San Joaquin County Office of Education Report

i DRAFT San Joaquin County Office of Education SELPA Review December 20, 2013 Joel D. Montero Chief Executive Officer San Joaquin County offiCe of eduCation Fiscal crisis & ManageMent assistance teaM December 20, 2013 Mick Founts, Ed.D. Superintendent of Schools San Joaquin County Office of Education 2901 Arch Airport Road Stockton, CA 95206 Dear Superintendent Founts, In December 2012, the San Joaquin County Office of Education and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for a SELPA review. Specifically, the agreement stated that FCMAT would perform the following: 1. Analyze the present AB 602 funding model and all funds used to provide service to special education students in the SELPA and make recommendations, if necessary, that would make the model more appropriate or equitable for all districts. 2. Provide an analysis of the fiscal impact on remaining districts if Lincoln Unified elects to withdraw from the SELPA. 3. Provide an analysis of the level of direct support and indirect costs charged by the COE to the special education programs for administrative support, including but not limited to payroll, finance and accounting, accounts payable, facilities management, human resources, workers compensation administration, collective bargaining, risk management and information technology. 4. Review the distribution of construction and deferred maintenance cost allocations and funding from the COE for special education facilities. 5. Provide a comparison of current administrative staffing ratios in the COE Special Education Regional Program relative to those in other like SELPAs, with consideration to the type of special education population served. 6. Review all class sizes operated by the COE in comparison to like class sizes maintained by other like SELPAs. 7. Analyze the COE Special Education Regional Program teacher and administrative salary and benefit costs relative to those of the districts that the SELPA serves and of like programs operated by other SELPAs/LEAs/COEs. 8. Compare the total costs of special education programs operated by the San Joaquin SELPA to the total costs of like programs operated by other SELPAs. 9. Define all the revenue sources for special education programs and services in San Joaquin COE that may not be included in the SELPA allocation plan. 10. Identify nonmandatory services that negatively impact COE Special Education Regional Program costs. 11. Compare historical legal expenses with those of other like SELPAs. This FCMAT special education study was approved by vote of the San Joaquin County SELPA superintendent’s council. The Escalon Unified School District voted against approval. The SELPA governance council requested FCMAT to conduct a review comparing fiscal and program operations that are provided by the county office. Fieldwork was conducted February 12-15, 2013. This final report contains the study team’s findings and recommendations in the above areas of review. FCMAT appreciates the opportunity to serve the San Joaquin County Office of Education, and extends thanks to all the staff for their assistance during fieldwork. Sincerely, Joel D. Montero Chief Executive Officer i TABLE OF CONTENTS Table of contents About FCMAT .........................................................................................iii Introduction ............................................................................................1 Background ......................................................................................................1 Study Guidelines ............................................................................................1 Study Team.......................................................................................................2 Executive Summary ........................................................................3 Findings and Recommendations .....................................................5 Staffing, Caseloads and Efficiency ............................................................5 Funding Model .............................................................................................11 Fiscal Analysis ................................................................................................21 Fiscal Effect if Lincoln USD Withdraws from SELPA ..........................33 Appendices ............................................................................................37 San Joaquin County offiCe of eduCation ii TABLE OF CONTENTS Fiscal crisis & ManageMent assistance teaM iii ABOUT FCMAT About FCMAT FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify, prevent, and resolve financial and data management challenges. FCMAT provides fiscal and data management assistance, professional development training, product development and other related school business and data services. FCMAT’s fiscal and management assistance services are used not just to help avert fiscal crisis, but to promote sound financial practices and efficient operations. FCMAT’s data management services are used to help local educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and share information. FCMAT may be requested to provide fiscal crisis or management assistance by a school district, charter school, community college, county office of education, the state Superintendent of Public Instruction, or the Legislature. When a request or assignment is received, FCMAT assembles a study team that works closely with the local education agency to define the scope of work, conduct on-site fieldwork and provide a written report with findings and recommendations to help resolve issues, overcome challenges and plan for the future. Studies by Fiscal Year 90 80 70 60 50 40 30 20 10 0 92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 San Joaquin County offiCe of eduCation seidutS fo rebmuN FCMAT also develops and provides numerous publications, software tools, workshops and professional development opportunities to help local educational agencies operate more effec- tively and fulfill their fiscal oversight and data management responsibilities. The California School Information Services (CSIS) arm of FCMAT assists the California Department of Education with the implementation of the California Longitudinal Pupil Achievement Data System (CALPADS) and also maintains DataGate, the FCMAT/CSIS software LEAs use for CSIS services. FCMAT was created by Assembly Bill 1200 in 1992 to assist LEAs to meet and sustain their financial obligations. Assembly Bill 