San Francisco Unified School District Report

Special Education Review January 30, 2025 San Francisco Unified School District Michael H. Fine Chief Executive Officer January 30, 2025 Dr. Maria Su, Superintendent San Francisco Unified School District 555 Franklin Street, San Francisco, CA 94102 Dear Superintendent Su: In June 2024, the San Francisco Unified School District and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for FCMAT to conduct a review of the district’s and county office of education’s special education program. The agreement stated that FCMAT would perform the following: 1. Analyze special education teacher staffing ratios, class sizes and caseloads using statutory requirements for mandated services and statewide guidelines, and make recommendations for improvement, if any. 2. Review the efficiency of staffing allocations of special education paraeducators, per Education Code requirements and/or industry standards, and make recommendations for improvement, if any. Review the procedures for identifying the need for paraeducators, including considerations related to the least restrictive environment and the processes for monitoring the assignment of paraeducators and determining the need for continued support from year to year (including classroom and 1-to-1 paraeducators). 3. Analyze staffing and caseloads for related service providers, including but not limited to speech pathologists, psychologists, occupational/physical therapists, adaptive physical education teachers and other staff who may be related service providers, and make recommendations for improvement, if any. 4. Analyze whether the district provides a continuum of special education and related services for students in preschool through age 22, including their placement in the least restrictive environments, and make recommendations for improvement (which may include instructional models), if any. 5. Review the district’s unrestricted general fund contribution to special education and make recommendations for greater efficiency, if any. This final report contains the study team’s findings and recommendations. FCMAT appreciates the opportunity to serve the San Francisco Unified School District and extends its thanks to all the staff for their assistance during fieldwork. Sincerely, Michael H. Fine Chief Executive Officer Michael H. Fine • Chief Executive Officer 1300 17th Street – City Centre, Bakersfield, CA 93301-4533 • Tel. 661-636-4611 • Fax 661-636-4647 www.fcmat.org Table of Contents Table of Contents About FCMAT ..................................................................................................iii Introduction .......................................................................................................v Background ............................................................................................................................v Study and Report Guidelines .............................................................................................v Study Team .............................................................................................................................v Executive Summary ........................................................................................ 1 Findings and Recommendations................................................................ 5 Background and Context ......................................................................................5 Transforming Education to Improve Outcomes for Students with Disabilities .....5 District/County Alignment with the 2015 Report on One System ............... 7 Identification for Special Education .....................................................................8 District/County Enrollment .................................................................................................8 District/County Special Education Enrollment ..............................................................9 District/County Special Education Enrollment by Disability Category ...................9 Continuum of Service Options ............................................................................16 District/County Continuum of Service Options ...........................................................17 Special Education Teacher Staffing ...................................................................23 Resource Specialist Program Teacher Staffing ..........................................................23 Special Day Class Staffing ...............................................................................................27 Special Education Paraeducator Staffing .........................................................31 Industry-Standard Paraeducator Staffing Ratios .........................................................31 District/County Paraeducator Staffing Guidelines for SDCs ....................................31 Fiscal Crisis and Management Assistance Team San Francisco Unified School District i Table of Contents District/County Paraeducator Staffing .........................................................................32 1-to-1 Student Support .......................................................................................................35 Related Service Provider Staffing and Caseloads .........................................38 Adapted Physical Education ............................................................................................38 Credentialed School Nurses ...........................................................................................39 Occupational Therapy .......................................................................................................39 Physical Therapy .................................................................................................................41 School Psychologists for School-Age Programs .......................................................43 Speech and Language Pathologists .............................................................................45 Unrestricted General Fund Contribution to Special Education ..................48 Fiscal Background ..............................................................................................................48 Building Comparable Data...............................................................................................49 District/County Special Education Expenses .............................................................51 District/County Unrestricted General Fund Contribution ........................................52 Appendices ....................................................................................................54 Appendix A — District/County Resource Specialist Staffing by School, 2024-25 ...............................................................................................54 Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards .........................59 Appendix C – Study Agreement ........................................................................72 Fiscal Crisis and Management Assistance Team San Francisco Unified School District ii About FCMAT About FCMAT Purpose and Services FCMAT was created in 1991 by the California Legislature to help California’s TK-14 local educational agen- cies (LEAs) avoid fiscal insolvency. Today, FCMAT helps LEAs identify, prevent and resolve financial, man- agement, program, data, and oversight challenges; provides professional learning; produces and provides software, checklists, manuals and other tools; and offers other related school business and data services. FCMAT may be asked to provide fiscal crisis or management assistance by a school district, charter school, community college, county office of education, the state superintendent of public instruction, or the Legislature. When FCMAT is asked for help with management assistance or a fiscal crisis, FCMAT management and staff work closely with the requesting LEA to meet their needs. Often this means conducting a formal study using a FCMAT study team that coordinates with the LEA for on-site fieldwork to evaluate specified operational areas and subsequently produces a written report with findings and recommendations for improvement. For more immediate needs in a specific area, FCMAT offers short-term technical assistance from a FCMAT staff member with the required expertise. To help meet the need for qualified chief business officials (CBOs) in LEAs, FCMAT offers four different CBO training and mentoring programs that consist of 11 or 12 diverse two-day training sessions over the course of a full year. For agencies with professional learning needs, FCMAT offers workshops on specific topics. Popular topics include associated student body operations, use of FCMAT’s Projection-Pro online financial forecasting software, use of FCMAT’s Local Control Funding Formula (LCFF) Calculator, and data reporting for the California Longitudinal Pupil Achievement Data System (CALPADS). FCMAT staff and management also frequently make presentations at various professional conferences. The California School Information Services (CSIS) service of FCMAT helps the California Department of Education (CDE) operate CALPADS; helps LEAs learn about CALPADS, resolve data issues and meet reporting requirements; provides LEAs with training and leadership in data management; developed and continues to host and improve the Standardized Account Code Structure (SACS) web-based financial reporting system for all California LEAs; and provides ed-data.org, which gives educators, policymakers, the Legislature, parents and the public quick access to timely and comprehensive data about K-12 educa- tion in California. Since it was formed, FCMAT has provided LEAs with the types of help described above on more than 2,000 occasions. FCMAT’s administrative agent is the Kern County Superintendent of Schools. FCMAT is led by Michael H. Fine, Chief Executive Officer, and is funded by appropriations in the state budget and modest fees to requesting agencies. Workshop schedules, manuals, presentation slide decks, Projection-Pro software, LCFF calculators, past reports, an online help desk, and many other resources are available for download or use at no charge on FCMAT’s website. Fiscal Crisis and Management Assistance Team San Francisco Unified School District iii About FCMAT History FCMAT was created by Assembly Bill (AB) 1200 in 1991. In 1997, AB 107 charged FCMAT with responsibility for CSIS and its statewide data management work, and AB 1115 in 1999 codified CSIS’ mission. AB 1200 created a statewide plan for county offices of education and school districts to work together locally to improve fiscal procedures and accountability standards. AB 2756 (2004) gave FCMAT specific responsibilities for districts that have received emergency state loans. In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to include these types of LEAs. On September 17, 2018, AB 1840 was signed into law. This legislation changed how fiscally insolvent dis- tricts are administered once an emergency appropriation has been made, shifting oversight responsibili- ties from the state to the local county office of education to be more consistent with the principles of local control, and giving FCMAT new responsibilities associated with the process. Fiscal Crisis and Management Assistance Team San Francisco Unified School District iv Introduction Introduction Background The San Francisco Unified School District is the city and county of San Francisco’s only public school district. According to DataQuest, 55,452 students in grades transitional kindergarten through 12 (TK-12) were enrolled in 2023-24. As a single-district county, the district and the San Francisco County Office of Education are administered and governed by the same seven-member board of trustees. According to DataQuest, 468 students were enrolled in the San Francisco County Office of Education in 2023-24. Throughout this report the San Francisco Unified School District and San Francisco County Office of Education are referred to as “the district/county” because most staff do not differentiate between these two local educational agencies (LEAs). However, recommendations to distinguish the district’s and the county office’s special education programming from one another are discussed in the “District/County Continuum of Service Options” section of this report. In 2023-24, 13.59% of the district/county’s students were identi- fied as requiring special education, which is an increase of 2.07 percentage points since 2019-20. In June 2024, the district/county and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for FCMAT to conduct a review of the district/county’s special education program. Study and Report Guidelines FCMAT visited the district/county on October 22-24, 2024, to conduct interviews with central office and school administrators, special education teachers, related service providers, and special education paraed- ucators. Following fieldwork, FCMAT reviewed and analyzed data and documents. This report is the result of those activities. FCMAT’s reports focus on systems and processes that may need improvement. Those that may be func- tioning well are generally not commented on in FCMAT’s reports. In writing its reports, FCMAT uses the Associated Press Stylebook and its own short internal style guide, which emphasize plain language, capital- ize relatively few terms, and strive for conciseness, clarity and simplicity Study Team The study team was composed of the following members: Carolynne Beno, Ed.D., CFE Colleen Patterson, MBA, CMA FCMAT Chief Analyst FCMAT Consultant John Lotze FCMAT Technical Writer All team members reviewed the draft report to confirm accuracy and achieve consensus on the final recommendations. Fiscal Crisis and Management Assistance Team San Francisco Unified School District v Executive Summary Executive Summary Identification for Special Education According to DataQuest, the district/county’s census day enrollment has declined over the past five years, but its special education enrollment has increased. In 2023-24, 13.59% of the district/county’s students in grades transitional kindergarten through 12 (TK-12) were identified as requiring special education, which was slightly less than the statewide average. This is a 2.07 percentage point increase since 2019-20. Identifying students for special education when they do not require specialized instruction is not a best practice and increases special education costs. When they are not enrolled in special education, students experience less stigma, increased access to rigorous instruction in general education, and more interac- tions with their typically developing peers. Increases in the percentage of students identified for special education in the district/county appear to be caused by its student success team (SST) process, multitiered systems of support (MTSS), and eligibility determination process for special education, as described below. Student Success Team (SST) Process All local educational agencies (LEAs) should have an SST process that identifies interventions to support students with learning differences and/or behavioral or social-emotional needs before a special educa- tion assessment is considered. The district/county has not set an expectation that all schools use its SST process, and it does not monitor, support, or require its consistent use. Staff reported that some schools have an SST process that provides intervention and support for students through the general education program, but that many schools do not have such a process. Factors that contribute to this include a lack of schoolwide intervention and support, and a belief that the SST process is a pathway to a special education assessment instead of an opportunity for a student to receive general education interventions that meet their differing needs. Multitiered System of Support (MTSS) MTSS is a framework that aligns academic, behavioral, and social-emotional learning with one another. Staff reported that district/county schools provide interventions to address certain student learning differences, and/or behavioral and social-emotional needs. However, staff reported that the quality and completeness of interventions and supports vary from school to school, and there are no standard districtwide/countywide supports and interventions that address these types of needs. This means that a student at one school may have access to intervention in the general education program but a student at a different school may not. Eligibility Determination Process for Special Education Special education should be reserved for students who are eligible to receive these specialized services. To be eligible for special education, a student must qualify by meeting a two-part test with the following criteria: • They must meet the definition of one of the 14 disability categories in the Individuals with Disabilities Education Act (IDEA). • The must need specially designed instruction. Staff reported that the district/county does not consistently apply the two-part test to determine if a stu- dent qualifies for special education during their initial individualized education program (IEP) meeting. Staff Fiscal Crisis and Management Assistance Team San Francisco Unified School District 1 Executive Summary reported that this occurs because some schools lack general education interventions and supports, so staff believe that qualifying a student for special education is the only way to ensure that a student will receive the support they need. In addition, staff indicated that some students are not being exited from the special education program using the two-part test at their triennial IEP meeting because of factors such as parent pressure for the student to remain in special education. Continuum of Special Education Services A special education local plan area (SELPA) must ensure that a continuum of special education ser- vice options is available to meet the needs of students with disabilities. Most LEAs offer different levels of specialized classes to meet the varying needs of these students, including LEA-based specialized classes, regional specialized classes that serve students throughout a SELPA, and nonpublic schools. Staff explained the district/county specialized classes for students with autism, extensive support needs, and behavioral/social-emotional needs are all considered district classes, and that they have not been differen- tiated to meet students’ varying needs (e.g., by offering different adult-to-student ratios or levels of related service provider support). Because it lacks the various levels of classes specially designed to meet differ- ing student needs that most other SELPAs have, the district/county may be missing an opportunity for a district/county class to meet the needs of students who may otherwise need to be referred to a nonpublic school (NPS). The district/county needs to analyze the needs of students in its special day class (SDC) programs for students with autism, extensive support needs, and behavioral/social-emotional needs to determine how it may be able to expand the continuum of services it offers by distinguishing district from county classes. Specialized county classes should have clearly defined differences in students’ needs, class sizes, and levels of support from related service providers such as behaviorists. Once it has such classes, the district/ county will need to determine whether the needs of students who currently attend an NPS can be met in a county class instead, and transition those students back to county classes. Special Education Staffing The district/county does not use statewide guidelines and/or industry standards to determine staffing for its special education program. The district/county has a document titled Special Education School Site Staffing Guide School Year 2024-2025 (district/county staffing guide) that specifies staffing ratios for its special edu- cation program. Some ratios in this guide are aligned with industry standards; however, the district/county’s special education staffing is not aligned with many of the ratios in the guide. Resource Specialist Program In 2024-25, districtwide/countywide resource specialist program (RSP) staffing was 248.80 full-time equiv- alent positions (FTE), which is 69.73 FTE more than what is required to meet the Education Code (EC) 56362(c) standard. However, the students who receive support from a resource specialist are not evenly distributed into groups of 28 students across district/county schools. In addition the statewide caseload average observed in LEAs similar to the district/county that serve students using an inclusive model is lower than the caseload maximum specified in EC 56362(c). Thus, having more staffing than is required to meet the EC 56362(c) caseload maximum may be necessary. The district/county’s staffing guide specifies a 1-to-22 teacher-to-student ratio for the RSP, which is rea- sonable because the industry standard for specialized academic instruction (SAI)-based programs that serve students in their least restrictive environment (LRE) is 20-24 students per special education teacher. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 2 Executive Summary However, in 2024-25, the district/county’s RSP staffing is 20.89 FTE more than what is needed to achieve a 1-to-22 teacher-to-student ratio. In addition, the district/county rarely shares a resource teacher between two schools when there are low caseloads at both schools. As a result, some schools have more staffing than needed to meet an RSP teacher to student ratio of 1-to-22 while others do not have enough staffing to meet this ratio, and eight schools have a lower RSP teacher-to-student ratio than the 1-to-28 required by EC 56362(c). Special Day Class Programs In 2024-25, the districtwide/countywide mild-to-moderate SDC teacher caseload average is lower than the industry-standard range of 12-15 students per teacher at every school level. As a result, the district/ county is staffed at 4.43 FTE SDC teachers more than what it would need to meet a caseload average of 12 students per teacher and 17.52 FTE SDC teachers more than what it would need to meet a caseload aver- age of 15 students per teacher. This is because the district/county determines its staffing using a caseload range of 10-12 students per mild-to-moderate SDC teacher. FCMAT was unable to determine whether the district/county’s teacher staffing for SDCs for students with extensive support needs was aligned with the industry standards. Although the district/county offers differ- ent pathways for students with different needs, such as Autism, the district/county’s data did not differenti- ate between cross-categorical and autism-focused SDCs, which have different caseload ranges. Special Education Paraeducators The district/county staffing guide defines paraeducator staffing for SDC programs. However, the district/ county’s class size ranges do not match the industry standards, and because the district/county does not use an adult-to-student staffing ratio to determine paraeducator staffing, it may be over- or understaffed. Assigning more paraeducator support than necessary is costly and may limit the opportunities of students with disabilities to gain independence; however, not assigning enough paraeducators to an SDC can mean that students lack sufficient support and supervision. The district/county would benefit from adding an adult-to-student ratio to its paraeducator staffing guidelines for SDCs. Although no industry standard exists for 1-to-1 paraeducators, in 2024-25, the district/county has 416.44 FTE 1-to-1 paraeducators providing intensive individual service (IIS). This is high for a district/county of this size compared to what is observed across the state. Although the district consistently administers its IIS assessment before assigning IIS, staff reported that some IEP teams recommend IIS for a student even though the IIS assessment does not demonstrate that need. Assigning more paraeducator support than necessary is costly. In addition, although a parent/guardian or staff member’s request for a student to have a 1-to-1 paraeducator may be well meaning, the University of Denver Colorado’s Paraprofessional Resource & Research Center has identified possible negative conse- quences of doing so, which are outlined in the “1-to-1 Student Support” section of this report. Related Service Providers In 2024-25, the district/county’s staffing for adapted physical education teachers, credentialed school nurses, occupational therapists, physical therapists, school psychologists, and speech and language pathologists is considerably higher than what is needed to meet industry-standard provider-to-student ratios, as described in the “Related Service Provider Staffing and Caseloads” section of this report. In addition, the district/county reported it has not attempted to recruit and hire district/county occupational therapists or physical therapists in many years. Because of this, it is increasing its costs by contracting for Fiscal Crisis and Management Assistance Team San Francisco Unified School District 3 Executive Summary 37.9 FTE occupational therapists and 11.3 FTE physical therapists through a nonpublic agency (NPA). Hiring its own employees would both be more cost effective for the district/county and give it more control over the management of these providers. Unrestricted General Fund Contribution to Special Education In 2023-24, the district/county’s adjusted unrestricted general fund contribution to special education was $196,336,787, or 74.45% of total special education costs. In 2024-25, the district/county’s unrestricted general fund contribution as a per centage of total special education costs, inclusive of indirect costs, was budgeted significantly lower and is projected to decrease to 73.86% based on first interim actual projec- tions and the district/county budget. