may be expensive. It could be rectified by having district has reduced the number of regular education bus routes over the years, it has more buses more timely mileage information. than necessary for the 20 routes now in operation. If the district intends to continue operating approximately this number of routes, it should have approximately 30 buses that can be used The district also owns and operates four passenger vans that teachers or coaches can check out to for routes, spares and field trips. The department has considered this and was preauthorized to use for small groups of students; however, they are not maintained any differently than the other receive replacement grants for a large number of buses in the fleet, pending funding from the white fleet vehicles. They should be maintained the same as school buses. South Coast Air Quality Management District. The grants do not provide a total dollar amount, but are authorized to replace one bus with another. On this program, the district can trade in a regular-education bus for one for special education. fiscal crisis & ManageMent assistance teaM rialto unified school district 66 67 SPECIAL EDUCATION TRANSPORTATION SPECIAL EDUCATION TRANSPORTATION The fuel system includes dispensing for gasoline and diesel fuel and is managed by an older elec- of in-service training. In the last year of their special license validity, they must receive 10 hours tronic fuel management system. This software system is antiquated and should be replaced with one of specific classroom training. In short, school bus drivers are the most highly trained and regu- that can be integrated into a vehicle maintenance management software system. The fuel system lated drivers in California. The training must be provided by a state certified school bus driver also serves the city of Rialto, and city employees have access at any time. There is discussion of instructor. Behind-the-wheel training may be given by a delegated behind the wheel instructor. upgrading the system and constructing a new transportation facility on another property nearby. The California Department of Education has developed curriculum for instructors and provides a training and certification program. The district also operates a small, slow-fill compressed natural gas (CNG) fueling system with eight bus fueling locations. Twenty-eight buses in the fleet are powered by CNG. Although the The district has one bus driver instructor on staff. The transportation manager is also a state certi- district has worked to rotate buses that are fueled on-site, this is a difficult logistical issue. Some fied school bus driver instructor, but the staff includes no delegated behind-the-wheel instructors. buses are fueled off-site, which can be costly. If the district determines that it will remain at its The district has not provided training for new school bus drivers in at least 12 years. The local current facility, it should expand the capacity of the CNG fueling system. area reportedly has a number of school bus drivers, and the district’s salary level is attractive. Since most school districts have great difficulty recruiting school bus drivers, this is a real benefit Recommendations for this district. The district should: The bus driver instructor provides approximately two renewal classes per year for drivers who need to renew their license. He also provides one in service meeting per month as well as a large 1. Determine how many large buses are necessary in the fleet, and apply for in-service meeting at the beginning of the school year. The bus driver instructor occasionally rides some special education buses when the next bus grant opportunity arises. along with drivers to evaluate their driving skills. 2. Purchase and implement a vehicle maintenance software system. The district has few accidents, which is an indicator of an effective bus driver training program. Drivers are provided with refresher training after every accident. 3. Develop an inventory of vehicle parts and organize all district vehicle mainte- nance parts in one secure area. Education Code Section 39831.3 requires every school district to develop a transportation safety plan housed at each school site and ready for inspection by any CHP officer. The district 4. Develop a method of accurately reporting mileage to reduce the frequency of complies with this law. bus inspections. The district has rarely provided specific, in-depth training for school bus drivers on the disabili- 5. Maintain passenger vans that transport students as if they were school buses. ties of special education students and strategies to manage them on school buses. The Special Education and Transportation departments should collaborate on regular training programs for 6. Upgrade the fuel management system and integrate it into the vehicle main- school bus drivers. tenance system. 7. Consider expanding the CNG fueling capacity. Recommendation The district should: Facility 1. Provide relevant training for special education bus drivers. The transportation facility is a large site shared by the Maintenance, Operations, Grounds, Food Service and Warehouse departments. The Transportation Department offices and driver’s lounge are well maintained. The shop building is older and in need of attention. The district is in the process of procuring a nearby property for a new fueling system and transpor- tation facility. The current facility is adequate for district needs; however, significant Transportation Department growth may place additional stress on it. If the district develops a new transportation facility, it should consider the potential growth of the department and district needs. Driver Training and Safety School bus driver training in California is highly regulated. Education Code Sections 40080- 40089 govern the training requirements for bus driver instructors and school bus drivers. Bus drivers must receive a minimum of 20 hours of classroom training and 20 hours of behind the wheel training to receive their license. They take a specialized written and behind-the-wheel test administered by the California Highway Patrol and annually receive a minimum of 10 hours fiscal crisis & ManageMent assistance teaM rialto unified school district 68 69 SPECIAL EDUCATION TRANSPORTATION APPENDICES Appendices A: Transportation Spreadsheets B: Study Agreement fiscal crisis & ManageMent assistance teaM rialto unified school district 70 71 APPENDICES APPENDICES Appendix A - Transportation Spreadsheets fiscal crisis & ManageMent assistance teaM rialto unified school district 72 73 APPENDICES APPENDICES Appendix B - Study Agreement fiscal crisis & ManageMent assistance teaM rialto unified school district 74 75 APPENDICES APPENDICES fiscal crisis & ManageMent assistance teaM rialto unified school district 76 77 APPENDICES APPENDICES fiscal crisis & ManageMent assistance teaM rialto unified school district 78 APPENDICES Fiscal crisis & ManageMent assistance teaM