107 in 1997 charged FCMAT with responsi- bility for CSIS and its statewide data management work. Assembly Bill 1115 in 1999 codified CSIS’ mission. AB 1200 is also a statewide plan for county office of education and school districts to work together locally to improve fiscal procedures and accountability standards. Assembly Bill 2756 (2004) provides specific responsibilities to FCMAT with regard to districts that have received emergency state loans. In January 2006, SB 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to those types of LEAs. iv ABOUT FCMAT Since 1992, FCMAT has been engaged to perform nearly 850 reviews for LEAs, including school districts, county offices of education, charter schools and community colleges. The Kern County Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D. Montero, Chief Executive Officer, with funding derived through appropriations in the state budget and a modest fee schedule for charges to requesting agencies. Fiscal crisis & ManageMent assistance teaM 1 INTRODUCTION Introduction Background The San Joaquin County Special Education Local Plan Area (SELPA) consists of 10 districts and the county office of education. The county office is responsible for providing special education to students referred to it by the SELPA member districts. The programs provided include special day classes (SDC) for students from ages 0-22 with moderate/severe disabilities in the areas of autism, emotionally disturbed, other health impaired, speech or language impairment, traumatic brain injury, intellectual disability, multiple disability, orthopedic impairment, visually impaired, deaf/hard of hearing, established medical disability and, in limited cases, students with specific learning disabilities. Related services in speech, occupational therapy, adaptive physical education and mental health counseling are available to students in the county office special day classes. Itinerant services for students who are deaf, hard of hearing, or visually impaired are provided to students in district programs. Districts may also individually contract for speech, occupational therapy and psycho- logical services for students in district programs. The county office administrative structure is responsible for overseeing the SDCs, itinerant programs, direct service districts, speech and language services and psychological services. The SELPA allocates the available resources to its districts by first funding the SELPA and all San Joaquin County Office of Education special education programs, with the remaining funds distributed to districts. This model is not clearly understood by all, and there are questions from the SELPA membership about overall operating costs for county programs. Study Guidelines In December 2012, the San Joaquin County Office of Education and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for management assistance. Specifically, the agreement states that FCMAT will perform the following: FCMAT visited the San Joaquin COE on February 12-15, 2013 to conduct interviews, collect data and review documents. This report is the result of those activities and is divided into the following sections: • Executive Summary • Staffing, Caseloads and Efficiency • Funding Model • Fiscal Analysis • Fiscal Effect if Lincoln USD Withdraws from SELPA San Joaquin County offiCe of eduCation 2 INTRODUCTION Study Team The study team was composed of the following members: William P. Gillaspie, Ed.D. Trina Frazier* FCMAT Deputy Administrative Officer Administrator Sacramento, California Fresno County SELPA Fresno, California Linda Grundhoffer FCMAT Consultant JoAnn Murphy Danville, California FCMAT Consultant Santee, California Anne Stone FCMAT Consultant Laura Haywood Mission Viejo, California FCMAT Technical Writer Bakersfield, California Debbie Fry FCMAT Consultant Lake Almanor, California *As a member of this study team, this consultant was not representing her employer but was working solely as an independent contractor for FCMAT. Fiscal crisis & ManageMent assistance teaM 3 EXECUTIVE SUMMARY Executive Summary The San Joaquin County SELPA allocates resources to member districts and ensures that each district has a stable and reliable fiscal basis for financial planning. Fiscal documents are thorough and detailed, although member districts report that they are not easily understood. Allocations are made “off the top” to county operated programs, which means they are funded first, with the remaining funds distributed to districts. Based on a historic method agreed on by SELPA members, districts receive varying base rates, which range from $96.72 to $199.33. The funding per average daily attendance (ADA) also varies. The SELPA and member districts should examine how these inequities have evolved, and may want to distribute funds to each district based on overall ADA because that is how state funding is allocated. If Lincoln School District withdraws from the SELPA it will take with it a higher base rate, which will negatively affect all member districts. All AB 602 funding would be reduced, as would federal and state preschool funds. Regionalized services funds would also be reduced. The total estimated fiscal impact would be $6,045,323. There is no clear distinction between the roles and responsibilities of the SELPA and the San Joaquin County Office of Education. The agencies are referred to interchangeably. There are programmatic differences in the roles; however, the SELPA distributes all funding, and the county office receives those funds just like other districts in the SELPA. The salary costs of the San Joaquin COE are slightly higher than some other county offices and lower than others. The San Joaquin COE salary and benefit costs are slightly higher than the median average of the nine districts in the San Joaquin SELPA. San Joaquin COE salary and benefits are comparable to both the Lodi and Stockton Unified SELPAs in San Joaquin County. The SELPA makes proportional reimbursement of tuition costs for students enrolled in nonpublic schools and agencies. Many requests for nonpublic schools and agencies are approved prior to exhausting all county-operated programs and resources. This can create an incentive for excessive use of nonpublic schools as a program option It should be noted that districts make these placements, not the county office. The SELPA should consider adopting a policy that states only claims for NPS/NPA costs for contracts that have been pre-approved by the SELPA will be considered for reimbursement. The total cost of county