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 4 Findings and Recommendations Background and Context Findings and Recommendations Background and Context Transforming Education to Improve Outcomes for Students with Disabilities Over the past two decades, educational reform movements emphasizing accountability have highlighted achievement gaps among students based on factors such as race and ethnicity, family income, language ability, and disability. Although California has made some progress in reducing inequities in educational outcomes for these student groups, those with disabilities remain among the lowest-performing subgroups. In 2013, California convened a statewide special education task force dedicated to ending persistent poor outcomes for California’s students with disabilities, including infants, toddlers, preschoolers, and students up to age 22 in kindergarten through grade 12 schools. The task force’s purpose was to study the complex systems designed to serve students with disabilities and to forward recommendations to the State Board of Education, the Commission on Teacher Credentialing, and the California Department of Education (CDE). In March 2015, the task force published One system: Reforming Education to Serve All Students, Report of California's Statewide Task Force on Special Education, as well as an executive summary. The Statewide Special Education Task Force Project Summary states the following: California’s current policies, including funding, credentialing, and a range of service deliv- ery options, tend to ‘bolt on’ special education to general education. While there are cer- tainly examples throughout the state of well-integrated models of supports, these are the exceptions rather than the norm. Our prevailing model has made it acceptable, and in some instances seem desirable, to isolate special education as a unique and separate system that parallels general education. This project summary also explains that operating special education as a separate program is contrary to current research, stating the following about what such research suggests : Inclusive practices, integrated systems, and coherence are essential to provide high-quality, cost-effective special education programs within (rather than apart from) a well-articulated system of education. The 2015 report on one system identified the following seven distinct and interconnected areas of focus to improve outcomes for students with disabilities: 1. Early learning. 2. Evidence-based school and classroom practices. 3. Educator preparation and professional learning. 4. Assessment. 5. Accountability. 6. Family and student engagement. 7. Special education financing. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 5 Findings and Recommendations Background and Context Among the areas of focus and many recommendations in the 2015 report on one system was the predomi- nant theme that California’s special education system would improve if one coherent system were designed in which general education and special education work together to meet the needs of all students. The report states: In a coherent system of education, all children and students with disabilities are considered general education students first; and all educators, regardless of which students they are assigned to serve, have a collective responsibility to see that all children receive the educa- tion and the supports they need to maximize their development and potential, allowing them to participate meaningfully in the nation’s economy and democracy. The summary of the project on the CDE website identified a need to transform the understanding of special education from being: A place where students go to receive more or different services, to a viewpoint that includes special education services as one of many programs of support under the umbrella of general education. In 2020, the CDE commissioned WestEd, a nonprofit dedicated to fostering “success for every learner,”1 to analyze policy and systemic changes affecting students with disabilities since the 2015 report on one system. The 2021 WestEd report, California’s Progress Toward Achieving One system: Reforming Education to Serve All Students, explains that the 2015 report on one system was intended to create momentum and discourse in California’s efforts to reform special education. To evaluate these efforts, WestEd examined the 2015 report on one system’s seven focus areas then made additional recommendations in each area. WestEd concluded, “numerous improvements have been made to California’s general and special educa- tion landscapes.” Guided by the insights from the 2015 report on one system and the 2021 WestEd report, LEAs should focus on achieving coherence, fostering inclusive practices, and integrating student support systems to build a comprehensive educational system that promotes positive outcomes for all students. LEAs need to recognize that students who receive special education services are general education students first and operate with the understanding that special education services are one of the many programs of support under general education rather than a place where students go to receive more or different services. These tenets will be used throughout this report to analyze the district/county’s continuum of special education services and special education staffing. 1 WestEd: Success for Every Learner. (n.d.). https://www.wested.org/about-us/ Fiscal Crisis and Management Assistance Team San Francisco Unified School District 6 Findings and Recommendations District/County Alignment with the 2015 Report on One System District/County Alignment with the 2015 Report on One System Congruent with tenets in the 2015 report on one system, staff described the district/county’s special edu- cation program as a support for students with disabilities, not a place where students with disabilities go to receive a separate education. Staff articulated a strong belief that students with disabilities are general education students who are best supported by all general education, pupil services and special education personnel at each school. Staff identified access to general education settings and inclusive practices as critical facilitators of positive outcomes for students with disabilities. These core beliefs and values held by district/county educators provide a strong foundation for the inclusive, coherent system of education envi- sioned in the 2015 report on one system to support the success of students with disabilities. However, incongruent with the principles in the 2015 report on one system, many staff interviewed reported that the special education department has historically operated in isolation from other district/ county departments. Many district/county departments have new staff in leadership positions. These leaders consistently iden- tified the need for improved communication and collaboration between departments as important to their ability to do their jobs. However, there is a need for these leaders to recognize that the work they do in their department and in collaboration with other departments is shared work to accomplish the district’s stated mission, which is to “provide each and every student the quality instruction and equitable support required to thrive in the 21st century.” Recommendation The district/county should: 1. Establish a culture that focuses on collaboration to promote positive outcomes for all students, including students with disabilities. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 7 Identification for Special Education Before examining the district/county’s special education staffing, continuum of special education services and unrestricted general fund contribution to its special education program, it is critical to think about those whom the program serves: the district/county’s students who receive special education services. This sec- tion provides an overview of data and trends related to the district/county’s students who receive special education services. District/County Enrollment From 2019-20 through 2023-24, the district/county’s census day enrollment for all TK-12 students decreased by 5,438 students, as shown in Figure 1 below. Census Day Enrollment of District/County Students in Grades TK-12, 2019-20 through 2023-24 65,000 60,000 61,358 59,004 55,000 55,800 55,901 55,920 50,000 45,000 40,000 35,000 30,000 25,000 20,000 15,000 10,000 5,000 0 2019-20 2020-21 2021-22 2022-23 2023-24 Figure 1. A chart showing an overall decline the district/county office census day enrollment for grades TK through 12 from 61,358 in 2019-20 to 55,920 2023-24, with a decline from 2019-20 to a low of 55,800 in 2021-22, followed by a slight increase from 2021-22 to 2023-24. Source: Enrollment for Charter and Non-Charter Schools - San Francisco (CDE). stnedutS fo rebmuN Findings and Recommendations Identification for Special Education School Year Fiscal Crisis and Management Assistance Team San Francisco Unified School District 8 District/County Special Education Enrollment Although total district/county enrollment decreased from 2019-20 through 2023-24, special education enrollment in TK-12 increased by 534 students during that period, as shown in Figure 2 below. Number of District/County Students in Grades TK-12 Enrolled in Special Education, 2019-20 through 2023-24 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 2019-20 2020-21 2021-22 2022-23 2023-24 Figure 2. A chart showing an overall increase in the number of district/county TK-12 students enrolled in special education, from 7,068 in 2019-20 to 7,602 in 2023-24. Source: Enrollment for Charter and Non-Charter Schools - San Francisco (CDE). District/county students who identify as male are much more likely to be identified for special education than those who identify as female. The former group make up 52% of all students but 66% of students in special education, which is only slightly lower than the statewide average of 67% as calculated from DataQuest. The latter group make up 48% of all students but only 34% of students in special education. The higher representation of males in special education is influenced by factors such as referral bias (e.g., boys are more likely to be referred because of poor grades or behavior support needs) and differences in how teachers perceive student behavior (e.g., boys often draw more negative attention in school). Consequently, it is important for LEAs to analyze special education referral rates by gender and provide professional development as needed to address any disparities. District/County Special Education Enrollment by Disability Category The IDEA defines thirteen categories of disability under which a school-age student may be eligible for special education. In 2024-25, approximately 97% of the district/county’s TK-12 students enrolled in special education qualified under one of the six main disability categories shown in Table 1 below. stnedutS fo rebmuN Findings and Recommendations Identification for Special Education 7,578 7,602 7,376 7,068 6,952 School Year Fiscal Crisis and Management Assistance Team San Francisco Unified School District 9 Findings and Recommendations Identification for Special Education Table 1: Percentage of District/County TK-12 Total Special Education Enrollment by Main Disability Category, 2019-20 and 2024-25 Speech and Specific Emotional Intellectual Language Other Health Learning Disability Disability Impairment Impairments Autism Disability 2019-20 3.96% 5.48% 16.6% 15.31% 17.49% 35.89% 2024-25 3.53% 4.59% 15.43% 17.41% 23.08% 33.07% Change -0.43% -0.89% -1.17% +2.1 +5.58% -2.82% Source: California Longitudinal Pupil Achievement Data System (CALPADS) report 16.1 for 2019-20 and CALPADS report 16.12 for 2024-25. Notes: Although there are 13 disability categories under which a school-age student with a disability may qualify for special education, this table shows data only for the six most common in the district/county. The main eligibility category of “emotional disability” was previously “emotional disturbance,” which is the term defined in the IDEA and used throughout the Education Code and the California Code of Regulations. However, Assembly Bill 2173, signed by the governor in July of 2024, permits California to use the less offensive term “emotional disability” in state law. According to the WestEd California Special Education Funding System Study, specific learning disabilities constitute the vast majority of identified disabilities for students in grades kindergarten through 12, followed by speech and language impairments and autism, respectively. In 2024-25, the district/county reported to the California Longitudinal Pupil Achievement Data System (CALPADS) that 33.07% of its TK-12 special education students were eligible due to a specific learning disability. Autism and other health impairment were the next two most common disability categories in the district/county, making up 23.08% and 17.41% of special education enrollment, respectively; this is different from the statewide trends identified by WestEd. Significantly, from 2019-20 through 2024-25, the number of TK-12 students with autism enrolled in spe- cial education increased from 1,193 to 1,759, which is a 47.44% increase. This increase is discussed in the “Continuum of Service Options” section of this report. Disproportionality in Special Education Identification The National Association of School Psychologists defines disproportionality as “the extent to which mem- bership in a given group affects the probability of being placed in a specific disability category.” Simply, it is the under- or overrepresentation of racial or ethnic groups in special education. Racial and Ethnic Balance of Students For most racial and ethnic groups, their representation as a percentage of total students enrolled in the special education was proportionate to their representation as a percentage of all district/county students. However, in 2023-24, 40.33% of the district/county’s special education students identified as Hispanic or Latino, compared to 35.53% of the district/county’s total student population, and 13.21% of the district/coun- ty’s special education students identified as African American, compared to 7.53% of the district/county’s total student population. Conversely, 18.35% of the district/county’s special education students identified as Asian, compared to 28.16% of the district/county’s total student population. This indicates an overrepresentation of students who are Hispanic, Latino or African American in special education and an underrepresentation of students who are Asian, as shown in Table 2 below. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 10 Findings and Recommendations Identification for Special Education Table 2: Percentage of Students in Special Education, by Race and Ethnicity, Compared to Percentage of Total Student Population, 2023-24 Two or African Hispanic Not More Pacific American Asian American or Latino Reported White Races Filipino Islander Indian Percentage of Total 28.16% 7.53% 35.53% 3.74% 13.35% 7.38% 3.38% 0.71% 0.23% Enrollment Percentage of Special 18.35% 13.21% 40.33% 5.52% 11.72% 6.83% 2.89% 0.86% 0.29% Education Enrollment Difference -9.81% +5.68 +4.8% +1.78% -1.63% -0.55% -0.49% +0.15% +0.06% Source: Enrollment by Ethnicity for Charter and Non-Charter Schools in 2023-24 - San Francisco (CDE). Overrepresentation of Students who Identify as African American The district/county was recognized by the CDE in its Compliance and Improvement Monitoring (CIM) pro- cess as “significantly disproportionate” because it overidentified students who are African American for special education in the disability categories of emotional disability (previously emotional disturbance) and other health impairment. An LEA identified as significantly disproportionate is required to take action, including reserving 15% of its IDEA funds to develop and implement a Compliance and Improvement Monitoring for Comprehensive Coordinated Early Intervening Services Action Plan (CIM for CCEIS Action Plan). The purpose of this plan is to identify and address any factors that contribute to disproportionality. Overrepresentation of Students who Identify as Hispanic or Latino Although the reason for the district/county’s higher-than-expected identification of Hispanic and Latino for special education services is unclear, it is imperative that the district/county identify only qualifying stu- dents with disabilities. This is necessary for at least two reasons: first, even the most efficient special edu- cation programs do not receive enough funding to support their programs, so it is essential that these finite resources be used for qualifying students with disabilities; and second, although special education services are vital for students with disabilities, students identified for special education may experience stigma, reduced expectations, and less access to the general education curriculum and teachers. These factors can limit their academic achievement and outcomes. The district/county needs to evaluate whether it overidentifies Hispanic and Latino students for special education. The Association of California School Administrators (ACSA) has published a brief titled, The Disproportionality of Latinx Students in Special Education, which discusses common causes of dispropor- tionality of Hispanic and Latino students in special education and provides recommendations on how to address each of them. It would benefit the district/county to review this brief and use it to investigate its possible overidentification of Hispanic and Latino students in special education. Underrepresentation of Students who Identify as Asian The district/county needs to investigate its lower-than-expected identification of Asian students for special education. The reason this is occurring is unclear; however academic literature is informative. A review of 15 academic studies examining the special education identification of Asian students2, (found that most stud- 2 Kulkarni, S. S. (2017). Disproportionate representation of Asian students in special education: A systematic review of the literature. Multiple Voices for Ethnically Diverse Exceptional Learners, 17(2), 19-33. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 11 Findings and Recommendations Identification for Special Education ies reported an underrepresentation of Asian American students in special education because of factors such as the model minority myth, which stereotypes all Asian Americans as academically successful and hardworking while ignoring the diversity within this group; cultural differences and parental beliefs about the stigma of disability labels; and lack of proficiency in Asian languages in school districts. It is imperative that the district identify all qualifying students with disabilities. Public schools are required under the IDEA to identify, locate, and evaluate all children who are suspected of having a disability. Failing to identify a student with a disability for special education can deprive the student of their rights to a free appropriate public education (FAPE) under the IDEA. This can impede the student’s academic achievement and outcomes and may obligate the district to pay for compensatory educational services. English Learners in Special Education In 2023-24, English learners made up 24.25% of all district/county TK-12 students but 27.94% of students in special education. English learners are commonly overidentified for special education services, and this may be the case in the district/county as well. It would benefit the district/county to review its data annually to monitor for high- er-than-expected identification of English learners in special education and provide professional develop- ment as needed. District/County Special Education Enrollment Compared to Statewide Enrollment From 2019-20 through 2023-24, the percentage of district/county TK-12 students enrolled in special educa- tion increased by 2.07% , from 11.52% to 13.59%.3 FCMAT compared district/county total and special education TK-12 enrollment to statewide enrollment for 2023-24 (the latest data available). This data is shown in Table 3 below. Table 3: TK-12 Total and Special Education Enrollment Comparison, 2023-24 San Francisco Unified and San Francisco 2023-24 County Office of Education California Grades TK-12 Total Enrollment 55,920 5,837,690 Grades TK-12 Special Education Enrollment 7,602 799,980 Percentage 13.59% 13.70% Sources: Enrollment for Charter and Non-Charter Schools - San Francisco (CDE) and Enrollment for Charter and Non-Charter Schools - State (CDE). The district/county identified a slightly lower percentage of TK-12 students as requiring special education than the statewide percentage. Nonetheless, the district/county needs to identify and address factors that may be contributing to its increasing percentage of students in special education to ensure only qualifying students receive special education services. 