operated programs is comparable with six other counties of similar size. The average number of administrators for special education programs in these county offices is 7.87 FTE. The number of administrators in the San Joaquin COE is 6.5. Its salary costs are slightly higher than other counties. The average number of administrators to students is 1:105, while the ratio in San Joaquin COE is 1:126. The special day class sizes in the county office meet or exceed the industry standard established by School Services of California, Inc. and are comparable to both Fresno and Stanislaus county offices of education. The county uses numerous codes to record program expenses and revenue. Identifying the posi- tions charged to individual programs and standardizing the accounting would improve clarity. The legal expenses of the county office are lower than the average range of other SELPAs of comparable size. San Joaquin County offiCe of eduCation 4 Fiscal crisis & ManageMent assistance teaM 5 STAFFING, CASELOADS AND EFFICIENCY Findings and Recommendations Staffing, Caseloads and Efficiency The county office has no written policy or guidelines on class sizes but does have an established practice of maximizing resources while yielding educational benefit for each student in the least restrictive environment. The Education Code does not indicate maximum caseloads for special day classes. The industry standards for SDC sizes and instructional aide support are defined in guidelines developed by School Services of California, Inc. (SSC) using data collected on standard practice throughout the state. The county office class sizes for SDC meet or exceed these guidelines. The average class size is 10-12 students with two instructional aides, while the SSC guidelines are 8-10 with additional aide support. In the 67 classes reviewed, 35 1:1 paraprofessional aides are assigned to individual students in addition to the designated class staffing. The preschool autism program has a three-tiered level of paraprofessional aide support depending on the needs of the students, ranging from 1:1 to 1:3. Students requiring 1:1 support ratios during intensive behavior analysis and discrete trial training receive those services at school. Both part- and full-time aides are employed to maximize resources. SDC Caseloads, San Joaquin County Office of Education Number Total number Average Program SSC Guidelines of classes of students class size Preschool 2 10-12 22 11 Pre-K Autism 9 9 76 8 Autism K-8 10 9 83 8 Autism 7-12 2 9 18 9 Severely Handicapped K-12 27 10-12 292 11 Emotionally Disturbed K-12 8 8-10 52 7 Deaf/Hard of Hearing 4 8-10 38 10 Orthopedically Handicapped 2 8-10 19 10 Source: SJCOE caseload distribution lists 2013 Special Day Class Loading in Comparative Size County Offices FCMAT reviewed SDC caseload data submitted from the two county offices of comparable size (Fresno and Stanislaus) that responded to FCMAT’s request for caseload data. Programs/classes are formed based on the needs of students and may not have the same title or program descrip- tion. Despite this difference, all of the programs’ class averages are close to or below the SSC guidelines. San Joaquin County offiCe of eduCation 6 STAFFING, CASELOADS AND EFFICIENCY SDC Class Caseloads, Fresno County Office of Education Total No. Average No. Program No. of Classes SSC Guideline of Students of Students in Class Pre-K 3 10-12 26 9 Pre-K Autism 3 8-10 24 8 Autism K-8 4 8-10 35 9 Severely Handicapped 53 10-12 455 9 K-Adult Emotionally Disturbed 9 8-10 50 6 K-12 Note: Fresno USD serves Fresno COE’s DHH and Fresno COE serves Fresno USD’s ATP. SDC Class Caseloads, Stanislaus County Office of Education Average. No. Program No. of Classes SSC Guideline of Students in Class Pre-K 4 10-12 4 Pre-Autism 5 9 9 Autism K-8 5 9 7 Autism 7-12 1 9 7 Severely Handicapped 1 10-12 7 Emotionally Disturbed 3 8-10 12 Deaf/Hard of Hearing 6 8-10 5 Orthopedically Impaired 1 8-10 6 The class sizes of the San Joaquin COE are higher than comparable classes in Fresno and Stanislaus counties. Recommendation The county office should: 1. Continue to staff SDC classes under current practice that follows SSC guide- lines. Designated Instruction Services (DIS) Designated instruction services are support services designed to help a child benefit from his/her special education program and make progress in the general education curriculum. Speech Pathologists Caseloads for speech pathologists in the county office are based on a weighted caseload. A caseload of no more than 55 is designated in Education Code (EC) 56363.3 unless the local plan specifies a higher average caseload and the reasons for the higher caseload. The average San Joaquin County Office caseload for a speech pathologist in the 2012-13 school year is 53 Fiscal crisis & ManageMent assistance teaM 7 STAFFING, CASELOADS AND EFFICIENCY students. The county office does not distinguish caseload distribution for preschool versus K-12 populations consistent with EC 56441.7, which specifies a caseload maximum of 40 for speech and language specialists serving the preschool population. The total average caseload for all K-12 speech pathologists is 53. Total No. of Students/ AT Services Sites Preschool Caseload Weighted 4 15 43.44 6 7 0 54 6 20 62.4 2 15 47.55 4 0 46 3 9 32.33 3 12 38.7 33 5 0 70 5 0 39 3 39 66.43 1 7 0 61 2 4 15 54.85 Speech and Language Caseloads – San Joaquin COE * Combined caseloads must be proportionately assigned consistent with EC 56363.3 and 56441.7. Source: Caseload data provided by SJCOE Recommendations The county office should: 1. Conduct an analysis to determine how to strategically decrease speech and language pathologist staffing while maintaining combined (preschool/K-12) caseloads within recommended guidelines. School Psychologists Contracts for individual psychologists in the county office can average 202 days per year. Psychologists play an integral role in the staff development provided by San Joaquin County SELPA. San Joaquin County offiCe of eduCation 8 STAFFING, CASELOADS AND EFFICIENCY Recommendations The county office should: 1. Define the contract days necessary for psychologists to complete their Individuals with Disabilities Education Act (IDEA) responsibilities regarding the evaluation of disabled students. 2. Develop systems to monitor and support the accountability of non-tradi- tional contract days. Itinerant Services (VI, DHH, APE, OT) Most itinerant service providers carry caseloads comparable to those recommended by School Services of California, Inc. Itinerant Caseloads Provider SSC Ratio FTE Average Caseload Adapted Physical Education 1:45-55 2.0 1:50 (APE) Visually Impaired (VI) 1:10-30 2.0 1:32 Deaf and Hard of Hearing 1:10-30 1.0* 1:67 (DHH) Occupational Therapy (OT) 1:20-35 3.8 1:60 Source: Caseload data provided by SJCOE While the occupational therapy caseload exceeds the industry standard, this is fairly common for districts/SELPAs around the state. The caseload for deaf and hard of hearing itinerants exceeds the guidelines established by School Services of California, Inc. Recommendations The county office should: 1. Consider increasing staff for deaf and hard of hearing to align with SSC guidelines. Administrative Staffing FCMAT was asked to review the administrative staffing ratios in the SELPA/county office and compare them to other SELPAs/county offices of similar size. The review focused on the county office administrative structure because the SELPA administrators do not provide program services in the San Joaquin County SELPA or in any of the SELPAs contacted. FCMAT contacted six SELPAs/county offices of similar size that provide programs to several districts, offer moderate/ severe programs for ages 0-22 and itinerant services similar to that of the San Joaquin COE, are geographically large and have a separate special education county administrator for those programs. Five of the SELPAs/county offices responded and are included in the data below. SELPA/county office administrators have various titles. Therefore, a ratio of full time equivalent (FTE) administrative positions to the total number of students served by the county office was Fiscal crisis & ManageMent assistance teaM 9 STAFFING, CASELOADS AND EFFICIENCY used. The total number of special education students served by a COE is not available on the California Special Education Management Information System (CASEMIS). The CASEMIS includes county office special day class students in the District of Residence reports, and in many cases the county office itinerant services are included in the CASEMIS District of Service reports. Therefore, the county offices provided both the administrative FTEs and the total number of SDC and itinerant students they serve. Adjustments were made for the one county office that also provides resource and mild/moderate programs. The San Joaquin COE has three coordinators listed on the organizational chart; however, the county office reported that these coordinators are not administrators but are service providers in occupational therapy, behavior management and nursing. The job description for San Joaquin COE indicates that coordinators supervise and evaluate staff, which is an administrative func- tion. The San Joaquin COE has indicated that this function of the coordinator position will be removed from the job description. Ratio of Students Served to COE Administrators County Office Number of Full Time Administrator/ of Education Students Served Equivalent Student Ratio Administrators San Joaquin 821 6.5 1:126 Stanislaus 768 5.5 1:140 Fresno 900* 8.5 1:106 Monterey 681 10 1:68 Sonoma 1012 6.92 1:146 Placer 570 6.5 1:88 * This includes itinerant services and students served in SD classrooms. The average FTE of special education administrative positions is 7.87. The average ratio of administrators to students in the comparison counties is 1:108. San Joaquin has fewer adminis- trators per students than three county offices and more than two county offices. Several factors can increase or decrease the appropriate number of county office administrators. These include the level of oversight that county office administrators provide to county office programs on district sites, whether the county office operates separate schools, and the number of district programs for moderate/severe students. Therefore, this data is not meant to be inter- preted that the San Joaquin COE is overstaffed, but it may be useful in discussions regarding administrative staffing. Recommendation The county office should: 1. Regularly review the data regarding administrator/student ratios with the SELPA member districts to determine the need for additional or fewer COE administrative support positions. San Joaquin County offiCe of eduCation 10 Fiscal crisis & ManageMent assistance teaM 11 FUNDING MODEL Funding Model In January 1974, the California State Board of Education adopted the California Master Plan for Special Education. (See Appendix A, Distribution of Special Education Resources to LEAs.) While much has changed over the last 39 years, the fiscal model remains essentially intact and offers detailed guidance. The essential objectives of an equitable finance plan for special education , as stated in the California Master Plan, are as follows: 1. Provide adequate resources to assure equality of educational opportunity for all individuals with exceptional needs. 2. Provide levels of support for special education programs which will promote programs and services of equal quality. 3. Provide encouragement for the development of comprehensive programs. 4. Promote both program and fiscal accountability. 5. Clarify fiscal relationships between state, county, and district. 6. Ensure equity in support levels among various program components. 7. Provide adjustments in support levels to reflect changing costs. 8. Provide support based on needs of pupils enrolled in special education- funding based on specified programs and services rather than on categorical disability groupings. 9. Ensure that reporting and auditing policies and procedures are meaningful for evaluation and program development. 