3 Source: Enrollment for Charter and Non-Charter Schools - San Francisco (CDE). Fiscal Crisis and Management Assistance Team San Francisco Unified School District 12 Findings and Recommendations Identification for Special Education Increasing Percentage of District/County Students in Special Education Education Code (EC) 56303 states, “A pupil shall be referred for special educational instruction and ser- vices only after the resources of the regular education program have been considered and, where appro- priate, utilized.” Identifying a student for special education before implementing general education inter- ventions does not best serve the student. Students in special education can experience stigma, less access to the rigorous instruction given in the general education curriculum, limited interaction with their typically developing peers, and lower expectations, which can limit their progress and outcomes. In addition, serving a student in special education through an IEP is costlier than serving one through interventions and general education supports. As mentioned in the “District/County Special Education Enrollment Compared to Statewide Enrollment” section of this report, from 2019-20 through 2023-24, the percentage of district/county students in grades TK-12 enrolled in special education increased by 2.07%. This increase appears to be influenced by at least the factors discussed below. Student Success Team Process Before considering a special education assessment, students with learning differences and/or behavioral or social-emotional needs should be referred to a student success team (SST). This school-based team approach is designed to help students with a wide range of concerns related to their school performance and experience. SSTs are responsible for reviewing students’ strengths and weaknesses, identifying appro- priate interventions, setting specific, measurable, achievable, relevant, and time-based (SMART) goals, and monitoring students’ progress toward these goals. An SST is composed of the student (if appropriate), the parent or guardian, and various school personnel such as counselors, resource specialists, speech patholo- gists, school psychologists, classroom teachers, and administrators. All LEAs should have an SST process. The district/county has not set an expectation that all schools use its SST process, and it does not monitor, support, and require its consistent use. Staff reported that some schools have an SST process that effec- tively provides intervention and support for students in the general education program. However, staff also indicated that many schools do not have such a process because of factors such as a lack of schoolwide intervention and support opportunities, or the SST process being viewed and used as a pathway to a spe- cial education assessment instead of an opportunity for a student to receive appropriate general education interventions in response to their specific needs. Multitiered System of Support California’s multitiered system of support (MTSS) focuses on aligning various initiatives, supports, and resources with content standards to meet the needs of all students. This integrated, comprehensive frame- work aligns academic, behavioral, and social-emotional learning and implements continual improvement processes throughout the educational system. It serves as a method of organization and uses data col- lected through universal screening to support decision making and problem solving. MTSS includes both response to instruction and intervention (RtI²) and positive behavioral interventions and supports (PBIS). Staff reported that district/county schools provide interventions to address certain student learning dif- ferences and/or behavioral and social-emotional needs. However, staff also indicated that interventions and supports vary in comprehensiveness and quality from school to school, and that there are no stan- dard countywide/districtwide supports and interventions to address a student’s academic, behavioral and social-emotional differences and needs. This means that a student at one district/county school may have access to intervention in the general education program but a student at a different district/county school may not. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 13 Findings and Recommendations Identification for Special Education Determining Eligibility for Special Education Special education should be reserved for students who are eligible to receive these specialized services. To be eligible for special education, a student must qualify by meeting the two-part test, which requires that they (1) meet the definition of one of the 14 disability categories in the IDEA, and (2) require specially designed instruction. Staff reported that the district/county does not consistently use the two-part test to qualify students for special education at their initial IEP meeting. Staff reported that the IEP teams at some schools decide to qualify a student for special education even if they do not meet the test criteria because general education interventions and supports are lacking at their school. Staff said that they believe if they do not qualify the student for special education, the student will not receive support in the general education program to address their needs. Not all students who initially qualify for special education services require those services throughout their school years. Students may exit special education at their annual or three-year (triennial) IEP meeting if they have demonstrated an ability to succeed in general education or no longer meet the definition of one of the IDEA’s disability categories, and/or have acquired the skills they previously lacked, such as using intelligible speech or language skills. Staff indicated that some students are not being exited from special education according to the two-part test at their triennial IEP meeting if they no longer qualify for special education. Staff indicated that parent pressure for the student to remain in special education is the largest factor preventing a student’s depar- ture from special education. However, keeping students in special education who do not require it is not a best practice. As previously mentioned, students experience less stigma, increased access to rigorous instruction given in general education, and more interactions with their typically developing peers when they are not enrolled in special education. A student’s exit from special education is evidence of the stu- dent’s and the program’s success. The following two strategies could help the district/county evaluate its special education entry and exit data and eligibility determination procedures: 1. Analyze its special education entry and exit data by at least school, grade level, and disability category to determine if there are notable trends. The district/county should consider using the 2020 Policy Analysis for California Education (PACE) brief, Students with Disabilities in the CORE Districts as a guide. In this brief PACE used data from the CORE districts (Fresno, Garden Grove, Long Beach, Los Angeles, Oakland, Sacramento, San Francisco, and Santa Ana) and noted how students in these LEAs entered and exited special education and transitioned between special education disability categories. The district/county could compare its special education entry and exit data to trends identified in this PACE brief. In addition, because it is one of the CORE districts in the brief, the district/county would benefit from collaborating with the other CORE districts to identify post-COVID-19 pandemic special education entry and exit trends. The other CORE districts are also large school districts, and this group has an established history of collaborating and testing improvement theories at the school and district level. The district/county would benefit from discussing challenges and best practices related to special education entry and exit in this post-COVID-19 pandemic context. 2. Review psychoeducational and speech and language assessments to identify several where the IEP team used the two-part test correctly to determine eligibility for special Fiscal Crisis and Management Assistance Team San Francisco Unified School District 14 Findings and Recommendations Identification for Special Education education and several where the IEP team did not. Then, redact any student, staff or school identifying information from each assessment and have an attorney or expert witness (e.g., school psychologist or speech and language therapist) use the redacted documents when they provide training on special education entrance and exit criteria and best practices. This training should be provided for special education staff and staff who serve as the administrative designee at IEP meetings. Recommendations The district/county should: 1. Annually monitor the percentage of students who qualify for special education and assess the proportionality of students in the special education group compared to the overall student population at least by gender, race, ethnicity, and English learner status. Provide training as needed in how to properly identify students for special education. 2. Continue to implement its CIM for CCEIS Action Plan to reduce its overrepresentation of African American students in special education. 3. Evaluate whether it overidentifies Hispanic and Latino students for special education. Consider using the ACSA brief, The Disproportionality of Latinx Students in Special Education, as a guide. 4. Set an expectation that all schools use a common SST process, and monitor, support, and require its consistent use. 5. Establish a districtwide MTSS, with tiers of interventions and supports to address a student’s academic, behavioral, and social-emotional differences and needs. Provide training for all schools, and monitor, support and require its consistent use. 6. Analyze its special education entry and exit data at least by school, grade level, and disability category to identify trends. Consider comparing its special education entry and exit data to trends identified in the 2020 Policy Analysis for California Education (PACE) brief, Students with Disabilities in the CORE Districts. 7. Collaborate with the other CORE districts to discuss post-COVID-19 pandemic special education identification trends, challenges, and best practices. 8. Provide professional development for special education and other staff who serve as the administrative designee at IEP meetings on how to properly determine special education eligibility using the two-part test. 9. Annually monitor special education entry and exit rates by school, grade level and disability category, and provide professional development as needed. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 15 Findings and Recommendations Continuum of Service Options Continuum of Service Options The IDEA establishes nationwide minimum standards for providing education services to children with disabilities, as well as related services for eligible infants, toddlers, preschoolers, children, and youth with disabilities up to the age of 22. It mandates that each state ensure the availability of a FAPE for any child with a disability who needs special education and related services, regardless of whether they have failed or been retained in a course or grade, and even if they are advancing from one grade level to another (Title 34, Section 300.101(c) of the Code of Federal Regulations (34 CFR 300.101(c))). The IDEA also requires that students with disabilities be educated in the least restrictive environment (LRE). To determine the appropriate setting for an individual student, their IEP team reviews the student’s strengths and needs and considers the educational benefit of placement in different educational settings. LRE placement is assessed by the CDE, and the results are published in its local level annual performance report. These reports, which are required by the IDEA, evaluate districts on 14 indicators for which the target is deemed to be either met or not met. Preschool Least Restrictive Environment In 2022-23, the district met two of the three targets for Indicator 6, which assesses the placement of preschool students in the LRE, expressed as a percentage of the total number of preschool students who receive special education services, as shown in Table 4 below. This report shows the district’s, not the dis- trict/county’s, preschool students in the LRE. Table 4: District’s 2022-23 Performance on Indicator 6 — Preschool Students in the LRE Indicator Indicator Rate Target Target Met? 6a Preschool LRE: Regular Program 47.35% ≥43.00% Yes 6b Preschool LRE: Separate Class 46.46% <29.00% No 6c Preschool LRE: Home 2.21% <3.50% Yes Source: Local Level Annual Performance Report 2022-23 (CDE) (most recent report). Despite not meeting one of the indicators for preschool LRE in 2022-23, the district demonstrated impres- sive improvement compared to 2021-22, when it did not meet any of the three indicators for preschool LRE. The district has been focused on improving preschool-age students’ access to general education settings and needs to sustain this momentum. School-Age Least Restrictive Environment In 2022-23, the district met two of the three targets for indicator 5, which assesses the placement of school-age students in the LRE, expressed as a percentage of the total number of school-age students who receive special education services, as shown in Table 5 below. This report shows the district’s, not the district/county’s, school-age students in the LRE. Table 5: District’s 2022-23 Performance on Indicator 5 — School-Age Students in the LRE Indicator Indicator Rate Target Target Met? 5a LRE Rate: In Regular Class More than 80% 67.98% ≥62.00% Yes 5b LRE Rate: In Regular Class Less than 40% 18.53% <16.50% No Fiscal Crisis and Management Assistance Team San Francisco Unified School District 16 Findings and Recommendations Continuum of Service Options Indicator Indicator Rate Target Target Met? 5c LRE Rate: Separate Schools 0.84% <3.00% Yes Source: Local Level Annual Performance Report 2022-23 (CDE) (most recent report). From 2021-22 through 2022-23, the district increased the percentage of students in special education who are in a regular class more than 80% of the time by 2.42% and continued to meet two of the three LRE indicators for school-age students. As described in the next section of this report, FCMAT found that the district has not reported all its data on students who attend nonpublic schools (NPSs), which would be counted as separate schools under Indicator 5c. This means that the district may not have met the LRE rate for Indicator 5c. District/County Continuum of Service Options Early Childhood Special Education Programs School districts typically begin serving a student with a disability in preschool special education programs after a child’s third birthday. However, because it is a single-district county and is its own SELPA, the district/county provides special education assessment and services to students from birth to age 5. The district/county offers the following early childhood special education programs: • Early Start Program This is a statewide program that provides family-centered services and support to families of infants and toddlers from birth to 36 months of age who have developmental delays or disabilities. Individualized Family Service Plans (IFSPs) are developed to meet the needs of each child and family. • Standalone Speech and Language Services At certain district schools, speech and language therapy is provided to eligible pre- school-age children who do not have other special education needs. • Itinerant Early Childhood Special Education Services Itinerant teachers provide services for students ages 3 through 5 in their natural environ- ment, which can include consultations with family and staff as well as direct support to the child. The goal of these services is to ensure progress toward a child’s IEP goals, provide access to curriculum and typical peers, and maintain the child’s current environment. • Integrated General Education Classes Early childhood special education teachers monitor and support students in making pro- cess toward their IEP goals in a general education setting. • Special Day Classes Early childhood special education teachers provide intensive instruction in a separate classroom with a low student-to-teacher ratio to support progress toward IEP goals and peer engagement. These SDCs are noncategorical, which means they serve students in all disability categories. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 17 Findings and Recommendations Continuum of Service Options Support Needs of Preschool Age Students with Autism School-age students with autism spectrum disorder (ASD) are more likely to be educated in more restric- tive settings with less access to the general education curriculum and their typically developing peers than other students with disabilities4 . Therefore, identifying the most important school readiness behaviors and foundational skills that a child with ASD needs to be taught in preschool are essential to improving their ability to participate in general education settings in their school-age years (Fleury, Thompson, and Wong, 2015). The National Clearinghouse on Autism Evidence and Practice (NCAEP) published a report in 2020 titled, Evidence-Based Practices for Children, Youth and Young Adults with Autism, which examines inter- vention literature and describes practices for which there is clear evidence of positive effects for children with ASD. Accordingly, most LEAs offer specialized preschool programs that use evidence-based practices that have been shown to meet the unique needs of students with ASD . In contrast, the district’s/county’s preschool SDC programs are all cross-categorical, meaning that teachers work with students with various disabilities and needs; the district/county does not offer a specialized program for preschool age children with ASD. As stated in the “District/County Special Education Enrollment by Disability Category” section of this report, the number of TK-12 students enrolled in special education with a main disability category of autism increased by 47.44% from 2019-20 through 2024-25. This increase makes it even more critical for the dis- trict/county to evaluate its preschool program. The district/county needs to determine whether it is using the practices that intervention science has demonstrated are effective for preschool age students with ASD, and to determine whether it could provide better support for these students if it had classes specifi- cally designed to meet their unique needs. School-Age Special Education Programs All district/county schools offer special education services, and most students with disabilities can apply to attend a school of their choice. However, some highly specialized services for students with disabilities are available only at specific schools. The district/county offers numerous special education programs for school-age students, as described below: General Education with Special Education Support All district/county schools serving students in grades TK-12 offer accommodations, modifications, supple- mentary aids, and/or supports designated in a student’s IEP. Students in this program are assigned to a general education classroom for most of the school day and have a special education case manager. Resource Specialist Program All district/county schools serving students in grades TK-12 offer a resource specialist program (RSP) where students are in a general education classroom for most of the school day. Services focus on accessing grade-level content with grade-level peers, as well as individualized instructional supports. Students in this program are assigned to a special education teacher (a resource specialist) as case manager. Resource specialist services are provided in the general education classroom and/or a separate setting as indicated in a student’s IEP. 4 American Psychiatric Association. (2013). Diagnostic and Statistical Manual of Mental Disorders (5th ed.). Arlington, VA: American Psychiatric Publishing. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 18 Findings and Recommendations Continuum of Service Options Separate Class or Special Day Class Some district/county schools offer separate, smaller classes with specialized services. Students in this pro- gram are assigned to a separate multigrade class for most of the day and are assigned a special education teacher. Instruction focuses on students accessing common core standards through accommodations, modifications, and specialized academic instruction (SAI). The district/county provides the following special day class (SDC) programs: • Autism-Focused (Mild-to-Moderate Needs) — Programs enriched with evidence-based practices and supports to help students with ASD develop academic, behavioral, and social skills. Student goals are focused on functional communication training, social pragmatics, and self-management skills. • Autism-Focused (Extensive Support Needs) — Programs enriched with evidence-based practices and supports help students with ASD develop preacademic, behavioral, and social skills. Student goals are focused on learning-readiness, adaptive (self-care) skills, communication, and independence. • Cross-Categorical (Mild-to-Moderate Needs) — SDCs in which students spend most of their day in a special education classroom, with integration in general education as appropriate. • Cross-Categorical (Extensive Needs) — SDCs in which students are focused on basic aca- demic, functional, and life skills. Students participate in community-based instruction and are included as appropriate in the general education curriculum and program. • Learning Center — A program in which students receive pull-out intervention for a large percentage of the day but are assigned to a general education classroom. • Success, Opportunity, Achievement, Resiliency (SOAR) (Mild-to-Moderate Needs) — SDCs enriched with therapeutic and behavior supports to help reduce behavioral excesses and develop skills in self-awareness, self-management, social skills, and responsible decision-making. Students typically require instruction in the separate setting for more than 50% of the day until they gain skills to access learning in a general education classroom. • Deaf and Hard of Hearing Auditory/Oral and Total Communication (Mild-to-Moderate Needs) — SDCs in which students are in a separate deaf/hard of hearing auditory oral or total communication classroom for more than 50% of the day. Depending on a student’s IEP, a sign language interpreter may enable the student to access general education classes and extracurricular activities as appropriate. • Access Transition Program — SDCs for adult students until they are 22 years of age. Programming includes post-secondary education, and employment and independent living skills. Students Who Attend a Nonpublic School In addition to in-district/county program options, some district students with IEPs attend an out-of-district/ county program at nonpublic schools (NPSs). NPSs are privately operated, publicly funded schools that specialize in providing educational services for students with exceptional needs that cannot be met in a traditional public school setting. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 19 Findings and Recommendations Continuum of Service Options FCMAT found discrepancies between the number of district/county students reported to be attending an NPS in DataQuest (based on data the district/county reported to CALPADS), the district/county’s special education information system (SEIS), the district/county’s student information system (SIS), and spread- sheets provided by the district/county that track the number of students attending an NPS. According to DataQuest's 2023-24 Special Education Enrollment by Grade Report, the San Francisco County Office of Education reported 80 students were attending an NPS, and San Francisco Unified reported no students attending an NPS. In 2023-24, based on data provided by the district/county, FCMAT estimates that the district/county had 141 students attending an NPS, which is 61 students more than it reported to CALPADS. Staff stated that the district/county has historically underreported to CALPADS the number of students in special education who attend an NPS. Staff explained that this has occurred because the student data in its SIS and SEIS do not match. The district/county reported it has historically recorded all students who are attending an NPS in its SIS as San Francisco County Office of Education students. However, the LEA for some students who attend an NPS was not listed in SEIS as the San Francisco County Office of Education. This created an error when the district/county CALPADS administrator attempted to certify and transmit district/county data to CALPADS. Staff explained that in some cases the district/county CALPADS admin- istrator changed the data to remove from enrollment students who were attending an NPS but whose records were generating errors so that the county/district could certify and report its data. Therefore, data for certain students attending an NPS was not submitted to CALPADS. To correct this issue, staff stated, in 2024 the district/county began enrolling and reporting all students who attend an NPS as San Francisco Unified students in both its SIS and SEIS. In addition, staff are comparing reports from the district/county’s SIS and SEIS regularly to identify and correct any LEA mismatches of stu- dents attending an NPS. Not correctly reporting the number of these students in CALPADS has two significant consequences. First, because student data is not just about numbers but tells a story of district/county students, not reporting it for all students who attend an NPS means that the district/county is not telling an accurate story about its students. Second, the CDE uses the district/county data to measure indicator 5c on its annual performance report, LRE rate for separate schools such as an NPS. If this data is not reported correctly, then indicator 5c referenced in the “Continuum of Service Options” section of this report is not accurate. In addition, the district/county may not be collecting funding for all its students who are attending an NPS, including funding based on average daily attendance (ADA). For example, in 2023-24, FCMAT found dis- crepancies in district/county-reported data, as shown in Table 6 below. Table 6: Number of District/County Students Reported Attending an NPS vs. District Records, 2023-24 Number of District/County NPS Enrollment Reported on Students Reported as District P-2 ADA of Students District/County NPS Tracking School Year Attending an NPS in CALPADS Attending an NPS* Spreadsheet 2023-24 80 94.47 141 Sources: DataQuest's 2023-24 Special Education Enrollment by Grade Report, CDE Funding Exhibits - Second Principal Apportionment, and district-provided data. *This includes students in NPSs, licensed children’s institutes (LCIs), extended year NPSs, and community day school. The P-2 ADA that the district/county collected for students attending an NPS in 2023-24 was more than the number of students the district/county reported to CALPADS as attending an NPS. However, it was signifi- Fiscal Crisis and Management Assistance Team San Francisco Unified School District 20 Findings and Recommendations Continuum of Service Options cantly less than the number of students on the district/county’s NPS tracking spreadsheet and the number of students it made payments for who were attending an NPS. In addition, the ADA reported includes ADA for students who attend community day schools, so the ADA reported for students attending an NPS in 2023-24 appears to be based on the number of students reported to be attending an NPS in CALPADS instead of the actual NPS enrollment. The National Center for Education Statistics reported that San Francisco Unified received $23,716 in total revenue (federal, state and local) per student in 2020-21 (the most recent year for which this data is avail- able). Therefore, it is essential that the district/county report the enrollment and ADA for all its students who attend an NPS to ensure it does not lose revenue. Differentiating District from County Special Education Programs A special education local plan area (SELPA) must ensure that a continuum of special education service options is available to meet the needs of students with disabilities. Most LEAs are part of a multiple-LEA SELPA (i.e., two or more district or charter LEAs which do not include a county office of education (COE)) or a COE-joined SELPA (i.e., one or more district or charter LEAs join one or more COEs). An LEA that is a member of a multiple-LEA or COE-joined SELPA typically can offer and provide a student with a FAPE that includes placement in different levels of specialized classes to meet the differing needs of students with disabilities. Three common specialized class levels are described below. 1. District or Charter LEA-Based Specialized Classes — These classes are run by a district or charter LEA for students in their own LEA. Specialized classes may be designed for students with a particular need (mild-to-moderate or extensive) or who qualify for special education under a specific disability category such as autism or emotional disability. 2. Regional Specialized Classes — These classes are offered regionally for students throughout a SELPA and may be operated by a COE or a district or charter LEA in the SELPA. Regional specialized classes typically serve students who qualify for special education under a specific disability category such as autism or an emotional disability, or who have extensive needs. 3. Nonpublic Schools — The most specialized classes are typically operated by an NPS and serve students whose needs cannot be met in a regional specialized class. A student attending the first type of specialized class above typically has fewer needs than a student attending the second or third types of specialized classes. Accordingly, these latter two types of classes typically have a lower student-to-staff ratio and a higher level of support from related service providers such as behaviorists. Because it is a single district/county SELPA, most staff in the district/county do not differentiate between district and county special education programs. The only exceptions to this are the Early Start program for infants and toddlers with developmental needs and the McAuley Counseling Enriched Education Program, which is an outpatient educational and therapeutic program run in partnership with the San Francisco Department of Public Health-Behavioral Health Services. Staff explained that the district/county’s specialized classes for students with autism, extensive support needs, and behavioral or social-emotional needs are all considered district classes, and that they have not been differentiated by different adult-to-student ratios or level of support from related service providers to meet varying student needs. This lack differentiation does not occur in most other SELPAs, and it may be causing the district/county to miss an opportunity to meet students’ needs in a district/county class instead of placing them in an NPS. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 21 Findings and Recommendations Continuum of Service Options The district/county needs to analyze the needs of students in its SDC programs for students with autism, extensive support needs, and behavioral/social-emotional needs to determine how it may be able to distin- guish district from county classes. Specialized county classes should differ from specialized district classes based on clearly defined distinctions in student support needs, class sizes, and level of support from related service providers such as behaviorists. Once it has differentiated district and county specialized classes from one another, the district/county will need to analyze the support needs of students currently attending an NPS to determine if there are groups of students of similar age with similar support needs who could be moved from an NPS to a county-operated program. If the district/county expands its continuum of services this way, information about this will need to be communicated clearly to all educational partners. Recommendations The district/county should: 1. Continue to monitor what percentage of the school day students with IEPs spend in general education settings, with a focus on meeting or exceeding LRE targets in its Local Level Annual Performance Report. 2. Evaluate its preschool programs to determine if it is using the practices that intervention science has demonstrated are effective for preschool-age students with ASD. 3. Consider whether a preschool SDC program specially designed to meet the unique needs of preschool-age students with ASD would allow it to provide better support for students with autism. 4. Continue to regularly compare NPS enrollment data from its SIS and SEIS to identify and correct any LEA mismatches for students attending an NPS. 5. Instead of removing the enrollment record for a student when it generates an error in CALPADS reporting, correct any special education-related errors that prevent CALPADS data from being certified and reported. 6. Check its enrollment-to-ADA ratios to make sure it reports ADA for all students who attend an NPS. 7. Determine whether expanding its continuum of special education services by distinguishing between specialized district and county programs would enable it to serve additional students in a district or county program instead of an NPS. 8. Analyze the support needs of students who attend an NPS to determine if there groups of students of similar age with similar support needs who could be moved from an NPS to a county-operated program if the district/county were to expand its special education services. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 22 Findings and Recommendations Special Education Teacher Staffing Special Education Teacher Staffing FCMAT compared the district/county’s special education teacher staffing to statewide guidelines and/or industry standards. Resource Specialist Program Teacher Staffing Education Code 56362(c) states: Caseloads for resource specialists shall be stated in the local policies developed pursuant to Section 56195.8 and in accordance with regulations established by the board. No resource specialist shall have a caseload which exceeds 28 pupils. The contract between the district and United Educators of San Francisco (UESF) specifies a maximum case- load of 27 students for resource specialist program (RSP) teachers. In 2024-25, the district/county has 248.80 full-time equivalent (FTE) resource specialists. Based on case- load estimates provided by the district/county, these teachers manage the cases of 5,014 students, averag- ing 20.15 students per teacher, as shown in Table 7 below. Table 7: Resource Specialist Teacher Staffing, 2024-25 Staffing Needed Staffing Total to Meet Above (+) or Below (-) Teacher Total Student Average Teacher Education Education Code School Level FTE Caseload Caseload Code Standard Standard Early Childhood 8.00 72 9.00 2.57 +5.43 Elementary School 77.00 1,559 20.25 55.68 +21.32 K-8 School 17.80 428 24.04 15.29 +2.51 Middle School 54.00 1,075 19.91 38.39 +15.61 High School 92.00 1,880 20.43 67.14 +24.86 Total 248.80 5,014 20.15 179.07 +69.73 Sources: District-provided data and EC 56362(c). Districtwide/countywide resource specialist staffing is 69.73 FTE more than what is required to meet the EC 56362(c) caseload standard. However, the students who receive support from a resource specialist are not neatly distributed into groups of 28 across district/county schools. Thus, having more staffing than is required to meet the EC 56362(c) standard may be necessary. In addition, the standard outlined in EC 56362(c) is based on a maximum caseload, which is higher than the statewide caseload average observed in LEAs that serve students using an inclusive model. Although the definition of an inclusive model varies across California’s school districts, the intent of such a model is to enable students to attend their neighborhood schools, progress through the grade levels that match their chronological ages, and access general education classes and curricula to the greatest extent possible. As described in the section of this report that discusses placement in the least restrictive environment, the district/county met four of the six indicators that measure LRE on its annual performance report and is operating an inclusive program. Accordingly, resource specialist staffing that exceeds the 1-to- Fiscal Crisis and Management Assistance Team San Francisco Unified School District 23 Findings and Recommendations Special Education Teacher Staffing 28 teacher-to-student ratio may be needed to provide sufficient services to meet students’ needs; these services are based on factors such as the number of specialized academic instruction (SAI) minutes in a student’s IEP and the percentage of time a student is in general education. The district/county’s staffing guide defines a resource setting for students with mild-to-moderate or exten- sive needs as including “push-in, pull-out, and collaborative teaching of SAI to access core curriculum and/ or special class core instruction for less than 50% of day.” The district/county staffing guide sets two different teacher-to-student ratios for resource settings, which are based on a student’s support needs, as shown in Table 8 below. Table 8: District/County Special Education Teacher Staffing Guidelines Number of Students by their Support Needs Number of Special Education Teachers For every 28 students with mild-to-moderate support needs in One mild-to-moderate support needs or one extensive support general education classes for greater than 50% of the instructional needs credentialed education specialist. day. For every 16-22 students with extensive support needs in general One mild-to-moderate support needs or one extensive support education class for greater than 50% of the instructional day. needs credentialed education specialist. Source: District/County Special Education School Site Staffing Guide School Year 2024-2025. The district/county staffing guide, taking into consideration the support need/service level and percentage of the instructional day the student is in general education, accounts for students’ needs and states the following: “we believe that if sites have appropriate levels of staffing and support given the specific needs, accommodations and modifications outlined in each student’s IEP, we will ensure student success in meet- ing IEP goals and build their independence as learners.” The staffing guide explains that staffing allocations will be made after analyzing the cumulative student needs per site, the special education pathway (pro- gram) and SAI minutes in students’ IEPs, and contractual guidelines for case managers. The district/county staffing guide also references the IDEA’s mandate to serve students in the LRE and the district/county’s commitment to inclusive practices. It states, “many students may receive instruction in the general education classroom for the majority of the day, including those with IEPs who require significant levels of service.” Because some students with mild-to-moderate needs require higher levels of SAI, the district/county staffing guide uses a higher staffing ratio for students with high minutes of SAI, rather than only for those with extensive needs. Students with mild-to-moderate needs who require SAI for more than 90, 110, or 120 minutes per day for elementary, middle, and high schools, respectively, are allocated teach- ers at a 1-to-22 teacher-to-student ratio. The district/county’s contractual caseload ratios can also be modified depending on the students’ eligibility and their instructional setting (i.e., general education resource setting or special class setting). It is appropriate to allocate additional RSP teachers to support students with higher minutes of service and/ or higher support needs. In addition, using a 1-to-22 teacher-to-student ratio is reasonable because the industry standard for SAI-based programs supporting students in their LRE is 20-24 students per special education teacher. FCMAT did not determine how many of the district/county’s students in the resource program required a 1-to-22 teacher-to-student ratio due to the students’ needs and level of SAI based on the formula outlined in the district/county’s staffing guide. However, in 2024-25 the district/county is staffed at 20.89 FTE more than what would be required if every resource program student qualified for the 1-to-22 teacher-to-student ratio, as shown in Table 9 below. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 24 Findings and Recommendations Special Education Teacher Staffing Table 9: District/County Resource Specialist Staffing at a 1-to-22 Ratio, 2024-25 Total RSP Staffing Staffing FTE Total RSP Total RSP Needed to Meet Above (+) or Below (-) Teacher Student Average Teacher Teacher-to-Student District/County Staffing FTE Caseload Caseload Ratio of 1-to-22 Guide Ratio of 1-to-22 2024-25 Districtwide/ 248.80 5,014 20.15 227.91 +20.89 Countywide Data Sources: District/county-provided data and District/County Special Education School Site Staffing Guide School Year 2024-2025. The district/county has adopted a flexible and reasonable method to determine the number of special education teacher positions it needs, based on student support needs and SAI time. This method, using a 1-to-22 teacher-to-student ratio, is aligned with the industry-standard caseload for SAI-based programs. However, the district/county does not use this method to determine staffing for its resource program. The main reason for this is that many district/county staff do not recognize that the resource program is overstaffed or the consequences of this problem. In addition, staff indicated that the Special Education Department has proposed RSP teacher reductions and attempted to move RSP teachers from schools with lower RSP student-to-teacher ratios to schools with higher RSP student-to-teacher ratios in the past, but these changes were not approved because of resistance from school staff or because the board of trustees did not approve the plan. The industry-standard practice is to share a resource teacher between two schools when caseloads are low at both schools, but staff reported the district/county rarely does this. As a result, some district/county schools have more staffing than needed to meet an RSP teacher-to-student ratio of 1-to-22 while others do not have enough staffing to meet this ratio, and eight schools are below the RSP teacher-to-student ratio of 1-to-28 required to meet the EC 56362(c) caseload standard. Table 10 below shows only district/county schools that have more than 0.5 FTE more or less than the staffing needed to meet the RSP teacher to stu- dent ratio of 1-to-22. Resource specialist staffing data for all district/county schools is shown in Appendix A. Table 10: District/County Resource Specialist Staffing at a 1-to-22 Ratio by School, 2024-25 Staffing Needed to Meet RSP Staffing FTE Total RSP Average RSP Teacher-to- Above (+) or Below (-) Total RSP Student Caseload Per Student Ratio of District/County Staffing School Teacher FTE Caseload Teacher 1-to-22 Guide Ratio of 1-to-22 Washington (George) High 10 250 25.00 11.36 -1.36 School (HS) Galileo HS 6 160 26.67 7.27 -1.27 Lakeshore Elementary School 1 49 49.00 2.23 -1.23 (ES) Carmichael (Bessie) 3 90 30.00 4.09 -1.09 K-8 Asawa (Ruth) SOTA 3 89 29.67 4.05 -1.05 HS Mission HS 7 174 24.86 7.91 -0.91 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 25 Findings and Recommendations Special Education Teacher Staffing Staffing Needed to Meet RSP Staffing FTE Total RSP Average RSP Teacher-to- Above (+) or Below (-) Total RSP Student Caseload Per Student Ratio of District/County Staffing School Teacher FTE Caseload Teacher 1-to-22 Guide Ratio of 1-to-22 Burton (Phillip and 6 148 24.67 6.73 -0.73 Sala) HS Brown Jr. (Willie) 2 57 28.50 2.59 -0.59 Middle School (MS) Denman (James) MS 4 101 25.25 4.59 -0.59 Lilienthal (Claire) K-8 1 34 34.00 1.55 -0.55 Creative Arts K-8 1.8 51 28.33 2.32 -0.52 Charter McKinley ES 1 33 33.00 1.50 -0.50 Tenderloin 1 33 33.00 1.50 -0.50 Community ES Jordan (June) HS 2 33 16.50 1.50 +0.50 Garfield ES 1.5 21 14.00 0.95 +0.55 Gateway MS Charter 6.5 128 19.69 5.82 +0.68 Hilltop HS 1 7 7.00 0.32 +0.68 The Academy - SF 2 29 14.50 1.32 +0.68 @ McAteer HS Youth Chance High 1 7 7.00 0.32 +0.68 School SF International HS 1 6 6.00 0.27 +0.73 Hoover (Herbert) MS 5 94 18.80 4.27 +0.73 C.A.R.E. Buchanan 1 5 5.00 0.23 +0.77 Harte (Bret) ES 2 27 13.50 1.23 +0.77 Lawton K-8 2 26 13.00 1.18 +0.82 Aptos MS 6 114 19.00 5.18 +0.82 Everett MS 3 47 15.67 2.14 +0.86 Sherman ES 3 46 15.33 2.09 +0.91 C.A.R.E. Bayview 1 1 1.00 0.05 +0.95 SF Civic Center 2 23 11.50 1.05 +0.95 Secondary HS King Jr (Dr Martin 4 66 16.50 3.00 +1.00 L) MS Marshall (Thurgood) 3 42 14.00 1.91 +1.09 HS Roosevelt MS 4 63 15.75 2.86 +1.14 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 26 Findings and Recommendations Special Education Teacher Staffing Staffing Needed to Meet RSP Staffing FTE Total RSP Average RSP Teacher-to- Above (+) or Below (-) Total RSP Student Caseload Per Student Ratio of District/County Staffing School Teacher FTE Caseload Teacher 1-to-22 Guide Ratio of 1-to-22 Independence HS 5 81 16.20 3.68 +1.32 O'Connell (John) HS 6 98 16.33 4.45 +1.55 Downtown HS 3 24 8.00 1.09 +1.91 Source: District/county-provided data. Notes: 8.0 FTE of the RSP teachers assigned to the preschool program and the 72 preschool students they support, and 4.0 FTE of the RSP teachers who were not assigned to a school and the 58 students they support, were removed for this analysis. The resulting dataset includes 236.8 FTE district/county RSP teachers, who manage the cases of 4,884 RSP students. This table reports only the district/county schools that have greater than 0.5 FTE more or less than the staffing needed to meet the RSP teach- er-to-student ratio of 1-to-22. Special Day Class Staffing The Education Code does not define caseload maximums for SDC programs. Article 9.5.7 of the district/ county’s contract with UESF states, “A Special Day Class exists when there are students who receive spe- cial education instruction greater than 50% of their school day.” The district/county staffing guide’s student- to-teacher ratios for SDC programs are shown alongside industry standards in Table 11 below. Table 11: District/County Special Education Teacher Staffing Guideline and Industry Standards for SDC Programs District/County Special Education Pathway District/County Staffing Guideline Industry-Standard Caseload Range Mild/Moderate Support Needs Special 10-12 students per 1 teacher 12-15 students per 1 teacher Day Class – Cross-Categorical Mild/Moderate Support Needs Special 10-12 students per 1 teacher 12-15 students per 1 teacher Day Class – Autism Focus Extensive Support Needs Special Day 8-10 students per 1 teacher 10-12 students per 1 teacher Class – Cross-Categorical Extensive Support Needs Special Day 8-10 students per 1 teacher 8-10 students per 1 teacher Class – Autism Focus SOAR Special Day Class – Mental 8-12 students per 1 teacher 8-10 students per 1 teacher Health and Behavioral Support Needs Access (Community, Access and 10-12 students per 1 teacher 10-12 students per 1 teacher Transition for 18–22-year-olds) Sources: District/County Special Education School Site Staffing Guide School Year 2024-2025 and industry standards. The district/county’s SDC staffing guidelines for classes for students with mild-to-moderate and extensive support needs specify lower caseloads than the industry standards. The district/county needs to evaluate whether aligning its SDC caseload guidelines with industry standards would allow it to reduce costs while continuing to meet students’ needs. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 27 Findings and Recommendations Special Education Teacher Staffing In the spring of 2024, the district and UESF agreed to change language in their contracts about caseloads for a few types of special education staff, including SDC teachers. Article 9.6.2, Caseload Overages, indi- cates that when the specified caseload is exceeded the unit member may receive overload pay, students may be reassigned to another student, or additional staff may be assigned to the school. School-Age Mild-to-Moderate Special Day Class Programs In 2024-25, the district/county has 69.85 FTE SDC teachers of classes for school-age students with mild-to-moderate support needs. Based on caseload estimates provided by the district/county, these teachers manage the cases of 785 students, averaging 11.24 students per teacher, as shown in Table 12 below. Table 12: District/County Mild-to-Moderate SDC Program Teacher Staffing, 2024-25 Total Total Teacher Industry- Teacher Student Caseload Standard Staffing FTE School Level FTE Caseload Average Caseload Range Above (+) or Below (-) Industry Standard Elementary 12-15 students per +3.10 FTE (above 12 students per teacher) 34.85 381 10.93 School teacher +9.45 FTE (above 15 students per teacher) 12-15 students per +0.33 FTE (above 12 students per teacher) K-8 School 3.00 32 10.67 teacher +0.87 FTE (above 15 students per teacher) 12-15 students per +0.67 FTE (above 12 students per teacher) Middle School 14.00 160 11.43 teacher +3.33 FTE (above 15 students per teacher) 12-15 students per +0.33 FTE (above 12 students per teacher) High School 18.00 212 11.78 teacher +3.87 FTE (above 15 students per teacher) 12-15 students per +4.43 FTE (above 12 students per teacher) Total 69.85 785 11.24 teacher +17.52 FTE (above 15 students per teacher) Sources: District/county-provided data and industry standards. The districtwide/countywide mild-to-moderate SDC teacher caseload average is below the industry-stan- dard range of 12-15 students per teacher at every school level. As a result, the district/county is staffed with 4.43 SDC teacher FTE more than what it would need to meet a caseload average of 12 students per teacher and 17.52 SDC teacher FTE more than what it would need to meet a caseload average of 15 students per teacher. The district/county is staffed above the industry standard range because it determines its staffing using a caseload range of 10-12 students per mild-to-moderate SDC teacher. The district/county needs to determine whether raising its mild-to-moderate SDC caseload averages to match industry standards would allow it to decrease teacher staffing and still meet students’ needs. SOAR Special Day Class Program In 2024-25, the district/county has 9.00 FTE SDC teachers of classes for students with social-emotional and behavioral support needs. Based on caseload estimates provided by the district/county, these teachers manage the cases of 60 students, averaging 6.67 students per teacher, as shown in Table 13 below. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 28 Findings and Recommendations Special Education Teacher Staffing Table 13: District/County SOAR SDC Program Teacher Staffing, 2024-25 Average Total Caseload Industry- Staffing FTE Total Teacher Student Per Standard Above (+) or Below (-) Industry Program FTE Caseload Teacher Caseload Range Standard 8 -10 students per +1.50 FTE (above 8 students per teacher) SOAR 9.00 60 6.67 teacher +3.00 FTE (above 10 students per teacher) Sources: District/county-provided data and industry standards. The districtwide/countywide SOAR SDC teacher caseload average is less than the industry-standard range of 8-10 students per teacher. As a result, the district/county SOAR teacher staffing is 1.50 FTE above what it would need to meet a caseload average of eight students per teacher and 3.00 FTE above what it would need to meet a caseload average of 10 students per teacher. The district/county needs to deter- mine whether raising its SOAR caseload averages to match industry standards would allow it to decrease teacher staffing and still meet students’ needs. School-Age Extensive Support Needs Special Day Class Program In 2024-25, the district/county has 41.00 FTE SDC teachers of classes for school-age students with exten- sive support needs. Based on caseload estimates provided by the district/county, these teachers manage the cases of 386 students, averaging 9.41 students per teacher, as shown in Table 14 below. Table 14: District/County Extensive Support Needs SDC Program Teacher Staffing, 2024-25 Average Total Teacher Total Student Caseload School Level FTE Caseload Per Teacher Industry-Standard Caseload Range 8-10 students per teacher – Autism focus Elementary School 15.00 138 9.20 10-12 students per teacher – cross-categorical 8-10 students per teacher – Autism focus K-8 School 2.00 17 8.50 10-12 students per teacher – cross-categorical 8-10 students per teacher – Autism focus Middle School 8.00 80 10.00 10-12 students per teacher – cross-categorical 8-10 students per teacher – Autism focus High School 16.00 151 9.44 10-12 students per teacher – cross-categorical 8-10 students per teacher – Autism focus Total 41.00 386 9.41 10-12 students per teacher – cross-categorical Sources: District/county-provided data and industry standards. FCMAT was unable to determine whether the district/county’s teacher staffing for SDCs for students with extensive support needs were aligned with the industry standards. Although the district/county offers dif- ferent pathways for students with different needs, such as Autism, the district/county’s data did not differ- entiate between cross-categorical and autism-focused SDCs, which have different caseload ranges. The district/county needs to begin distinguishing its SDCs for students with autism from other SDCs in its data because both the district/county’s staffing guide and industry standards use different caseload sizes for these classes. After the district/county does this, it will need to review caseloads and assess students’ needs to determine if it should adjust teacher staffing for any of these classes. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 29 Findings and Recommendations Special Education Teacher Staffing Access Special Day Class Program In 2024-25, the district/county has 18.00 FTE SDC teachers of classes for adult students ages 18 to 22 who have extensive support needs. Based on caseload estimates provided by the district/county, these teach- ers manage the cases of 178 students, averaging 9.89 students per teacher, as shown in Table 15 below. Table 15: District/County Access SDC Program Teacher Staffing, 2024-25 Average Total Caseload Staffing FTE Total Teacher Student Per Industry-Standard Above (+) or Below (-) School Level FTE Caseload Teacher Caseload Range Industry Standard Adult 18.00 178 9.89 10-12 students per teacher Within Industry Standard Range Sources: District/county-provided data and industry standards. After rounding, the districtwide/countywide Access Program caseload average of 9.89 students per teacher is within the industry standard range of 10-12 students per teacher. The district/county needs to continue to review caseload projections and assess students’ needs annually to determine if it should adjust teacher staffing in this program. Recommendations The district/county should: 1. Evaluate whether aligning its SDC caseload guidelines with industry standards would allow it to reduce the number of teachers needed for these programs while continuing to meet students’ needs. 2. Reduce the number of RSP teachers in accordance with the district/county staffing guide. 3. Use factors such as caseload numbers, student needs, and schoolwide needs to determine which schools can share an RSP teacher. 4. Begin tracking SDC teacher caseload data by specialized pathway (i.e., SOAR, Autism, Access). Analyze teacher-to-student ratios by SDC pathway using the district/county staffing guidelines and industry standards, and take into consideration student need, to determine if consolidating classes to reduce SDC teacher staffing is warranted. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 30 Findings and Recommendations Special Education Paraeducator Staffing Special Education Paraeducator Staffing Special education paraeducators, also known as special education aides or instructional assistants, are trained professionals who work with students, typically under the direction of a classroom teacher. LEAs often employ special education paraeducators under different titles with distinct job descriptions to per- form functions such as supporting specialized academic instruction, specialized medical support, behav- ioral support, and 1-to-1 student support or intensive individual service (IIS). The district/county’s special education supervisors coordinate with the Special Education Department’s allocation team to assign paraeducators to schools using a set formula, which can be modified based on factors such as class size and students’ needs. Schools are responsible for hiring and supervising special education paraeducators. Industry-Standard Paraeducator Staffing Ratios The industry-standard base staffing for SDCs is to assign one paraeducator for every teacher of students with mild-to-moderate and extensive support needs. For SDCs serving students with autism, the standard is two special education paraeducators for every teacher. In addition, the industry standard for staffing in excess of the SDC base staffing level is determined by an adult-to-student ratio, as shown in Table 16 below. Table 16: Industry-Standard Paraeducator Staffing and Adult-to-Student Ratios Industry-Standard SDC Support Level SDC Focus Special Education Paraeducator Staffing Adult-to-Student Ratio One to two six-hour special education paraeducators for Mild-to-Moderate Noncategorical 1-to-7 a class size of 12-15 One to two six-hour special education paraeducators for Extensive Noncategorical 1-to-5 a class size of 10-12 Two to four six-hour special education paraeducators for All Autism 1-to-3 a class size of 8-10 Source: Industry standards. Note: Industry-standard staffing for special education paraeducators is determined by class size to meet an adult-to-student ratio, which includes the classroom teacher and special education paraeducator(s). District/County Paraeducator Staffing Guidelines for SDCs The district/county assigns paraeducators to its SDCs according to the guidelines shown in Table 17 below. Table 17: District/County’s Special Education Paraeducator Staffing Guidelines for SDCs Number of Program Class Size Number of Teachers Paraeducators Mild-to-Moderate Special Day Class – Cross-Categorical 8-12 1 1 Mild-to-Moderate Special Day Class – Autism Focus 8-12 1 2 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 31 Findings and Recommendations Special Education Paraeducator Staffing Number of Program Class Size Number of Teachers Paraeducators Extensive Special Day Class – Cross-Categorical 6-10 1 2 Extensive Special Day Class – Autism Focus 6-10 1 2 SOAR Special Day Class – Mental Health and Behavioral 8-10 1 2 Access (Community, Access and Transition 18–22-year- 6-10 1 3 olds) Source: District/County Special Education School Site Staffing Guide School Year 2024-2025. Establishing paraeducator staffing guidelines for SDC programs is a good practice, but the district/county’s class size ranges do not match the industry standards, and because the district/county does not use an adult-to-student staffing ratio to determine paraeducator staffing, it may be over- or understaffed. Assigning more paraeducator support than necessary is costly and may limit students’ opportunities to gain indepen- dence; however, not assigning enough paraeducators to an SDC can mean that students lack appropriate support and supervision. Therefore, the district/county would benefit from adding an adult-to-student ratio to its paraeducator staffing guidelines for SDCs. When using such a ratio to determine staffing, it is the best practice to include the teacher and classroom paraeducators in the adult portion of the ratio, and to remove any students who have a 1-to-1 paraeducator and their assigned 1-to-1 paraeducator from the ratio. District/County Paraeducator Staffing In 2024-25, the district/county has 1,304 special education paraeducators providing a total of 927.56 FTE, as shown in Table 18 below. Table 18: District/County’s Special Education Paraeducators by Type, 2024-25 Type of Paraeducator Number of Paraeducators Number of FTE Paraeducators Classroom 671 480.81 1-to-1 Support 589 416.44 Bus 44 30.31 Total 1,304 927.56 Source: District/County-provided data. Of its 671 (480.81 FTE) special education classroom paraeducators, the district/county reported that 371 of these employees work in SDCs and the other 300 serve in the RSP. FCMAT compared the district/county’s SDC paraeducator staffing to industry-standard paraeducator staffing for SDCs, which is based on an adult- to-student ratio, and found that the district/county has 26 SDCs staffed with one paraeducator more than the industry-standard adult-to-student ratio and 17 SDCs that may be staffed with one paraeducator less than the industry-standard ratio. It was not possible for FCMAT to definitively determine whether the SDCs that may be staffed with one paraeducator less than the industry-standard adult-to-student ratio actually are. This is because, as men- tioned earlier, it is the best practice to include the teacher and classroom paraeducators in the adult portion of the ratio, and to remove from the ration any students who have a 1-to-1 paraeducator and their assigned 1-to-1 paraeducator. However, the district/county reported that it does not track which paraeducators are Fiscal Crisis and Management Assistance Team San Francisco Unified School District 32 Findings and Recommendations Special Education Paraeducator Staffing assigned to which SDC at a school, so, FCMAT was unable to remove any students who have a 1-to-1 par- aeducator and their assigned 1-to-1 paraeducators when calculating ratios. This means that the 26 SDCs reported as exceeding the industry standard adult-to-student ratio may not be exceeding it, and that other SDCS could potentially have fewer adults than the district/county’s data shows, because 1-to-1 paraeduca- tors and their assigned students are not being removed from the count. District/county SDCs that do not have the industry-standard adult-to-student ratio are shown in Table 19 below. Data for all district/county SDCs is presented in Appendix B. Because the district/county does not track paraeducator assignments by SDC at a school, FCMAT was unable to remove any students who have a 1-to-1 paraeducator and their assigned 1-to-1 paraeducators when calculating ratios. This means that the SDCs reported as aligned with the industry-standard ratio may be so reported only because the data includes one or more 1-to-1 paraeducators. The district/county needs to begin tracking 1-to-1 special education paraeducator assignments by SDC so it can determine actual SDC staffing numbers and ratios. Table 19: District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry- Teacher and Standard Classroom Teacher and Support Classroom Staffing Above Number of Paraeducator- Support (+) or Below Number of Classroom to-Student Paraeducator- (-) Industry School Site SDC Class Type Students Paraeducators Ratio to-Student Ratio Standard Alvarado ES Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 Mild-to-Moderate AP Giannini MS Needs Autism 12 2 3-to-12 or 0.25 1-to-3 or 0.33 -1 Focus AP Giannini MS Extensive Needs 9 2 3-to-9 or 0.33 1-to-5 or 0.20 +1 Mild-to-Moderate Argonne ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Mild-to-Moderate Argonne ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Balboa HS Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 Balboa HS Extensive Needs 9 2 3-to-9 or 0.33 1-to-5 or 0.20 +1 Burton HS Extensive Needs 8 2 3-to-8 or 0.38 1-to-5 or 0.20 +1 Burton HS Extensive Needs 9 2 3-to-9 or 0.33 1-to-5 or 0.20 +1 Mild-to-Moderate El Dorado ES Needs Autism 12 2 3-to-12 or 0.25 1-to-3 or 0.33 -1 Focus Mild-to-Moderate Galileo HS Needs Autism 6 2 3-to-6 or 0.50 1-to-3 or 0.33 +1 Focus Fiscal Crisis and Management Assistance Team San Francisco Unified School District 33 Findings and Recommendations Special Education Paraeducator Staffing Industry- Teacher and Standard Classroom Teacher and Support Classroom Staffing Above Number of Paraeducator- Support (+) or Below Number of Classroom to-Student Paraeducator- (-) Industry School Site SDC Class Type Students Paraeducators Ratio to-Student Ratio Standard Mild-to-Moderate Garfield ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Huerta (Dolores) Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 ES Huerta (Dolores) Extensive Needs 6 2 3-to-6 or 0.50 1-to-5 or 0.20 +1 ES Mild-to-Moderate Jefferson ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Key (Francis Scott) Extensive Needs 7 2 3-to-7 or 0.43 1-to-5 or 0.20 +1 ES Key (Francis Scott) Extensive Needs 6 2 3-to-6 or 0.50 1-to-5 or 0.20 +1 ES King (Thomas Extensive Needs 6 2 3-to-6 or 0.50 1-to-3 or 0.33 +1 Starr) ES Autism Focus Mild-to-Moderate Lakeshore ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Mild-to-Moderate Lakeshore ES Needs Autism 12 2 3-to-12 or 0.25 1-to-3 or 0.33 -1 Focus Lawton K-8 Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 Lawton K-8 Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 Lawton K-8 Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 Mild-to-Moderate Lincoln HS Needs Autism 12 2 3-to-12 or 0.25 1-to-3 or 0.33 -1 Focus Extensive Needs Lincoln HS 6 2 3-to-6 or 0.50 1-to-3 or 0.33 +1 Autism Focus Extensive Needs Lincoln HS 6 2 3-to-6 or 0.50 1-to-3 or 0.33 +1 Autism Focus Lowell HS Extensive Needs 9 2 3-to-9 or 0.33 1-to-5 or 0.20 +1 Lowell HS Extensive Needs 10 2 3-to-10 or 0.30 1-to-5 or 0.20 +1 Mild-to-Moderate McKinley ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Fiscal Crisis and Management Assistance Team San Francisco Unified School District 34 Findings and Recommendations Special Education Paraeducator Staffing Industry- Teacher and Standard Classroom Teacher and Support Classroom Staffing Above Number of Paraeducator- Support (+) or Below Number of Classroom to-Student Paraeducator- (-) Industry School Site SDC Class Type Students Paraeducators Ratio to-Student Ratio Standard Mild-to-Moderate Miraloma ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Mild-to-Moderate Miraloma ES Needs Autism 12 2 3-to-12 or 0.25 1-to-3 or 0.33 -1 Focus Mission HS Extensive Needs 9 2 3-to-9 or 0.33 1-to-5 or 0.20 +1 Mission HS Extensive Needs 9 2 3-to-9 or 0.33 1-to-5 or 0.20 +1 Presidio MS Extensive Needs 7 2 3-to-7 or 0.43 1-to-5 or 0.20 +1 Mild-to-Moderate Roosevelt MS Needs Autism 12 2 3-to-12 or 0.25 1-to-3 or 0.33 -1 Focus Mild-to-Moderate Sherman ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Mild-to-Moderate Sherman ES Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Focus Sunnyside ES Extensive Needs 7 2 3-to-7 or 0.43 1-to-5 or 0.20 +1 Sunnyside ES Extensive Needs 5 2 3-to-5 or 0.60 1-to-5 or 0.20 +1 Mild-to-Moderate Taylor (Edward Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 R) ES Focus Mild-to-Moderate Tenderloin Needs Autism 13 2 3-to-13 or 0.23 1-to-3 or 0.33 -1 Community ES Focus Washington HS Extensive Needs 8 2 3-to-8 or 0.38 1-to-5 or 0.20 +1 Washington HS Extensive Needs 8 2 3-to-8 or 0.38 1-to-5 or 0.20 +1 Source: District/county-provided data. Notes: This table shows data for 228 of the district/county classroom special education paraeducators working in an SDC; it includes only SDCs that are above or below the industry standard. It also excludes data for district/county classroom special education paraeducators working in preschool, deaf/hard of hearing, SOAR, and Access SDCs because FCMAT does not have an industry standard for those programs. 1-to-1 Student Support There is no established industry standard for special education paraeducators providing IIS, also known as 1-to-1 paraeducator support. Many LEAs throughout the state have taken steps to remove the designation of 1-to-1 support because it unintentionally reinforces the concept of one adult assigned to one student. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 35 Findings and Recommendations Special Education Paraeducator Staffing Industry practice commonly refers to both the assessment process and the special education paraeducator role as special circumstance instructional assistance (SCIA). The district/county consistently uses an IIS assessment process to determine whether a student requires 1-to-1 paraeducator support. This process clarifies decision-making procedures and recognizes that IIS is a significant program decision that should be based on a thorough, data-driven evaluation that includes con- sidering all less restrictive alternatives. The district/county’s IIS assessment aligns with industry standards because it focuses on personal independence, promotes individual decision-making, works to maximize existing supports, and is based on data-driven assessment. In 2024-25, the district/county has 416.44 FTE one-to-one paraeducators assigned to provide IIS. Although there is no industry standard for comparison, this is high for a district/county of this size compared to what is observed across the state. Causes of the High Number of 1-to-1 Paraeducators Staff explained that many district/county students receive IIS because of increased student support needs following the COVID-19 pandemic, and because of teacher turnover that results in inexperienced teachers who need additional help in certain SDCs. Although the district consistently administers its IIS assess- ment before assigning IIS, staff reported some IEP teams recommend IIS for a student even though the IIS assessment does not demonstrate that need. Some staff expressed that the district/county’s paraeducator allocations to SDCs are rigid and not responsive enough to students’ needs; therefore, some IEP teams will add IIS to a student’s IEP to ensure that the class is assigned a 1-to-1 paraeducator for that student, regard- less of whether the student meets the IIS assessment criteria. Staff also stated that if a student who has a 1-to-1 paraeducator changes schools, the 1-to-1 paraeducator may remain at the student’s former school, and the student’s new school may be assigned an additional 1-to-1 paraeducator for the student. Consequences of High 1-to-1 Paraeducator Staffing As previously mentioned, assigning more paraeducator support than necessary is costly. In addition, although a parent/guardian or staff member’s request for a student to have a 1-to-1 paraeducator may be well meaning, according to the University of Colorado at Denver’s Paraprofessional Resources and Research Center, it can negatively affect the student’s education in the following ways: • The paraeducator may become the student’s primary service provider, and the teacher’s involvement and interactions with the student may be limited. The University of Colorado at Denver’s Paraprofessional Resources and Research Center cautions, “This practice is further exacerbated when paraeducators are not qualified and or trained. It is not in the best interest of the students with most complex needs to be taught by the least qualified staff member.” • The paraeducator’s constant presence may cause the student to become overly dependent on that adult to do things they could otherwise do independently. • The paraeducator may create social barriers between the student they are supporting and the student’s peers. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 36 Findings and Recommendations Special Education Paraeducator Staffing Best Practices in 1-to-1 Paraeducator Assignment In addition to using an assessment to determine whether a student requires a 1-to-1 paraeducator, LEAs should also identify when during the school day a student requires a 1-to-1 paraeducator and assign this only for those times. Form H of the district/county’s IIS assessment, titled, “Referral for Intensive Individual Services School Day Analysis,” could be used to determine which parts of the school day a student requires support (e.g., for mathematics or during recess). This is an alternative to assigning a student a 1-to-1 paraed- ucator for the entire school day, which is only necessary for some students. If staff use a modified version of Form H for this purpose, a 1-to-1 paraeducator could be shared by more than one student at a school. This could reduce the number of 1-to-1 paraeducators needed and the associated costs, as well as reduce a student’s dependence on 1-to-1 paraeducator support and help a student transition to independence over time. Staff recognized that Form H could be used for this purpose, but the district/county reported that it does not consistently use Form H to determine whether 1-to-1 paraeducators could support more than one student at a school. Part of the IIS assessment process focuses on planning for a student’s transition to independence and developing annual IEP goals to support this. Staff reported that they do not consistently write goals for independence or plans to reduce a student’s reliance on 1-to-1 special education paraeducator support when adding IIS support to a student’s IEP. Doing so would be a good practice because it focuses IEP services on addressing deficit areas to strengthen skills, allows the student’s IEP team to monitor annual progress, and helps them determine whether adjustments to the level of service are needed. It would also help the IEP team move away from the concept of assigning one adult to one student, which would enable the district/county to assign one special education paraeducator to more than one students when appro- priate. Staff identified resistance from parents as the main barrier to reducing or removing IIS, regardless of whether this support is necessary or beneficial to the student. Recommendations The district/county should: 1. Begin using adult-to-student ratios to help determine the assignment of special education paraeducators to SDCs. 2. Begin tracking which paraeducators are assigned to which SDCs at a school. 3. Regularly monitor and evaluate whether schools are consistently assigning 1-to-1 special education paraeducator support based on IIS assessment results. 