10. Provide methods for monitoring and evaluating quality control in special education. The California Master Plan for Special Education, California State Board of Education, January 10, 1974, pages 36-37, states: No two multiagency SELPAs are identical. Each SELPA uses its own demographic, socioeconomic, and political considerations to address concerns such as equality of educational opportunity, programs and services of equal quality, and equity in support levels. There is no single, correct way to construct a SELPA funding plan. Equally important is the SELPA’s responsibility to continually analyze its funding model to ensure that resources are used effectively, providing equal opportunity and quality and equitable support. Assembly Bill (AB) 602 was enacted in 1997 to provide SELPAs with a state funding model that permits flexibility in its application and allows for any needed changes. FCMAT was asked to analyze the AB 602 funding model and all funds used to serve special education students in the SELPA and make recommendations, if necessary, that would make the model more appropriate or equitable for all districts. The San Joaquin County SELPA Local Plan for Special Education was revised in June 2007 and contains a section addressing the distribution of special education resources to its LEAs. San Joaquin County offiCe of eduCation 12 FUNDING MODEL The SELPA allocation plan guides the distribution of resources and ensures that each LEA has a stable, reliable fiscal basis for financial planning. SELPAs receive funding from three sources to help districts pay the excess costs of providing special education programs and services to children with physical, emotional, or developmental disabilities: federal funds provided by the Individuals with Disabilities Education Act (IDEA), state funds provided per Part 30 of the Education Code (AB 602 funding), and local funds raised through property taxes. Member districts in the San Joaquin County SELPA lack understanding of the funding alloca- tion plan. The SELPA regularly provides detailed information to the member districts regarding the plan at council and fiscal meetings. The SELPA director is available to the member districts to review the plan and for consultation. Some districts reported that when fiscal documents are shared at council meetings, each repre- sentative draws attention to their respective district data and does not take the time to determine how fiscal and programmatic decisions affect the SELPA as a whole. Each district should under- stand the global perspective and the intricacies of the funding allocation plan and how decisions affect each member. The SELPA may want to simplify the information provided to the member LEAs to increase understanding. The fiscal documents and reports to the superintendent’s council are thorough and detailed. These reports may be valuable for the fiscal staff, but the information included could be excessive for program staff. Although all reports should be available to both fiscal and program decision makers, they should be modified for the reader. The local plan clearly states the purpose of the SELPA’s allocation plan; however, superintendents, special education administrators, and busi- ness staff members repeatedly indicated that the plan is not clearly understood. It is not unusual for SELPAs to be subject to inquiries about their funding allocation plan, espe- cially from new superintendents, special education directors and business staff. This is primarily why continuous education for member districts is crucial. This is particularly relevant given the high turnover rate experienced in SELPA members’ top leadership positions over the last decade. Member LEAs should have a full financial accounting of all funding sources, with amounts updated either quarterly, or at periods that allow each member LEA to use the data for its reporting requirements and deadlines (i.e., first interim, second interim, budget adoptions, unau- dited actuals). Other helpful items may include the account code string and any notes that may help clarify calculations, deadline dates, etc. ADA for AB 602 purposes, as provided by CDE, and the December unduplicated pupil count would also provide data that member LEAs frequently reference. If federal preschool funds are allocated based on pupil count, that data also would be useful. Other services charged to member LEAs by the SELPA AU or county operated programs could also assist member LEAs in accurately budgeting expenditures. The estimated transportation bill back cost is provided to districts at Finance Advisory, Council of Directors and Special Education Finance Committee meetings and does provide essential data for budget planning, as this item is typically very expensive for member LEAs. A single fiscal summary sheet for each LEA would be more effective. Below is a sample fiscal summary sheet that could offer a comprehensive overview of each member LEA’s allocations. Fiscal crisis & ManageMent assistance teaM 13 FUNDING MODEL LEA Name Fiscal Summary Sheet 2012-13 2nd Quarter Update On-Going Funds Funding Source Account Code Amount Notes State AB602 0100-65000-0-5001-0000-879200 $0.00 P-1 Certification, See AB602 Breakdown AB602 PY Adjustments 0100-65000-0-5001-0000-879201 $0.00 TBD at P-2 Program Specialist 0100-65000-0-5060-0000-879200 $0.00 Estimate Out-of-Home Care 0100-65000-0-5001-0000-879200 $0.00 Estimate Legal/NPS/NPA Claims 0100-65000-0-5001-0000-879200 $0.00 Submit Claims by July 31, 2013 Other State 0100-65000-0-5001-0000-879200 $0.00 TBD Sub-Total for Resource 6500: $0.00 Federal Entitlement 0100-33100-0-5001-0000-818100 $0.00 2012-13 Allocation. See Federal Ent Breakdown. Federal Priv School 0100-33110-0-5001-0000-818100 $0.00 n/a Preschool Part B-619 0100-33150-0-5730-0000-818200 $0.00 2012-13 Allocation Preschool Part B-611 0100-33200-0-5730-0000-818200 $0.00 2012-13 Allocation J50 Infant 0100-65100-0-5710-0000-831100 $0.00 Estimate WorkAbility 0100-65200-0-5770-0000-867700 $0.00 Estimate Low Incidence Svcs 0100-65300-0-5750-0000-867700 $0.00 Estimate Mental Health Claims 0100-65120-0-5755-0000-859000 $0.00 Submit Claims by July 31, 2013 On-Going Grand Total: $0.00 Costs and Billbacks 2012-13 Transportation Billback Estimate Billback Notes Estimated Rider Count SELPA will transfer Billback charge to Member LEA using Budget Estimate @ $6,400 per Rider account code 0100-65000-0-5750-9200-714201 Other Charges, Fee-for-Service n/a $0.00 SELPA will invoice Member LEA Other Information SEMA SEMAI SEMB 2011-12 SEMA with PCRA without PCRA without PCRA with PCRA Maintenance-of-Effort Reports 2012-13 Federal Expenditures 2012-13 State/Local Expenditures 2012-13 Total Expenditures ADA for AB602 Purposes 2012-13 P-2 2012-13 P-1 2011-12 P-2 Served by District Member Served by County Operated Programs Pupil Count (by District of Service) Dec 2012 Dec 2011 Dec 2010 Total Unduplicated Pupil Count Breakdown Preschool Only Pupil Count Infant Only Pupil Count Parentally-Placed Private School Pupils (Ages 6-21) Note: Also include any one-time funds, which may increase the document size to legal. Thursday, February 28, 2013 San Joaquin County offiCe of eduCation 14 FUNDING MODEL As is the case with many SELPAs, San Joaquin SELPA’s transition from the J-50 funding plan to the AB 602 funding plan appears to have exacerbated some ongoing inequalities and inequities. Federal IDEA basic local assistance is based on prior year pupil count. The San Joaquin County SELPA AB 602 funds are allocated to the LEAs using a method