4. Consistently use Form H of its IIS assessment to determine when during the school day a student requires 1-to-1 special education paraeducator support, and assign 1-to-1 paraeducator support accordingly. 5. Use IIS assessment results to determine whether one paraeducator can provide 1-to-1 support to more than one student at a school. 6. Ensure that each IEP that calls for IIS, except for medically necessary support, includes goals for independence and a support phase-out plan that is actively monitored. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 37 Findings and Recommendations Related Service Provider Staffing and Caseloads Related Service Provider Staffing and Caseloads Related services are the developmental, corrective and other services required to help a child with a dis- ability benefit from special education (34 CFR 300.34). These services are written into students’ IEPs and include but are not limited to physical therapy, speech and language therapy, and occupational therapy. FCMAT analyzed staffing ratios for the district/county’s adapted physical education (APE) teachers, occu- pational therapists, physical therapists, school nurses, school psychologists, and speech and language pathologists (SLPs). Staffing ratios for other related service providers were not analyzed because there is no established industry standard for them. The industry standards for related service providers are shown in Table 20 below. Table 20: Industry-Standard Provider-to-Student Ratios Industry-Standard or Education Code Provider Type Provider-to-Student Ratio Psychologist 1-to-977 SLP (preschool) 1-to-40 SLP (ages 5-22) 1-to-55 APE Teacher 1-to-45-55 Physical Therapist 1-to-45-55 Occupational Therapist 1-to-45-55 Vision and Orientation and Mobility 1-to-10-30 Deaf and Hard of Hearing 1-to-15-25 Nurse 1-to-2,274 Sources: Industry standards, Education Code 56363.3, and Pupil Services Staff by Type (CDE). Adapted Physical Education Article 9.5.7.1 of the district/county’s contract with UESF states that the caseload size for APE teachers is 45-55 students, which matches the industry standard. In 2024-25, the district/county has 5.0 FTE APE teacher positions with a combined total caseload of 50 students receiving direct services, as shown in Table 21 below. This is 4.0 FTE APE teacher positions above the average industry standard provider-to-student ratio. All APE teachers are district/county employees. Table 21: District/County Adapted Physical Education Teacher Staffing, 2024-25 District/County and Industry- 2024-25 Standard Staffing Number Total Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-) Provider of FTE Caseload Average Student Ratio Industry Standard Industry Standard APE 1.11 FTE (to meet 1-to-45) +3.89 FTE (above 1-to-45) 5.0 50.0 10.0 1-to-45-55 Teacher 0.90 FTE (to meet 1-to-55) +4.09 FTE (above 1-to-55) Fiscal Crisis and Management Assistance Team San Francisco Unified School District 38 Findings and Recommendations Related Service Provider Staffing and Caseloads Sources: District/county-provided data and industry standards. Note: Only students receiving direct services from the district/county’s APE teachers were included in the total caseload and related calculations. As shown in the table, the district has approximately five times the industry-standard staffing levels for APE teachers. Staff reported that each district/county APE teacher serves students at several schools, and that significant travel time between schools increases the number of APE teachers needed. The district/county needs to review APE teacher caseload projections, assessment loads, the number of schools each APE teacher supports, driving times between schools, direct and consultation service minutes, and students’ needs to determine if it can reduce the number of APE teachers and continue to meet students’ needs. Credentialed School Nurses In 2024-25, the district/county has 68.30 FTE credentialed school nurse positions. At the time of FCMAT’s fieldwork, 49.80 FTE of these positions were filled, and each filled position serves an average caseload of 1,122.89 students, as shown in Table 22 below. This is 25.21 FTE credentialed school nurse positions more than the average industry-standard provider-to-student ratio. Table 22: District/County Credentialed School Nurse Staffing, 2024-25 Number Industry- of FTE 2023 Standard Staffing of Filled Census Day Caseload Provider-to- FTE Needed to Meet Above (+) or Below (-) Provider Positions Enrollment Average Student Ratio Industry Standard Industry Standard School 49.80 55,920 1,122.89 1-to-2,274 24.59 FTE +25.21 FTE Nurse Sources: Pupil Services Staff by Type (CDE), district/county-provided data, and Enrollment for Charter and Non-Charter Schools - San Francisco Unified and San Francisco County Office of Education (CDE). As shown in the table, the district/county has double the industry-standard staffing levels for credentialed school nurses. In addition to having 25.21 FTE more nurses working than the industry standard, the district/ county has another 18.50 FTE credentialed school nurse positions that were not filled at the time of field- work, which means it has 43.71 FTE more credentialed school nurse positions than the industry standard. The district/county needs to review its enrollment, special education enrollment, duties performed by credentialed school nurses, schoolwide needs, and students’ needs to determine how much it can reduce credentialed school nurse staffing. Most LEAs use a combination of credentialed school nurses and licensed vocational nurses (LVNs) to meet students’ needs; however, the district/county reported having only 0.85 FTE LVNs. When analyzing creden- tialed school nurse duties and evaluating staffing reductions, the district/county needs to evaluate whether certain duties being performed by a credentialed school nurse could instead be performed by an LVN. Occupational Therapy In 2024-25, the district/county has 39.7 FTE occupational therapist positions, each with an average case- load of 27.63 students receiving direct services, as shown in Table 23 below. This is 17.76 FTE occupational therapist positions more than the average industry-standard provider-to-student ratio. In addition, the district/county has 6.0 FTE certified occupational therapy assistants (COTAs) and a 1.0 FTE licensed occu- pational therapy assistant, who were not included in this analysis because they act in a support role and cannot perform all the duties of an occupational therapist. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 39 Findings and Recommendations Related Service Provider Staffing and Caseloads Table 23: District/County Occupational Therapist Staffing, 2024-25 Industry Standard Staffing Number 2024-25 Total Caseload Provider-to-Student Above (+) or Below (-) Provider of FTE Caseload Average Ratio Industry Standard +15.32 FTE (above 1-to-45) Occupational Therapist 39.7 1,097 27.63 1-to-45-55 +19.75 FTE (above 1-to-55) Sources: District/county-provided data and industry standards. Notes: Only students receiving direct services from the district/county’s occupational therapists were included in the total caseload and related calculations. The district/county’s 6.0 FTE COTAs and 1.0 FTE licensed occupational therapy assistant were not included in this analysis. As shown in the table, the district/county more than double the industry-standard staffing levels for occu- pational therapists. Staff reported that travel time between district/county schools influences the number of occupational therapists needed. However, the district/county does not recognize that it is staffed sig- nificantly higher than the industry standard. The district/county needs to review occupational therapist caseload projections, assessment loads, the number of schools each occupational therapist serves, driving time between schools, direct and consultation service minutes, and students’ needs to determine if it can reduce the number of occupational therapists and continue to meet students’ needs. In addition to being staffed significantly above the industry standard for occupational therapists, only 2.0 FTE of district/county occupational therapist positions are filled with district/county employees in 2024- 25; the other 37.9 FTE are filled through contracts with nonpublic agencies (NPAs). Because NPA staff are typically more expensive than district/county staff, the district/county could probably reduce occupational therapist costs if it hired its own employees. FCMAT estimated the annual cost for an occupational therapist contracted through an NPA, as shown in Table 24 below. FCMAT projected costs based on three different numbers of days worked per year: • 184 days – This is a typical school year of 180 days with four days added for professional development and/or preparation. • 204 days – This is a typical school year of 180 days with four days added for professional development and/or preparation and 20 days added for extended school year. • 251 days – This is the number of days district/county-employed occupational therapists were reported to work currently, which is not aligned with what is observed across the state. Table 24: Estimated NPA Cost for an Occupational Therapist, 2024-25 Hourly Rate Hours Per Day Daily Rate Total Cost 184 Workdays $110.00 7 $770.00 $141,680 204 Workdays $110.00 7 $770.00 $157,080 251 Workdays $110.00 7 $770.00 $193,270 Sources: District/county-provided data. Note: FCMAT reviewed district/county master contracts with NPAs and determined that NPA hourly rates for occupational therapists varied from $80 to $150 per hour; however, the most common rate stated was a from $105 to $115 per hour. Therefore, FCMAT used an average rate of $110.00 per hour for its estimate. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 40 Findings and Recommendations Related Service Provider Staffing and Caseloads For comparison, the total cost for an occupational therapist who is a district/county employee is shown in Table 25 below. The district/county reported that a district/county employee occupational therapist works 251 days per year. This is far more than is commonly observed across the state. Typically, occupational therapists work approximately 184 days, or approximately 204 days if they serve students in an extended school year program. Total costs for 184, 204 and 251 workdays are included in Table 25. Table 25: District/County Cost for a District/County Employee Occupational Therapist, 2024-25 Daily Benefits Health Benefits Rate Salary Rate Benefits Cost Cost Total Cost 184 Workdays $503.62 $92,666.08 35.62% $33,007.66 $12,800 $138,473.74 204 Workdays $503.62 $102,738.48 35.62% $36,595.45 $12,800 $152,133.93 251 Workdays $503.62 $126,408.62 35.62% $45,026.75 $12,800 $184,235.37 Source: District/county-provided data. FCMAT’s calculated cost for a district/county-employed occupational therapist is lower than its estimated cost of an occupational therapist contracted through an NPA. The cost saving was estimated to be from approximately $3,206 to $9,035 annually per occupational therapist, depending on the number of work- days, which means the possible cost savings compared to the 37.9 FTE occupational therapists employed through an NPA would be significant. The district/county reported that it has not attempted to recruit and hire its own occupational therapists in many years because managers are concerned that they would not be able to hire the staff they want because the City and County of San Francisco also employ occupational therapists who are in the same union and come with the same contract as those the district employs. The district/county would thus have to take these factors into consideration when hiring. However, by not seeking a pool of potential employees or attempting to hire its own employees, the district/county is increasing its costs for occupational thera- pists. In addition to being more cost effective, hiring its own employees would give the district/county more control over the management of its occupational therapists. The district/county also needs to review the number of workdays for occupational therapists to determine if it can create a district/county occupational therapist position that is aligned with the industry-standard 184 or 204 workdays rather than the current 251 workdays, which would significantly reduce costs. Physical Therapy In 2024-25, the district/county has 12.3 FTE physical therapist positions, each with an average caseload of 20.41 students receiving direct services, as shown in Table 26 below. This is 7.28 FTE physical therapist positions more than the average industry-standard provider-to-student ratio. Table 26: District/County’s Physical Therapist Staffing, 2024-25 Industry-Standard Staffing Number 2024-25 Total Caseload Provider-to-Student Above (+) or Below (-) Provider of FTE Caseload Average Ratio Industry Standard +6.72 FTE (above 1-to-45) Physical Therapist 12.3 251.0 20.41 1-to-45-55 +7.74 FTE (above 1-to-55) Sources: District/county-provided data and industry standards. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 41 Findings and Recommendations Related Service Provider Staffing and Caseloads Note: Only students receiving direct services from the district/county’s physical therapists were included in the total caseload and related calculations. As shown in the table, the district/county has almost double the industry-standard staffing levels for physi- cal therapists. Staff reported that travel time between district/county schools increases the number of phys- ical therapists needed. However, the district/county does not recognize that its physical therapist staffing is far higher than the industry standard. The district/county needs to review physical therapist caseload pro- jections, assessment loads, the number of schools each physical therapist supports, driving time between schools, direct and consultation service minutes, and students’ needs to determine if it can reduce the number of physical therapists and continue to meet students’ needs. In addition to being staffed significantly above the industry standard for physical therapists, in 2024-25 only 1.0 FTE of the physical therapist positions is filled with a district/county employee; the other 11.3 FTE were filled through contracts with NPAs. FCMAT estimated an annual cost for physical therapists contracted through an NPA, as shown in Table 27 below. As with occupational therapists, FCMAT determined costs for 184, 204, and 251 days worked per year. Table 27: Estimated NPA Cost for a Physical Therapist, 2024-25 Hourly Rate Hours Per Day Daily Rate Total Cost 184 Workdays $106.00 7 $742.00 $136,528 204 Workdays $106.00 7 $742.00 $151,368 251 Workdays $106.00 7 $742.00 $186,242 Sources: District/county-provided data. Note: FCMAT reviewed district/county master contracts with NPAs and determined that NPA hourly rates for physical therapists varied from $93 to $150 per hour; however, the most common rate stated was from $100 to $112 per hour. Therefore, FCMAT used an average rate of $106.00 per hour for its estimate. For comparison, the total cost for a physical therapist who is a district/county employee is shown in Table 28 below. The district/county reported that a physical therapist who is a district/county employee works 251 days per year. This is far more than what is observed across the state. Typically, physical therapists work approximately 184 days, or approximately 204 days if they serve students in an extended school year pro- gram. Table 28 includes total costs for 184, 204 and 251 workdays per year. Table 28: District/County Cost for a Physical Therapist, 2024-25 Daily Benefits Health Benefits Rate Salary Rate Benefits Cost Cost Total Cost 184 Workdays $493.23 $90,754.32 35.62% $32,326.69 $12,800 $135,881.01 204 Workdays $493.23 $100,618.92 35.62% $35,840.46 $12,800 $149,259.38 251 Workdays $493.23 $123,800.73 35.62% $44,097.82 $12,800 $180,698.55 Sources: District/county-provided data. FCMAT’s calculated cost for a district/county-employed physical therapist is lower than its estimated cost of a physical therapist contracted through an NPA. The annual cost savings was estimated to be from approx- Fiscal Crisis and Management Assistance Team San Francisco Unified School District 42 Findings and Recommendations Related Service Provider Staffing and Caseloads imately $647 to $5,543 per physical therapist, depending on the number of workdays. The possible cost savings of using district/county-employed staff for the 11.3 FTE physical therapists currently filled through an NPA is significant. As with occupational therapists, the district/county reported it has not attempted to recruit and hire its own physical therapists in many years because managers are concerned that they would not be able to hire the staff they want, because the City and County of San Francisco also employe physical therapists who are in the same union and come with the same contract as those the district employs. The district/county would thus have to take these factors into consideration when hiring. However, by not seeking a pool of potential employees or attempting to hire its own employees, the dis- trict/county is increasing its costs. In addition to being more cost effective, hiring its own employees would give the district/county more control over the management of its physical therapists. The district/county also needs to review the number of workdays for physical therapists to determine if it can create a district/county physical therapist position that is aligned with an industry-standard 184 or 204 workdays rather than the current 251 workdays, which would significantly reduce costs. School Psychologists for School-Age Programs In 2024-25, the district/county has 106.6 FTE school psychologist positions; 76.6 FTE are filled with district/ county employees, and 30.0 FTE are filled through contracts with NPAs. Unlike its practice with occupa- tional therapist and physical therapist positions, staff reported that the district/county annually opens appli- cant pools and hires as many district/county-employed school psychologists as possible. The district/county has 96.8 FTE school psychologists serving school-age programs, each with an average caseload of 577.69 students, as shown in Table 29 below. The district/county’s other 9.8 FTE school psy- chologists serve the preschool program and were not included in this staffing comparison. Table 29: District/County School Psychologist Staffing for School-Age Programs Compared to Industry Standard, 2024-25 Industry- 2023 Standard FTE Needed to Staffing Number of Census Day Caseload Provider-to- Meet Industry Above (+) or Below (-) Provider FTE Enrollment Average Student Ratio Standard Industry Standard School Psychologist 96.80 55,920 577.69 1-to-977 57.24 FTE +39.56 FTE for School-Age Programs Sources: District/county-provided data, Pupil Services Staff by Type (CDE), and Enrollment for Charter and Non-Charter Schools - San Francisco Unified and San Francisco County Office of Education (CDE). Note: The district/county’s 9.8 FTE school psychologists who serve the preschool program were not included in this staffing comparison. As shown in the table, the district/county has almost double the industry-standard staffing levels for school psychologists for school-age programs. Staff reported that school psychologists who serve the school-age program work in the comprehensive role of a school psychologist, which means they provide social-emo- tional and behavioral support, consult with teachers, provide one-to-one counseling, and complete assess- ments. Staff reported that most of these psychologists’ time is spent on initial and triennial psychoeduca- tional assessments. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 43 Findings and Recommendations Related Service Provider Staffing and Caseloads The district/county has expanded its behavioral support team In recent years, and it now includes 22.0 FTE behavior intervention specialists. In addition, the district/county has hired staff who provide educational- ly-related mental health services (ERMHS), including 4.0 FTE registered associate clinical social workers, 4.8 FTE licensed marriage and family therapists, 15.0 FTE associate marriage and family therapists, 2.0 FTE associate professional clinical counselors, and a 1.0 FTE credentialed school counselor. It also contracts with the City and County of San Francisco, which provides additional ERMHS. FCMAT does not have an industry standard for behavioral intervention specialists or staff who provide ERMHS, but the services pro- vided by these staff typically reduce the need for school psychologists. Staff reported that the high number of initial assessments following the COVID-19 pandemic increased the district/county’s need for school psychologists. Article 9.5.10 of the district/county’s contract with UESF states: “Psychologists shall serve a total school population at a ratio of 1:800 students within SFUSD in TK through age 22. This ratio does not include stu- dents in private school, preschool, and ERMHS (Educationally Related Mental Health Services).” This ratio has a lower number of students per provider than the industry-standard 977 students, yet the district aver- ages even fewer students per provider than the ratio in its contract. If the district adhered to the contract ratio, it would have 26.90 FTE fewer school psychologists, as shown in Table 30 below. Table 30: District/County School Psychologist Staffing Compared to Contract Standard, 2024-25 FTE Needed to Staffing 2023 Contract Meet Contract Above (+) or Below Number of Census Day Caseload Provider-to- Provider-to- (-) Contract Staffing Provider FTE Enrollment Average Student Ratio Student Ratio Guideline School Psychologist 96.80 55,920 577.69 1-to-800 69.90 FTE +26.90 FTE for School-age Programs Sources: District/county-provided data, Pupil Services Staff by Type (CDE), and Enrollment for Charter and Non-Charter Schools - San Francisco Unified and San Francisco County Office of Education (CDE). Note: The district/county’s 9.8 FTE school psychologists who serve the preschool program were not included in this staffing comparison. Because it is significantly overstaffed with school psychologists compared to both industry standards and its own contract, it would benefit the district/county to review the following items to help determine how many FTE school psychologist positions it needs and what staffing reductions can be made: • The number of initial psychoeducational assessments in the current school year. • The number of annual and triennial psychoeducational assessments expected next school year. • The number of early reassessments expected next school year • Total student enrollment. • Special education enrollment. • Individual school needs. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 44 Findings and Recommendations Related Service Provider Staffing and Caseloads Speech and Language Pathologists In 2024-25, the district/county has 133.0 FTE speech and language pathologists (SLPs); 90.0 FTE are employed by the district/county, 43.0 FTE are contracted through an NPA. Unlike its practice for occupa- tional therapist and physical therapist positions, staff reported that the district/county annually opens appli- cant pools and hires as many district/county-employed SLPs as possible. Because the district/county did not provide information about the age or grade levels of the 1,123 students served by the 43.0 FTE SLPs employed by an NPA, the analysis below is limited to the 90.0 FTE district/ county-employed SLPs and the 3,002 students for whom they provide direct services. District/County-Employed Speech and Language Pathologists Serving the Preschool Program Education Code 56441.7(a) and Article 9.5.7.5 of the district/county’s contract with UESF establish a maxi- mum caseload of 40 students for SLPs serving preschool students. In 2024-25, the district/county has 15.8 FTE district/county-employed SLPs who work exclusively with preschool age students; 4.0 FTE of these SLPs only administer assessments and do not have a caseload, so were excluded from this analysis. The remaining 11.8 FTE district/county-employed SLPs working exclu- sively with preschool age students each have an average caseload of 18.98 students receiving a direct service, as shown in Table 31 below. Table 31: District/County Employed Preschool Speech and Language Pathologist Staffing, 2024-25 Contract and FTE Needed to Staffing Above (+) or Education Meet Contract Below (-) Contract 2024-25 Code Standard and Education and Education Code Number of Total Caseload Provider-to- Code Provider- Standard Provider-to- Provider FTE Caseload Average Student Ratio to-Student Ratio Student Ratio District/County Employed SLPs for 11.8 224 18.98 1-to-40 5.6 FTE +6.20 FTE Preschool Sources: District/county-provided data and EC 56441.7(a). Note: Only preschool-age students receiving direct services from a district/county employed SLP were included in the caseload average for comparison with the EC 56441.7(a) maximum. The district/county’s 4.0 FTE district/county-employed SLPs who administer preschool assessments and do not have a caseload were not included in this staffing comparison. As shown in the table, the district/county has more than double the industry-standard staffing levels for district/county employed SLPs for preschool. District/County-Employed Speech and Language Pathologists Serving School-Age Students Education Code 56363.3 and Article 9.5.7.4 of the district/county’s contract with UESF establish a maxi- mum caseload of 55 students and 45 students, respectively, for SLPs serving students ages 5-22. In 2024-25, the district/county has 56.4 FTE district/county-employed SLPs working exclusively with school-age students; 1.0 FTE of these SLPs supported only students in private/parochial schools, so was Fiscal Crisis and Management Assistance Team San Francisco Unified School District 45 Findings and Recommendations Related Service Provider Staffing and Caseloads excluded from this analysis. The remaining 55.4 FTE district/county-employed SLPs each managed an aver- age caseload of 38.00 students receiving a direct service, as shown in Table 32 below. Table 32: District/County-Employed School Age Speech and Language Pathologist Staffing, 2024-25 Education FTE Needed to Meet Staffing 2024-25 Code Standard Education Code Above (+) or Below Number Total Caseload Provider-to- Provider-to-Student (-) Education Code Provider of FTE Caseload Average Student Ratio Ratio Maximum District/County- Employed SLPs 55.4 2,105 38.00 1-to-55 38.27 +17.13 FTE — School-Age Sources: District/county-provided data and EC 56363.3. Notes: Only students receiving direct services from a district/county-employed SLP who serves only school-age students were included in the caseload average for comparison with the EC 56363.3 maximum. The district/county’s 1.0 FTE district/county-employed SLP who serves only students in private/parochial schools was not included in this staffing comparison. As shown in the table, the district/county has approximately one and a half times the industry-standard staffing levels for district/county employed SLPs for school-age programs. District/County-Employed Speech and Language Pathologists Serving Preschool and School-Age Students In 2024-25, the district/county has 17.8 FTE district/county-employed SLPs who serve both preschool and school-age students, each with an average caseload of 37.81 students who received a direct service, as shown in Table 33 below. Table 33: District/County-Employed Preschool and School-Age Averaged Speech and Language Pathologist Staffing, 2024-25 EC 56363.3 and 56441.7(a) FTE Needed to Meet Staffing Blended* EC 56363.3 and Above (+) or Below 2024-25 Minimum 56441.7(a) Combined (-) EC 56363.3 and Number Total Caseload Provider-to- Average Caseload 56441.7(a) Blended Provider of FTE Caseload Average Student Ratio Maximum Maximum District/County- Employed SLPs 17.8 673 37.81 1-to-47.5 14.17 +3.63 FTE —Preschool and School Age Sources: District/county-provided data, EC 56441.7(a) and EC 56363.3. Note: Only students who receive direct services from a district/county-employed SLP who serves both preschool and school-age students were included in the caseload average for comparison with the average of the caseload maximums specified in EC 56441.7(a) and EC 56363.3. *The blended minimum staffing ratio was calculated by averaging the statutory preschool and school-age caseload maximums. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 46 Findings and Recommendations Related Service Provider Staffing and Caseloads Summary of District/County-Employed Speech and Language Pathologist Staffing In 2024-25, the district/county’s staffing for district/county-employed SLPs is as follows: • Preschool – 6.20 FTE more than what is needed to meet the EC 56441.7(a) caseload maximum. • School-Age – 17.13 FTE more than what was needed to meet the EC 56363.3 caseload maximum. • Preschool and School Age – 3.63 FTE more than what was needed to meet the EC 56441.7(a) and EC 56363.3 averaged maximum. Collectively, district/county staffing for employed SLPs is 26.96 FTE more than what is needed to meet EC caseload maximums. Staff indicated that increased student needs following the COVID-19 pandemic and a higher than usual number of speech and language initial assessments necessitated an increase in the district/county’s SLP staffing. As with other related service providers, the district/county does not recognize that it is staffed significantly higher than needed to meet the Education Code standard. The district/county needs to review SLP caseload projections and students’ needs to determine if it can reduce SLP staffing while continuing to meet students’ needs. Recommendations The district/county should: 1. Evaluate whether it can reduce its staffing for adapted physical education teachers, credentialed school nurses, occupational therapists, physical therapists, school psychologists, and SLPs to align with industry standards while still meeting students’ needs. 2. Continue to open applicant pools annually to recruit and fill as many school psychologist and SLP positions as possible with district/county employees. 3. Evaluate the number of days physical therapists and occupational therapists employed in district/county positions work, and determine if it can reduce those days to align with industry standards while still meeting students’ needs. 4. Begin opening applicant pools for occupational therapists and physical therapists to increase the number of district/county-employed staff in these positions. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 47 Findings and Recommendations Unrestricted General Fund Contribution to Special Education Unrestricted General Fund Contribution to Special Education Fiscal Background California’s special education funding structure was established by and is commonly referred to as Assembly Bill (AB) 602, which was introduced and signed into law in 1997 and became effective during the 1998-99 fiscal year. Under AB 602, special education funding is based on the average daily attendance (ADA) of all students in a school district, regardless of the number of students served in special education programs or the cost to serve them. California distributes special education funds to SELPAs based on their member districts’ total ADA counts. In addition to AB 602 state funding, districts receive a small amount of federal funds. These funds are designed to supplement the general education program, not to support a standalone program. The combined state and federal funds are insufficient to pay for even the most efficient special education programs. Districts make contributions to special education from local resources generated by all students, including those in special education. These contributions are the amount of funding districts must transfer from their unrestricted general funds to pay for the portion of special education costs that exceeds program revenues. Federal law requires districts to spend at least the same amount of state and local funds on special edu- cation services in each successive year. This is commonly referred to as the maintenance of effort (MOE). There are limited exceptions to this requirement, and if a district is considering reductions to its total gen- eral fund contribution to special education, it is required to follow the guidelines in the MOE document (20 USC 1413 (a)(2)(B)). The IDEA lists the following circumstances as exceptions that allow a district to reduce the amount of state and local funds it spends on special education: i. Voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel; ii. A decrease in the enrollment of children with disabilities; iii. The termination of the obligation of the agency to provide a program of special education to a particular child with a disability that is an exceptionally costly program, as determined by the state educational agency, because the child: a. Has left the jurisdiction of the agency; b. Has reached the age at which the obligation of the agency to provide free and appropriate public education (FAPE) to the child has terminated; or c. No longer needs the program of special education; or iv. The termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the construction of school facilities. The year-end expenditures charged to special education goal codes in the Standardized Account Code Structure (SACS), which is the state’s financial reporting format, are used to calculate special education MOE. If special education savings are included in the district’s fiscal recovery plan, the MOE requirement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 48 Findings and Recommendations Unrestricted General Fund Contribution to Special Education must be taken into consideration. Districts need to monitor their MOE throughout the year and analyze fore- casts of MOE calculations at first and second interim financial reporting periods. Districts should be mindful of what expenses are charged to special education SACS goal codes, including for non-special education SACS resource codes, because those may increase the MOE. In addition, districts should monitor reduc- tions in expenditures to determine if any meet one of the exceptions that may allow the district to reduce the amount of state and local funds it spends on special education. Building Comparable Data Resource codes in the SACS are used to identify revenues and expenditures that have specific accounting or reporting requirements or that are legally restricted. Special education SACS resource codes are used to record special education spending and therefore contain vital information about a district’s unrestricted general fund contribution to its special education program. The special education financial reporting methods used by districts, county offices of education and SELPAs can vary. For example, the San Francisco Unified School District and county office include legal/ settlement and transportation costs in this reporting, while other districts and county offices exclude them. There are also differences in how special education funds are allocated by SELPAs. Because of these dif- ferences, it is not always possible to accurately compare a district’s unrestricted general fund contribution to those of other districts. However, a district should evaluate a contribution that is excessive compared to other districts or that is increasing disproportionately compared to other costs. To calculate an unrestricted general fund contribution amount that can be compared year to year and includes expenditures most districts classify as special education, FCMAT made the following adjustments to the district/county’s SACS data: • FCMAT combined special education income and expenses from the district and county office of education to account for a large difference in the amount of income and expenses held at the county level versus those passed on to the district during the review period. For example, students attending an NPS were typically reported to CALPADS as county office of education students, but the ADA income and expenditures for those students were reported as district revenue and expenses. • To improve multiyear continuity, FCMAT used only ongoing special education income. FCMAT removed one-time funding totaling $4,855,574 in 2021-22, $3,328,726 in 2022-23, and $24,748 in 2023-24. It appears that special education expenditures charged to these one-time state and federal income sources were ongoing and were budgeted by the dis- trict/county as such beginning in 2024-25. • FCMAT used only special education expenses in the comparison. During the review period, the district charged some non-special education expenditures to special education SACS resource codes. These non-special education expenses increased significantly in the 2024- 25 budget, which budgeted $597,762 in non-special education expenses to special edu- cation resources. To ensure that the unrestricted general fund contributions analyzed are attributed solely to special education services, FCMAT excluded these non-special educa- tion expenses in the 2024-25 budget from its calculation. • The district included in its MOE the impact of special education expenses charged to one- time non-special education SACS resource codes. Because these expenses were made from non-special education one-time revenue sources, they did not require a district con- Fiscal Crisis and Management Assistance Team San Francisco Unified School District 49 Findings and Recommendations Unrestricted General Fund Contribution to Special Education tribution. These one-time revenues caused large one-time reductions in the unrestricted general fund contribution to special education and included the following: • Elementary and Secondary School Emergency Relief Fund (ESSER). • The Arts, Music and Instructional Materials block grant. • Community Schools Partnership Program funds and the Extended Learning Opportunities Program grant. • In-Person Instruction grant. • Learning Loss Mitigation funding. • A-G Completion Improvement grant program funds. • County Safe Schools for All funds. FCMAT added the following amounts back for comparison purposes: $7.2 million in 2020- 21, $34.9 million in 2021-22, $2.6 million in 2022-23 and $1.8 million in 2023-24. The impact of the one-time funding on the unrestricted general fund contribution dropped to $0.3 million in the 2024-25 budget as these funds were exhausted. • Full indirect costs have not been charged to all special education programs using the CDE’s approved rates for all the comparison years. In 2021-22, 2022-23, 2023-24, the dis- trict/county charged full indirect costs to all special education grant programs. The district/ county used an indirect cost rate of 4.49% in its 2024-25 adopted budget and multiyear fiscal projections The best practice is to charge the full indirect rate to all programs, includ- ing those with special education SACS resource codes, so that the true cost of the special education program can be determined. For continuity of data, FCMAT charged the full indi- rect cost rate to all special education programs for all the comparison years. Even with these adjustments, the district/county’s general fund contribution trend does not directly cor- relate to its increases in total special education expenditures or special education MOE. This is because of the following: • Expenditures with special education SACS goal codes have been charged inconsistently to non-special education SACS resource codes. FCMAT assumed that these expenses will continue to be charged to the same non-special education resources that they were bud- geted to in 2024-25. These resources mainly include the following: the unrestricted general fund, Extended Learning Opportunities Program, Elementary and Secondary Education Act (ESEA) Title I, ESEA Schoolwide funds, and other local income. FCMAT estimates the impact of this to be a decrease in the unrestricted general fund contribution of $9.4 million in 2020-21, $21.8 million in 2021-22, $37.4 million in 2022-23, $42.7 million in 2023-24, and a projected $33.1 million in 2024-25. • Transportation expenses are included in total special education expenditures for MOE purposes but are reported separately in Table 34 below. This is because transportation income is not reported since the California School Accounting Manual has not developed a method to match the income with the expense. For 2024-25, the district/county’s transpor- tation expenses will increase its special education MOE by $36.9 million. However, the esti- mated $16.4 million in special education transportation income for 2024-25 is not credited to the SACS special education goal code. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 50 Findings and Recommendations Unrestricted General Fund Contribution to Special Education District/County Special Education Expenses FCMAT analyzed the district/county’s special education income and expenditures, using only ongo- ing income from fiscal years 2021-22 to 2024-25 (one-time 2021-22, 2022-23 and 2023-24 income was excluded), as shown in Table 34 below. Table 34: Comparison of Special Education Expenses Using Ongoing Income Only, 2021-22 through 2024-25 Average Historical Historical Historical Projected Historical Category 2021-22 2022-23 2023-24 2024-25 Annual Rate Increase/Decrease in Special Education -8.26% 6.10% 3.06% N/A N/A Students Increase in Ongoing Income 6.88% 7.55% 8.55% 3.35% 2.96% Increase in Certificated Salaries -0.96% 2.21% 13.54% 5.8% 4.98% Increase/Decrease in Classified Salaries -1.28% -2.16% 33.39% 5.75% 9.62% Increase/Decrease in Benefits -0.08% 2.95% 13.68% 19.22% 5.65% Increase/Decrease in Books and Supplies 38.38% 12.94% 11.19% -44.05% 24.59% Increase/Decrease in Services (Excluding 4.59% 37.57% 36.45% -55.8% 32.11% Transportation) Increase in Transportation 402.31% 4.15% 11.34% 20.10% 160.83% Tuition Excess Costs/Indirect -6.90% 48.96% -41.56% 166.10% -32.67% Costs Increase/Decrease in Adjusted General Fund 18.87% 21.23% 14.83% -9.90% -9.90% Contribution Adjusted Dollar Amount of General Fund $144,479,963 $155,582,066 $196,336,787 $172,728,735 N/A Contribution Adjusted Dollar Amount of Special Education $211,676,217 $226,856,553 $269,595,447 $242,097,866 N/A Expenses Sources: Official SACS unaudited actuals. 2024-25 data was projected using SACS first interim actual year-to-date expenses extrapolated using 2023-24 SACS first interim-to-unaudited actual ratios, base 2023-24 salaries and benefits and settlements, and both district and county office of education expenses charged to special education SACS goal codes. Notes: Official SACS unaudited actuals and 2024-25 income and general fund contribution data were reduced by one-time income in 2020-21, 2021-22, 2022-23, and 2023-24, and expenses were adjusted to include full indirect costs. Ongoing costs charged to non-special education resources are included in the total cost of the program but do not have a fiscal impact on the district/county contribution. Amounts and percentages in the “Increase in Ongoing Income,” “Increase/Decrease in Adjusted General Fund Contribution,” and “Adjusted Dollar Amount of General Fund Contribution” categories were adjusted to exclude expenses charged to non-special education ongoing income, and to add full indirect costs for any year the district/county did not charge it. The “Adjusted Dollar Amount of Special Education Expenses” category was adjusted to match footnoted entries in the district/county’s budget. The average increase in ongoing special education funding over the last four years has been 2.96% per year. All district/county employee group salaries increased more than funding from 2020-21 through 2023- 24. In addition to all negotiated salary increases, there were average annual expenditure increases of more than 59% in other paraeducator positions and/or services, 41.5% in certificated management positions, and 6.2% in classified management positions. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 51 Findings and Recommendations Unrestricted General Fund Contribution to Special Education In 2023-24, special education enrollment increased by 3.06% and income increased by 8.55%, but expenses increased more than the income. Expenses increased in all categories in 2023-24, including large increases in employee salaries. The cost of services increased by 36.45% that year. Staff reported that the number of students attending an NPS has been historically underreported to CALPADS, and the district/county has not conducted a cost-per-student analysis, which is required to identify and support the annual filing for extraordinary cost pool reimbursement for NPS/LCI and mental health services under EC 56836.21. The Special Education Extraordinary Cost Pool for NPS/LCI is ongoing state funding that was increased by almost 700% in 2022-23. Staff reported that the district/county has not submitted extraor- dinary cost pool claims in recent years because of multiple transitions among staff who would have com- pleted this task. However, the district/county did submit an extraordinary cost pool claim to the CDE for 2023-24. In 2023-24, the district/county’s average annual cost for a student to attend an NPS was $75,594. The total cost of NPA/NPS expenses per student for all identified special education students has increased from $4,362 in 2021-22 to $7,644 in 2023-24. This is an increase of 75.24% even though the ADA generated by NPS students appears relatively unchanged over that review period. An analysis of the services detail shows that legal fee and settlement costs decreased by 52% from 2022- 23 through 2023-24. Thus, the increase in service costs was probably not driven by one-time expenditures. Transportation costs continue to increase but at a slower rate than the costs for other services. The district/county’s 2024-25 first interim budget for services, after accounting for estimated NPS and transportation expenses, has only $2.4 million in budgeted funding to cover other contracted services, including legal fees, settlements and NPA expenses. It is essential that the district/county properly identify and track transportation costs and expenses for students attending an NPS so that budgeting and decision making can be based on historical data. District/County Unrestricted General Fund Contribution The district/county’s adjusted unrestricted general fund contributions, including expenditures for increased indirect costs and increases or reductions for one-time income and redirected income, are shown in Table 35 below. Table 35: District/County’s Adjusted Unrestricted General Fund Contributions to Special Education, 2020-21 through 2023-24 Category 2020-21 2021-22 2022-23 2023-24 Adjusted Unrestricted General Fund Contribution $122,443,996 $144,479,963 $155,582,066 $196,336,787 Percentage of Adjusted Special Education Costs 68.68% 70.64% 70.47% 74.45% Sources: Official SACS unaudited actuals data for the district and county office of education. Note: Official SACS unaudited actuals income and unrestricted general fund contribution data were adjusted for one-time income in 2020-21, 2021-22, 2022-23 and 2023-24. They were also adjusted to add expenses for full indirect costs for any year those costs were not charged by the district/county. In 2023-24, the district/county’s unrestricted general fund contribution (adjusted to add full indirect costs to special education program expenditures and to include the impact of one-time income) was 74.45% of adjusted special education costs. The fluctuations in expenses observed in 2020-21 and 2021-22 were associated with declines in expenses during periods when students were generally not in attendance Fiscal Crisis and Management Assistance Team San Francisco Unified School District 52 Findings and Recommendations Unrestricted General Fund Contribution to Special Education because of the COVID-19 pandemic. In 2023-24, the district/county incurred significant employee collective bargaining settlement costs and increased staffing expenses. In 2024-25, the district/county’s unrestricted general fund contribution as a per centage of total special education costs, inclusive of indirect costs, was budgeted significantly lower and is projected to decrease to 73.86% based on first interim actual projections and the district/county budget. Recommendations The district/county should: 1. Continue to monitor its unrestricted general fund contribution to the special education program. 2. Consistently charge full indirect costs to special education programs. 