that is linked to the 1997-98 adjusted base funding for each district and county office. In addition, member LEAs receive (1) a per-ADA share of the COLA, (2) a proportionate share of growth, and (3) a per-ADA share of 75% of the supple- ment to base (which San Joaquin COE terms as “Phase III”), with the 25% balance used toward full funding (which San Joaquin COE terms as “Phase I”). After the amounts are added to the member LEA’s base funding, the allocations are based on a funding factor derived from the balance of AB 602 funds available to districts divided by the total SELPA revenues, less the COE total base funding and less the total for maximizing the reserve. Using both the P-2 and Annual Certification data, in the 2011-12 fiscal year, this factor was 0.3651, or $9,427,526 of the $25,796,558 AB 602 exhibit amount (after deducting $2,902,374 for county program base funding and ongoing maxi- mization reserves). Member LEAs receive AB 602 funding in a range between $96.72 per ADA and $199.33 per ADA. Federal IDEA funds are allocated to SELPAs using a complex statewide formula involving base year allocation, poverty and CBEDS counts. Some SELPAs distribute these funds equally among all LEAs based on pupil count. Only the county office receives the revenue generated by property taxes, which is consistent with how many other SELPAs distribute these funds. County offices have a portion of their property taxes allocated to the SELPA of which they are a member, based on historical ratios. Since 1998-99, special education funding increases are based on each SELPA’s K-12 growth ADA times the statewide target rate. Comparison of Base Rates Each SELPA is unique in terms of base rate funding levels, unlike the statewide target rate, which is the same for all SELPAs. The table below compares San Joaquin SELPA’s AB 602 base rate to that of similar-size SELPAs. 2011-12 County ADA and AB 602 Base Rate Comparison SELPA Name SELPA Total ADA AB 602 Base Rate Fresno County 77,697.10 630.5336974560 Monterey County 68,995.47 640.3183505810 Placer County 64,990.16 629.2049360958 San Joaquin County 64,488.89 634.1812413171 Sonoma County 67,399.04 727.1327104489 Source: SELPA Special Education Funding Exhibits Districts with increasing ADA receive growth dollars funded at the SELPA K-12 statewide average of $465 per ADA. However, if the SELPA has districts with declining ADA, adjustments to the funding utilize each SELPA’s unique base rate. For San Joaquin County SELPA this is $634 per ADA, and the SELPA has a one-year hold harmless policy for districts with declining ADA. The decline is calculated at the base rate. The table below shows the AB 602 funding each member LEA receives. Based on the SELPA’s data, the AB 602 funding for the base, supplements to the base, COLA, and growth adjustments per ADA among the member LEAs ranges from $96.72 to $199.33. Each member LEA receives a different per-ADA rate based on the historical methodology. Fiscal crisis & ManageMent assistance teaM 15 FUNDING MODEL Current Funding Allocations State Property Tax for Special Total CDE AB602 Apportionment Basic Local Assistance Entitlement Education 28,698,932.00 9,929,699.00 2,173,765.00 40,802,396.00 2011-12 P-2 AB602 per Dec-2010 Federal 3310 Federal 3310 per Current Total Member ADA AB602 Allocation ADA Pupil Count Allocation Pupil Count State Prop Tax Allocation Banta Elementary 310.02 44,035.00 142.04 17 24,181.00 1,422.41 0.00 68,216.00 Escalon Unified 2,742.54 270,221.00 98.53 244 347,063.00 1,422.39 0.00 617,284.00 Jefferson Elementary 2,452.34 371,617.00 151.54 249 354,175.00 1,422.39 0.00 725,792.00 Lammersville Joint 2,113.60 328,778.00 155.55 180 256,030.00 1,422.39 0.00 584,808.00 Lincoln Unified 8,539.94 1,106,778.00 129.60 928 1,319,977.00 1,422.39 0.00 2,426,755.00 Linden Unified 2,235.49 216,225.00 96.72 282 401,114.00 1,422.39 0.00 617,339.00 Manteca Unified 22,224.03 2,723,523.00 122.55 2,386 3,393,821.00 1,422.39 0.00 6,117,344.00 New Jerusalem 1,213.83 170,703.00 140.63 34 48,361.00 1,422.38 0.00 219,064.00 Ripon Elementary 2,980.69 383,003.00 128.49 275 391,157.00 1,422.39 0.00 774,160.00 Tracy Unified 16,653.25 2,411,745.00 144.82 1,604 2,281,512.00 1,422.39 0.00 4,693,257.00 Sub Total 61,465.73 8,026,628.00 6,199.00 8,817,391.00 16,844,019.00 SELPA and County 2011-12 P-2 AB602 per Dec-2010 Federal 3310 Federal 3310 per Current Total Operated ADA AB602 Allocation ADA Pupil Count Allocation Pupil Count Off-the-Top Allocation Venture Academy 1,256.11 250,377.00 199.33 86 0.00 0.00 0.00 250,377.00 Court/Community Schools 1,291.28 257,387.00 199.33 0 0.00 0.00 0.00 257,387.00 County Operated Programs 475.77 17,990,775.00 Off the Top 696 1,112,308.00 1,598.14 2,173,765.00 21,276,848.00 SELPA 0.00 2,173,765.00 0 0.00 0.00 0.00 2,173,765.00 Sub Total 3,023.16 20,672,304.00 782.00 1,112,308.00 2,173,765.00 23,958,377.00 Grand Total 64,488.89 28,698,932.00 6,981.00 9,929,699.00 2,173,765.00 40,802,396.00 There appear to be no significant discrepancies in the percentage of students in county programs versus the percentage that each district makes up of the SELPA. Each district makes up a proportional percentage of the students placed in county programs based on their overall ADA with the exception of early intensive behavioral treatment (EIBT). Banta Elementary, Jefferson Elementary, Lammersville Joint, and Tracy Unified have higher than their proportional share of EIBT/IBT contracts. Percentage of Students in County-Operated Programs District District % of Total County % of SJCOE EIBT/IBT % EIBT Annual SELPA Placements Students Contract ADA ADA Banta 310.02 0.48% 2 0.31% 2 3.13% Escalon 2,742.54 4.28% 25 3.89% 0 0.00% Jefferson 2,452.34 3.82% 24 3.73% 6 9.38% Lammersville 2,113.60 3.29% 25 3.89% 7 10.94% Lincoln 8,541.07 13.31% 83 12.91% 7 10.94% Linden 2,235.49 3.48% 22 3.42% 1 1.56% Manteca 22,224.03 34.65% 247 38.41% 17 26.56% New Jerusalem 1,213.83 1.89% 0 0.00% 1 1.56% Ripon 2,980.69 4.65% 32 4.98% 2 3.13% Tracy 16,653.98 25.96% 183 28.46% 21 32.81% SJCOE-Other Programs 2,679.68 4.18% 0 0.00% 0 0.00% Totals 64,147.27 100.00% 643 100.00% 64 100.00% The SELPA member districts do not receive equal funding per ADA. Funding allocations to the San Joaquin SELPA and its member LEAs could be based on overall ADA to equitably distribute federal and state resources and services, as shown in the table below. San Joaquin County offiCe of eduCation 16 FUNDING MODEL Proposed Funding Allocations Fiscal crisis & ManageMent assistance teaM xaT ytreporP etatS latoT desoporP noitacudE laicepS rof tnemeltitnE ecnatsissA lacoL cisaB tnemnoitroppA 206BA EDC 00.693,208,04 00.567,371,2 00.996,929,9 47.139,896,82 latoT desoporP 0133 laredeF 0133 laredeF 0102-ceD yb latoT rep 206BA 2-P 21-1102 noitacollA xaT porP etatS tnuoC lipuP rep noitacollA tnuoC lipuP ecnereffiD ADA ADA yb 206BA ADA noitacollA 206BA ADA rebmeM 66.315,56 00.0 14.224,1 00.181,42 71 )43.207,2( 23.331 66.233,14 40.241 00.530,44 20.013 yratnemelE atnaB 14.507,217 00.0 93.224,1 00.360,743 442 14.124,59 23.331 14.246,563 35.89 00.122,072 45.247,2 deifinU nolacsE 12.721,186 00.0 93.224,1 00.571,453 942 )97.466,44( 23.331 12.259,623 45.151 00.716,173 43.254,2 yratnemelE nosreffeJ 35.028,735 00.0 93.224,1 00.030,652 081 )74.789,64( 23.331 35.097,182 55.551 00.877,823 06.311,2 tnioJ ellivsremmaL 35.345,854,2 00.0 93.224,1 00.779,913,1 829 35.887,13 23.331 35.665,831,1 06.921 00.877,601,1 49.935,8 deifinU nlocniL 12.551,996 00.0 93.224,1 00.411,104 282 12.618,18 23.331 12.140,892 27.69 00.522,612 94.532,2 deifinU nedniL 12.587,653,6 00.0 93.224,1 00.128,393,3 683,2 12.144,932 23.331 12.469,269,2 55.221 00.325,327,2 30.422,22 deifinU acetnaM 09.191,012 00.0 83.224,1 00.163,84 43 )01.278,8( 23.331 09.038,161 36.041 00.307,071 38.312,1 melasureJ weN 71.055,887 00.0 93.224,1 00.751,193 572 71.093,41 23.331 71.393,793 94.821 00.300,383 96.089,2 yratnemelE nopiR 56.567,105,4 00.0 93.224,1 00.215,182,2 406,1 )53.194,191( 23.331 56.352,022,2 28.441 00.547,114,2 52.356,61 deifinU ycarT 84.851,210,71 00.193,718,8 00.991,6 84.931,861 84.767,491,8 00.826,620,8 37.564,16 latoT buS latoT desoporP rep 0133 laredeF 0133 laredeF 0102-ceD rep 206BA 2-P 21-1102 ytnuoC dna APLES noitacollA poT-eht-ffO tnuoC lipuP noitacollA tnuoC lipuP poT-eht-ffO ADA noitacollA 206BA ADA detarepO 87.764,761 00.0 00.0 00.0 68 )22.909,28( 87.764,761 33.991 00.773,052 11.652,1 ymedacA erutneV 37.651,271 00.0 00.0 00.0 0 )72.032,58( 37.651,271 33.991 00.783,752 82.192,1 sloohcS ytinummoC/truoC poT eht ffO 00.848,672,12 00.567,371,2 41.895,1 00.803,211,1 696 00.577,099,71 00.577,099,71 77.574 smargorP detarepO ytnuoC 00.567,371,2 00.0 00.0 00.0 0 00.567,371,2 00.567,371,2 00.0 APLES 25.732,097,32 00.567,371,2 00.803,211,1 00.287 25.461,405,02 00.403,276,02 61.320,3 latoT buS 00.693,208,04 00.567,371,2 00.996,929,9 00.189,6 00.239,896,82 98.884,46 latoT dnarG Using this method, Banta, Jefferson, Lammersville, New Jerusalem and Tracy are overfunded. The total calculated increase or decrease for a revised AB 602 allocation method could be applied by San Joaquin County SELPA over a two-to three-year period to allow the districts receiving a decrease to plan for the adjustment. This may be a more equitable distribution and would not increase the allocation to districts with a high pupil count or practice of overidentifying students for special education. AB 602 funds would be allocated to districts based on overall ADA. Any revised method should discourage overidentification of special education students. 17 FUNDING MODEL San Joaquin County offiCe of eduCation APLES ytnuoC niuqaoJ naS yrammuS noitacollA 21-1102 sdnuF detaleR dna 206BA morf snoitacollA 206BA tibihxE EDC ecnedicnI woL dna slairetaM eraC emoH fo tuO /tsilaicepS margorP buS alumroF lacoL cisaB AEDI noitacudE laicepS diA etatS tnemeltitnE /tnemnoitroppA latoT buS secivreS dezilanoigeR ecnatsissA xaT ytreporP tnempiuqE latoT xxxx 0056 0056 0056 xxxx 0133 0056 0056 ecruoseR 48.357,389,34 67.738,99 00.735,641,2 80.389,439 00.693,208,04 00.996,929,9 00.567,371,2 00.239,896,82 tnuomA woL emoH fo tuO margorP lacoL cisaB AEDI laicepS 0102-ceD 2-P 21-1102 ecnedicnI eraC /tsilaicepS ecnatsissA noitacudE diA etatS tnuoC lipuP ADA rebmeM 00.612,86 00.0 00.0 00.0 00.612,86 00.181,42 00.0 00.530,44 71 20.013 yratnemelE atnaB 00.482,716 00.0 00.0 00.0 00.482,716 00.360,743 00.0 00.122,072 442 45.247,2 deifinU nolacsE 00.297,527 00.0 00.0 00.0 00.297,527 00.571,453 00.0 00.716,173 942 43.254,2 yratnemelE nosreffeJ 00.808,485 00.0 00.0 00.0 00.808,485 00.030,652 00.0 00.877,823 081 06.311,2 tnioJ ellivsremmaL 00.557,624,2 00.0 00.0 00.0 00.557,624,2 00.779,913,1 00.0 00.877,601,1 829 49.935,8 deifinU nlocniL 00.933,716 00.0 00.0 00.0 00.933,716 00.411,104 00.0 00.522,612 282 94.532,2 deifinU nedniL 00.443,711,6 00.0 00.0 00.0 00.443,711,6 00.128,393,3 00.0 00.325,327,2 683,2 30.422,22 deifinU acetnaM 00.460,912 00.0 00.0 00.0 00.460,912 00.163,84 00.0 00.307,071 43 38.312,1 melasureJ weN 00.061,477 00.0 00.0 00.0 00.061,477 00.751,193 00.0 00.300,383 572 96.089,2 yratnemelE nopiR 00.752,396,4 00.0 00.0 00.0 00.752,396,4 00.215,182,2 00.0 00.547,114,2 406,1 52.356,61 deifinU ycarT 00.910,448,61 00.0 00.0 00.0 00.910,448,61 00.193,718,8 00.0 00.826,620,8 00.991,6 37.564,16 latoT buS 00.773,052 00.0 00.0 00.0 773,052 00.0 0 00.773,052 0 11.652,1 ymedacA erutneV ytinummoC/truoC 00.783,752 00.0 00.0 00.0 783,752 00.0 0 00.783,752 0 82.192,1 sloohcS detarepO ytnuoC 00.848,672,12 00.0 00.0 00.0 848,672,12 00.803,211,1 567,371,2 00.577,099,71 287 77.574 smargorP 48.221,553,5 67.738,99 00.735,641,2 80.389,439 567,371,2 00.0 0 00.567,371,2 0 00.0 APLES 48.437,931,72 67.738,99 00.735,641,2 80.389,439 00.773,859,32 00.803,211,1 00.567,371,2 00.403,276,02 00.287 61.320,3 latoT buS 48.357,389,34 67.738,99 00.735,641,2 80.389,439 00.693,208,04 00.996,929,9 00.567,371,2 00.239,896,82 00.189,6 98.884,46 latoT dnarG 00.0 00.0 00.0 00.0 00.0 00.0 00.0 00.0 *ecnereffiD APLES dna EOC 1 latoT buS timiL euneveR CDS tuO srefsnarT APLES notkcotS ecivreS dooF tratS daeH secivreS lipuP 0056 xxxx xxxx xxxx xxxx xxxx detarepO ytnuoC 90.844,126,2 00.084,954,2 )00.712,581( 00.090,621 39.887,04 61.086,24 00.626,731 smargorP 00.0 00.0 00.0 00.0 00.0 00.0 00.0 APLES 90.844,126,2 00.084,954,2 )00.712,581( 00.090,621 39.887,04 61.086,24 00.626,731 latoT buS .secruos gnidnuf emos rof noitacolla nwonknu eht ot eud era secnereffiD* 18 FUNDING MODEL San Joaquin County SELPA Allocation Summary 2011-12 Allocations from Other Sources COE/SELPA Personnel State J-50 Infant AB602 Prior Year IDEA Preschool IDEA Preschool Federal Mental State Mental Health Development for Legal/NPS Claims Other (See Below) Total Entitlement Corrections Grant Entitlement Health Services Services Paid SELPA 6510 6500 3315 3320 3327 6512 6535 6500 xxxx xxxx 228,767.00 108,827.00 296,445.00 743,431.00 785,926.00 2,695,840.00 23,993.00 0.00 3,382,625.09 52,249,607.93 State J-50 AB602 Prior IDEA IDEA Federal State Mental Personnel Legal/NPS Other (See Infant Year Preschool Preschool Mental Health Development Claims Paid Below) Total 0.00 0.00 0.00 0.00 0.00 0.00 46.00 0.00 0.00 68,262.00 0.00 0.00 0.00 0.00 0.00 0.00 664.00 172,343.00 0.00 790,291.00 0.00 0.00 0.00 0.00 0.00 0.00 677.00 85,953.00 0.00 812,422.00 0.00 0.00 0.00 0.00 0.00 0.00 490.00 8,859.00 0.00 594,157.00 0.00 0.00 0.00 0.00 0.00 0.00 2,525.00 209,693.00 0.00 2,638,973.00 0.00 0.00 0.00 0.00 0.00 0.00 767.00 59,000.00 0.00 677,106.00 0.00 0.00 0.00 0.00 0.00 0.00 6,492.00 705,092.00 0.00 6,828,928.00 0.00 0.00 0.00 0.00 0.00 0.00 93.00 0.00 0.00 219,157.00 0.00 0.00 0.00 0.00 0.00 0.00 748.00 231,693.00 0.00 1,006,601.00 0.00 0.00 0.00 0.00 0.00 0.00 4,363.00 433,694.00 0.00 5,131,314.00 0.00 0.00 0.00 0.00 0.00 0.00 16,865.00 1,906,327.00 0.00 18,767,211.