3. Monitor and track transportation and NPS costs, and annually analyze trend data to use for budgeting. 4. Develop a system to track the expenditures for individual students who are attending an NPS so it can determine whether those expenses may qualify for extraordinary cost pool reimbursement. 5. Monitor and track special education expenses charged to non-special education resources so that the full cost of the program can be monitored and MOE can be managed. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 53 Appendices Appendix A — District/County Resource Specialist Staffing by School, 2024-25 Appendices Appendix A — District/County Resource Specialist Staffing by School, 2024-25 Staffing Needed Staffing FTE to Meet RSP Above (+) or Below Total RSP Average Teacher-to- (-) District/County Total RSP Student Teacher Student Ratio of Staffing Guide School Teacher FTE Caseload Caseload 1-to-22 Ratio of 1-to-22 Washington (George) High 10 250 25.00 11.36 -1.36 School (HS) Galileo HS 6 160 26.67 7.27 -1.27 Lakeshore Elementary School 1 49 49.00 2.23 -1.23 (ES) Carmichael (Bessie) 3 90 30.00 4.09 -1.09 K-8 Asawa (Ruth) SOTA 3 89 29.67 4.05 -1.05 HS Mission HS 7 174 24.86 7.91 -0.91 Burton (Phillip and 6 148 24.67 6.73 -0.73 Sala) HS Brown Jr. (Willie) 2 57 28.50 2.59 -0.59 Middle School (MS) Denman (James) MS 4 101 25.25 4.59 -0.59 Lilienthal (Claire) K-8 1 34 34.00 1.55 -0.55 Creative Arts K-8 1.8 51 28.33 2.32 -0.52 Charter McKinley ES 1 33 33.00 1.50 -0.50 Tenderloin 1 33 33.00 1.50 -0.50 Community ES Key (Francis Scott) 1 31 31.00 1.41 -0.41 ES Miraloma ES 1 31 31.00 1.41 -0.41 Muir (John) ES 1 31 31.00 1.41 -0.41 Lincoln (Abraham) 8 185 23.13 8.41 -0.41 HS Rooftop K-8 3 74 24.67 3.36 -0.36 Huerta (Dolores) ES 1 28 28.00 1.27 -0.27 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 54 Appendices Appendix A — District/County Resource Specialist Staffing by School, 2024-25 Staffing Needed Staffing FTE to Meet RSP Above (+) or Below Total RSP Average Teacher-to- (-) District/County Total RSP Student Teacher Student Ratio of Staffing Guide School Teacher FTE Caseload Caseload 1-to-22 Ratio of 1-to-22 Webster (Daniel) ES 1 27 27.00 1.23 -0.23 Ulloa ES 1 26 26.00 1.18 -0.18 Taylor (Edward R) 2 48 24.00 2.18 -0.18 ES Sloat (Commodore) ES, Mission 0.7 19 27.14 0.86 -0.16 Education Center ES Balboa HS 9 201 22.33 9.14 -0.14 Guadalupe ES 1 25 25.00 1.14 -0.14 Alvarado ES 2 46 23.00 2.09 -0.09 Buena Vista Horace 3.5 79 22.57 3.59 -0.09 Mann K-8 Moscone (George 1.5 35 23.33 1.59 -0.09 R) ES West Portal ES 1.5 35 23.33 1.59 -0.09 Wallenberg (Raoul) 5 111 22.20 5.05 -0.05 HS Cobb (Dr William 1 23 23.00 1.05 -0.05 L) ES Longfellow ES 2 45 22.50 2.05 -0.05 Sunnyside ES 1.5 34 22.67 1.55 -0.05 Feinstein (Dianne) 2 44 22.00 2.00 0.00 ES Flynn (Leonard R) 2 42 21.00 1.91 0.09 ES Yu (Alice Fong) K-8 1.5 33 22.00 1.50 0.00 Hillcrest ES 1 21 21.00 0.95 +0.05 Milk (Harvey) Civil 1 21 21.00 0.95 +0.05 Right ES SF Community K-8 1 21 21.00 0.95 +0.05 Chin (John Yehall) 0.5 10 20.00 0.45 +0.05 ES Presidio MS 5 108 21.60 4.91 +0.09 Parker (Jean) ES 0.5 9 18.00 0.41 +0.09 Lau (Gordon J) ES 1 20 20.00 0.91 +0.09 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 55 Appendices Appendix A — District/County Resource Specialist Staffing by School, 2024-25 Staffing Needed Staffing FTE to Meet RSP Above (+) or Below Total RSP Average Teacher-to- (-) District/County Total RSP Student Teacher Student Ratio of Staffing Guide School Teacher FTE Caseload Caseload 1-to-22 Ratio of 1-to-22 Peabody (George) 1 20 20.00 0.91 +0.09 ES Revere (Paul) K-8 1 20 20.00 0.91 +0.09 Redding ES 0.8 15 18.75 0.68 +0.12 Bryant ES 1 19 19.00 0.86 +0.14 McCoppin (Frank) 1 19 19.00 0.86 +0.14 ES Sutro ES 1 19 19.00 0.86 +0.14 Chavez (Cesar) ES 2 41 20.50 1.86 +0.14 Visitacion Valley MS 3 62 20.67 2.82 +0.18 Marshall ES 1 18 18.00 0.82 +0.18 New Traditions ES 1 18 18.00 0.82 +0.18 SAN FRANCISCO PUBLIC 1 18 18.00 0.82 +0.18 MONTESSORI CDC Stevenson (Robert 1 18 18.00 0.82 +0.18 Louis) ES Wo (Yick) ES 1 18 18.00 0.82 +0.18 Sanchez ES 1.5 29 19.33 1.32 +0.18 Alamo ES 1 17 17.00 0.77 +0.23 Argonne ES 1 17 17.00 0.77 +0.23 Clarendon ES 2 39 19.50 1.77 +0.23 Giannini (A.P.) MS 6 127 21.17 5.77 +0.23 Lick (James) MS 5 104 20.80 4.73 +0.27 Lowell HS 4.5 93 20.67 4.23 +0.27 Francisco MS 2 38 19.00 1.73 +0.27 Spring Valley 1 16 16.00 0.73 +0.27 Science ES Lafayette ES 3 60 20.00 2.73 +0.27 Jefferson ES 2 37 18.50 1.68 +0.32 Malcolm X Academy 1 15 15.00 0.68 +0.32 ES Wells (Ida B) HS 1 15 15.00 0.68 +0.32 Glen Park ES 2 36 18.00 1.64 +0.36 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 56 Appendices Appendix A — District/County Resource Specialist Staffing by School, 2024-25 Staffing Needed Staffing FTE to Meet RSP Above (+) or Below Total RSP Average Teacher-to- (-) District/County Total RSP Student Teacher Student Ratio of Staffing Guide School Teacher FTE Caseload Caseload 1-to-22 Ratio of 1-to-22 Monroe ES 2 36 18.00 1.64 +0.36 Serra (Junipero) ES 2 36 18.00 1.64 +0.36 Cleveland ES 1 14 14.00 0.64 +0.36 Sunset ES 1 14 14.00 0.64 +0.36 Drew (Dr Charles) College Preparatory 1 13 13.00 0.59 +0.41 Academy ES Grattan ES 2 35 17.50 1.59 +0.41 El Dorado ES 1 12 12.00 0.55 +0.45 Marina MS 3 56 18.67 2.55 +0.45 Jordan (June) HS 2 33 16.50 1.50 +0.50 Garfield ES 1.5 21 14.00 0.95 +0.55 Gateway MS Charter 6.5 128 19.69 5.82 +0.68 Hilltop HS 1 7 7.00 0.32 +0.68 The Academy - SF 2 29 14.50 1.32 +0.68 @ McAteer HS Youth Chance High 1 7 7.00 0.32 +0.68 School SF International HS 1 6 6.00 0.27 +0.73 Hoover (Herbert) MS 5 94 18.80 4.27 +0.73 C.A.R.E. Buchanan 1 5 5.00 0.23 +0.77 Harte (Bret) ES 2 27 13.50 1.23 +0.77 Lawton K-8 2 26 13.00 1.18 +0.82 Aptos MS 6 114 19.00 5.18 +0.82 Everett MS 3 47 15.67 2.14 +0.86 Sherman ES 3 46 15.33 2.09 +0.91 C.A.R.E. Bayview 1 1 1.00 0.05 +0.95 SF Civic Center 2 23 11.50 1.05 +0.95 Secondary HS King Jr (Dr Martin 4 66 16.50 3.00 +1.00 L) MS Marshall (Thurgood) 3 42 14.00 1.91 +1.09 HS Roosevelt MS 4 63 15.75 2.86 +1.14 Fiscal Crisis and Management Assistance Team San Francisco Unified School District 57 Appendices Appendix A — District/County Resource Specialist Staffing by School, 2024-25 Staffing Needed Staffing FTE to Meet RSP Above (+) or Below Total RSP Average Teacher-to- (-) District/County Total RSP Student Teacher Student Ratio of Staffing Guide School Teacher FTE Caseload Caseload 1-to-22 Ratio of 1-to-22 Independence HS 5 81 16.20 3.68 +1.32 O'Connell (John) HS 6 98 16.33 4.45 +1.55 Downtown HS 3 24 8.00 1.09 +1.91 Sources: District/county-provided allocation data and District/County Special Education School Site Staffing Guide School Year 2024-2025. Note: 8.0 FTE of the RSP teachers assigned to the preschool program and the 72 preschool students they support, and 4.0 FTE of the RSP teach- ers who were not assigned to a school and the 58 students they support were removed for this analysis. The resulting dataset included 236.8 FTE of the district/county’s RSP teachers who managed the cases of 4,884 RSP students. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 58 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Alamo Extensive Aligned with Elementary Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry School (ES) Focus Standard Extensive Aligned with Alamo ES Needs Autism 7 2 3-to-7 or 0.43 1-to-3 or 0.33 Industry Focus Standard 1 Paraeducator Extensive Alvarado ES 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry Needs Standard Aligned with Extensive Alvarado ES 11 2 3-to-11 or 0.27 1-to-5 or 0.20 Industry Needs Standard AP Giannini Mild-to- Aligned with Middle School Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry (MS) Needs Standard Mild-to- Aligned with AP Giannini Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry MS Needs Standard Mild-to- 1 Paraeducator AP Giannini Moderate 12 2 3-to-12 or 0.25 1-to-3 or 0.33 Below Industry MS Needs Autism Standard Focus 1 Paraeducator AP Giannini Extensive 9 2 3-to-9 or 0.33 1-to-5 or 0.20 Above Industry MS Needs Standard Extensive Aligned with AP Giannini Needs Autism 8 2 3-to-8 or 0.38 1-to-3 or 0.33 Industry MS Focus Standard Mild-to- Aligned with Aptos MS Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Aptos MS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 59 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Extensive Aligned with Aptos MS Needs Autism 8 2 3-to-8 or 0.38 1-to-3 or 0.33 Industry Focus Standard Mild-to- 1 Paraeducator Moderate Argonne ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- 1 Paraeducator Moderate Argonne ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Balboa High Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry School (HS) Needs Standard Mild-to- Aligned with Balboa HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Balboa HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Balboa HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard 1 Paraeducator Extensive Balboa HS 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Balboa HS 9 2 3-to-9 or 0.33 1-to-5 or 0.20 Above Industry Needs Standard Buena Vista Mild-to- Aligned with Horace Mann Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry K-8 Needs Standard Buena Vista Mild-to- Aligned with Horace Mann Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry K-8 Needs Standard Mild-to- Aligned with Burton HS Moderate 8 1 2-to-8 or 0.25 1-to-7 or 0.14 Industry Needs Standard 1 Paraeducator Extensive Burton HS 8 2 3-to-8 or 0.38 1-to-5 or 0.20 Above Industry Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 60 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard 1 Paraeducator Extensive Burton HS 9 2 3-to-9 or 0.33 1-to-5 or 0.20 Above Industry Needs Standard Mild-to- Aligned with Clarendon ES Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Clarendon ES Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Denman MS Moderate 15 1 2-to-15 or 0.13 1-to-7 or 0.14 Industry Needs Standard Aligned with Extensive Denman MS 9 1 2-to-9 or 0.22 1-to-5 or 0.20 Industry Needs Standard Mild-to- Aligned with Moderate Denman MS 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry Needs Autism Standard Focus Mild-to- 1 Paraeducator Moderate El Dorado ES 12 2 3-to-12 or 0.25 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Moderate El Dorado ES 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry Needs Autism Standard Focus Mild-to- Aligned with Everett MS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Moderate Everett MS 8 2 3-to-8 or 0.38 1-to-3 or 0.33 Industry Needs Autism Standard Focus Mild-to- Aligned with Francisco MS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Extensive Aligned with Francisco MS Needs Autism 7 2 3-to-7 or 0.43 1-to-3 or 0.33 Industry Focus Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 61 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Mild-to- Aligned with Galileo HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Galileo HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Galileo HS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Mild-to- 1 Paraeducator Moderate Galileo HS 6 2 3-to-6 or 0.50 1-to-3 or 0.33 Above Industry Needs Autism Standard Focus Aligned with Extensive Galileo HS 12 2 3-to-12 or 0.25 1-to-5 or 0.20 Industry Needs Standard Mild-to- 1 Paraeducator Moderate Garfield ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Moderate Garfield ES 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Needs Autism Standard Focus Extensive Aligned with Glen Park ES Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Extensive Aligned with Glen Park ES Needs Autism 9 2 3-to-9 or 0.33 1-to-3 or 0.33 Industry Focus Standard Extensive Aligned with Grattan ES Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Extensive Aligned with Grattan ES Needs Autism 9 2 3-to-9 or 0.33 1-to-3 or 0.33 Industry Focus Standard Mild-to- Aligned with Harte (Bret) ES Moderate 8 1 2-to-8 or 0.25 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Hillcrest ES Moderate 6 1 2-to-6 or 0.33 1-to-7 or 0.14 Industry Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 62 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard 1-3 / Mild- Aligned with Hillcrest ES to-Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard 4-5 / Mild- Aligned with Hillcrest ES to-Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Hoover MS Moderate 14 1 2-to-14 or 0.14 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Moderate Hoover MS 2 1 2-to-2 or 1.00 1-to-3 or 0.33 Industry Needs Autism Standard Focus 1 Paraeducator Huerta Extensive 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry (Dolores) ES Needs Standard 1 Paraeducator Huerta Extensive 6 2 3-to-6 or 0.50 1-to-5 or 0.20 Above Industry (Dolores) ES Needs Standard Mild-to- 1 Paraeducator Moderate Jefferson ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Moderate Jefferson ES 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry Needs Autism Standard Focus Aligned with Industry Mild-to- Standard Since June Jordan Moderate 3 1 2-to-3 or 0.67 1-to-7 or 0.14 Base Staffing Is HS Needs 1 Paraeducator for This Type of Class Mild-to- Aligned with June Jordan Moderate 8 2 3-to-8 or 0.38 1-to-3 or 0.33 Industry HS Needs Autism Standard Focus 1 Paraeducator Key (Francis Extensive 7 2 3-to-7 or 0.43 1-to-5 or 0.20 Above Industry Scott) ES Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 63 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard 1 Paraeducator Key (Francis Extensive 6 2 3-to-6 or 0.50 1-to-5 or 0.20 Above Industry Scott) ES Needs Standard Extensive Aligned with King (Thomas Needs Autism 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry Starr) ES Focus Standard Extensive 1 Paraeducator King (Thomas Needs Autism 6 2 3-to-6 or 0.50 1-to-3 or 0.33 Above Industry Starr) ES Focus Standard Mild-to- 1 Paraeducator Moderate Lakeshore ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Moderate Lakeshore ES 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry Needs Autism Standard Focus Mild-to- 1 Paraeducator Moderate Lakeshore ES 12 2 3-to-12 or 0.25 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus 1 Paraeducator Extensive Lawton K-8 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Lawton K-8 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Lawton K-8 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry Needs Standard Mild-to- Aligned with Lick MS Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lick MS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lincoln HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lincoln HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 64 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Mild-to- Aligned with Lincoln HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lincoln HS Moderate 9 1 2-to-9 or 0.22 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lincoln HS Moderate 8 1 2-to-8 or 0.25 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lincoln HS Moderate 8 1 2-to-8 or 0.25 1-to-7 or 0.14 Industry Needs Standard Aligned with Extensive Lincoln HS 11 1 2-to-11 or 0.18 1-to-5 or 0.20 Industry Needs Standard Mild-to- 1 Paraeducator Moderate Lincoln HS 12 2 3-to-12 or 0.25 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Extensive 1 Paraeducator Lincoln HS Needs Autism 6 2 3-to-6 or 0.50 1-to-3 or 0.33 Above Industry Focus Standard Extensive 1 Paraeducator Lincoln HS Needs Autism 6 2 3-to-6 or 0.50 1-to-3 or 0.33 Above Industry Focus Standard Mild-to- Aligned with Longfellow ES Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Longfellow ES Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lowell HS Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Lowell HS Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Moderate Lowell HS 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Needs Autism Standard Focus Fiscal Crisis and Management Assistance Team San Francisco Unified School District 65 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard 1 Paraeducator Extensive Lowell HS 9 2 3-to-9 or 0.33 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Lowell HS 10 2 3-to-10 or 0.30 1-to-5 or 0.20 Above Industry Needs Standard Extensive Aligned with Lowell HS Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Extensive Aligned with Lowell HS Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Mild-to- Aligned with Marina MS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Moderate Marina MS 8 2 3-to-8 or 0.38 1-to-3 or 0.33 Industry Needs Autism Standard Focus Mild-to- 1 Paraeducator Moderate McKinley ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Moderate McKinley ES 9 2 3-to-9 or 0.33 1-to-3 or 0.33 Industry Needs Autism Standard Focus Mild-to- 1 Paraeducator Moderate Miraloma ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- 1 Paraeducator Moderate Miraloma ES 12 2 3-to-12 or 0.25 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Mission HS Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Mission HS Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 66 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Mild-to- Aligned with Mission HS Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard 1 Paraeducator Extensive Mission HS 9 2 3-to-9 or 0.33 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Mission HS 9 2 3-to-9 or 0.33 1-to-5 or 0.20 Above Industry Needs Standard Extensive Aligned with Mission HS Needs Autism 8 2 3-to-8 or 0.38 1-to-3 or 0.33 Industry Focus Standard Mild-to- 1 Paraeducator MLK MS Moderate 7 1 2-to-7 or 0.29 1-to-7 or 0.14 Above Industry Needs Standard Mild-to- 1 Paraeducator MLK MS Moderate 6 1 2-to-6 or 0.33 1-to-7 or 0.14 Above Industry Needs Standard Mild-to- Aligned with O'Connell HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with O'Connell HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Peabody Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry (George) ES Needs Standard Mild-to- Aligned with Peabody Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry (George) ES Needs Standard Mild-to- Aligned with Peabody Moderate 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry (George) ES Needs Autism Standard Focus Mild-to- Aligned with Peabody Moderate 9 2 3-to-9 or 0.33 1-to-3 or 0.33 Industry (George) ES Needs Autism Standard Focus Mild-to- Aligned with Peabody Moderate 9 2 3-to-9 or 0.33 1-to-3 or 0.33 Industry (George) ES Needs Autism Standard Focus Fiscal Crisis and Management Assistance Team San Francisco Unified School District 67 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Mild-to- Aligned with Presidio MS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Moderate Presidio MS 11 2 3-to-11 or 0.27 1-to-3 or 0.33 Industry Needs Autism Standard Focus 1 Paraeducator Extensive Presidio MS 7 2 3-to-7 or 0.43 1-to-5 or 0.20 Above Industry Needs Standard Mild-to- Aligned with Revere (Paul) Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry K-8 Needs Standard Mild-to- Aligned with Revere (Paul) Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry K-8 Needs Standard Mild-to- Aligned with Roosevelt MS Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- 1 Paraeducator Moderate Roosevelt MS 12 2 3-to-12 or 0.25 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Extensive Aligned with Roosevelt MS Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Ruth Asawa Mild-to- Aligned with School of the Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Arts HS Needs Standard Mild-to- Aligned with Sanchez ES Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Sanchez ES Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry Needs Standard Mild-to- 1 Paraeducator Moderate Sherman ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Fiscal Crisis and Management Assistance Team San Francisco Unified School District 68 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Mild-to- 1 Paraeducator Moderate Sherman ES 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Needs Autism Standard Focus Mild-to- Aligned with Spring Valley Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Science ES Needs Standard Mild-to- Aligned with Spring Valley Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Science ES Needs Standard Stevenson Mild-to- Aligned with (Robert Louis) Moderate 13 1 2-to-13 or 0.15 1-to-7 or 0.14 Industry ES Needs Standard Stevenson Mild-to- Aligned with (Robert Louis) Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry ES Needs Standard Stevenson Mild-to- Aligned with (Robert Louis) Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry ES Needs Standard 1 Paraeducator Extensive Sunnyside ES 7 2 3-to-7 or 0.43 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Sunnyside ES 5 2 3-to-5 or 0.60 1-to-5 or 0.20 Above Industry Needs Standard Extensive Aligned with Sunset ES Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Extensive Aligned with Sunset ES Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Mild-to- 1 Paraeducator Taylor (Edward Moderate 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry R) ES Needs Autism Standard Focus Mild-to- Aligned with Taylor (Edward Moderate 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry R) ES Needs Autism Standard Focus Fiscal Crisis and Management Assistance Team San Francisco Unified School District 69 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Mild-to- 1 Paraeducator Tenderloin Moderate 13 2 3-to-13 or 0.23 1-to-3 or 0.33 Below Industry Community ES Needs Autism Standard Focus Mild-to- Aligned with Thurgood Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Marshall HS Needs Standard Mild-to- Aligned with Vis Valley MS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Wallenberg HS Moderate 12 1 2-to-12 or 0.17 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Washington HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Washington HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Washington HS Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry Needs Standard Mild-to- Aligned with Washington HS Moderate 11 1 2-to-11 or 0.18 1-to-7 or 0.14 Industry Needs Standard Aligned with Extensive Washington HS 7 1 2-to-7 or 0.29 1-to-5 or 0.20 Industry Needs Standard Aligned with Extensive Washington HS 7 1 2-to-7 or 0.29 1-to-5 or 0.20 Industry Needs Standard 1 Paraeducator Extensive Washington HS 8 2 3-to-8 or 0.38 1-to-5 or 0.20 Above Industry Needs Standard 1 Paraeducator Extensive Washington HS 8 2 3-to-8 or 0.38 1-to-5 or 0.20 Above Industry Needs Standard Mild-to- Aligned with Willie Brown Moderate 10 1 2-to-10 or 0.20 1-to-7 or 0.14 Industry MS Needs Standard Fiscal Crisis and Management Assistance Team San Francisco Unified School District 70 Appendices Appendix B — District/County’s Special Education Paraeducator SDC Staff Compared to Industry Standards Industry Standard Teacher and Classroom Staffing Teacher and Support Above Number of Classroom Support Paraeducator(s) or Below SDC Class Number of Classroom Paraeducator(s) to to Students Industry School Site Type Students Paraeducators Students Ratio Ratio Standard Extensive Aligned with Wo (Yick) ES Needs Autism 9 2 3-to-9 or 0.33 1-to-3 or 0.33 Industry Focus Standard Extensive Aligned with Wo (Yick) ES Needs Autism 10 2 3-to-10 or 0.30 1-to-3 or 0.33 Industry Focus Standard Source: District/county-provided allocation data. Note: This table shows data for 228 of the district/county classroom special education paraeducators working in an SDC. It excludes data for district/county classroom special education paraeducators working in preschool, deaf/hard of hearing, SOAR, and Access SDCs because FCMAT does not have an industry-standard staffing ratios for those programs. Fiscal Crisis and Management Assistance Team San Francisco Unified School District 71 Appendices Appendix C – Study Agreement Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 72 Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 73 Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 74 Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 75 Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 76 Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 77 Appendix C – Study Agreement Fiscal Crisis and Management Assistance Team San Francisco Unified School District 78 Appendix C – Study Agreement Digitally signed by Michael H. Fine Michael H. Fine Date: 2024.06.17 15:49:16 -07'00' Fiscal Crisis and Management Assistance Team San Francisco Unified School District 79