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 250,377.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 257,387.00 228,767.00 0.00 0.00 0.00 0.00 0.00 2,128.00 0.00 2,713,006.09 24,220,749.09 0.00 0.00 0.00 0.00 0.00 0.00 5,000.00 (1,906,327.00) 669,619.00 4,123,414.84 228,767.00 0.00 0.00 0.00 0.00 0.00 7,128.00 (1,906,327.00) 3,382,625.09 28,851,927.93 228,767.00 0.00 0.00 0.00 0.00 0.00 23,993.00 0.00 3,382,625.09 47,619,138.93 0.00 108,827.00 296,445.00 743,431.00 785,926.00 2,695,840.00 0.00 0.00 0.00 4,630,469.00 COE and SELPA Alternative Low Pre-K Staff Dispute Infant Incidence Development Resolution Discretionary Services Grant Infant Part C Grant Grant Grant Transportation 3345 3385 3395 6515 6530 7240 Sub Total 2 0.00 91,558.00 0.00 0.00 0.00 0.00 91,558.00 3,654.00 0.00 15,000.00 3,760.00 12,075.00 635,130.00 669,619.00 3,654.00 91,558.00 15,000.00 3,760.00 12,075.00 635,130.00 761,177.00 The tables above offer a snapshot of the total funds allocated to each LEA, including the San Joaquin COE-operated programs and the SELPA. Although it is not part of the AB 602 funding calculation, the local assistance entitlement was included because it is part of the total fund. The state mental health allocation to the LEAs of $1,800,796 was provided; however, the information did not specify how it would be allocated to each of the member LEAs. Medi-Cal Administrative Activities funding was not included because it fluctuates from year to year. Allocating resources based on reported ADA or numbers of pupils served in the prior year may not be equitable. Funding methods should ensure that programs and services are available to meet the needs of all students in the San Joaquin County SELPA. Demographic, geographic, and socioeconomic factors may warrant an increase to some districts to ensure equitability. One option is to set aside a small amount of funds to help any district, small or large, with extraor- Fiscal crisis & ManageMent assistance teaM 19 FUNDING MODEL dinary costs. However, extraordinary costs should be carefully defined and criteria developed to prevent overuse of this funding. District staff reported that many requests for nonpublic school (NPS) funds are approved prior to exhausting all SELPA programs and resources. The SELPA reimburses districts for 70% of the costs for nonpublic school placements determined by the district. This creates an incentive for excessive placements and/or eliminates viable options in the least restrictive environment. The funds provided by the AB 602 funding plan for students placed in group homes, foster homes, and other similar facilities (out of home care funds) is used to pay for NPS placements. The districts reported concerns that not all NPS/NPA (nonpublic agency) placements are warranted and that some of these students may be appropriately served by county-operated programs. A clear distinction is needed of the roles and responsibilities of the SELPA and of the San Joaquin COE special education department. The terms “county office program” and “SELPA program” are often used interchangeably. This often occurs when one administrator is responsible for both the SELPA and county-operated special education programs. Having a single administrator is efficient and effective, but it is important to continually reinforce that the SELPA and the special education department provide distinctly different programs, services, and supports. It also is important to distinguish that the SELPA receives and distributes funding, including AB 602 funds, and the special education department is an LEA and recipient of those funds similarly to the member LEAs. Recommendations The county SELPA should: 1. Consider modifying the fiscal information provided to program staff to increase understanding. 2. Continue to ensure that fiscal information is presented to member LEAs with a comprehensive explanation of the effect on individual districts and the SELPA as a whole. 3. Continue to ensure that member LEAs receive ongoing education regarding the SELPA funding allocation method. 4. Consider modifying the AB 602 funding allocation method to be based on ADA. 5. Consider a two- to three-year implementation phase-in if the funding alloca- tion method is revised. 6. Develop a reporting mechanism for revenue sources that are not included in the allocation model so that SELPA member districts can clearly understand these sources and how they are used and expended. 7. Consider establishing a small fund to assist districts that may incur extraordi- nary costs because of demographic, geographic, or socioeconomic factors. San Joaquin County offiCe of eduCation 20 FUNDING MODEL 8. Ensure that all NPS/NPA placements are warranted and that districts have first exhausted all county-operated programs and resources. It should be noted that districts make these placements, not the county office. 9. The SELPA should consider adopting a policy that states only claims for NPS/NPA costs for contracts pre-approved by the SELPA will be considered for reimbursement. 10. Consider preparing and disseminating a packet in a format that distinguishes the SELPA from county-operated programs so it is easily understood by board members, superintendents, principals, district and county business offices, transportation departments and special education offices. 11. Develop new letterhead that identifies the San Joaquin COE and SELPA and includes the names of the county superintendent and the SELPA director to help clarify their respective roles. Fiscal crisis & ManageMent assistance teaM 21 FISCAL ANALYSIS Fiscal Analysis Direct and Indirect Costs The San Joaquin COE charges the state approved indirect cost rate for services that are not directly charged to individual programs. These services include payroll, personnel, workers’ compensation, finance and accounting, accounts payable, facilities management, collective bargaining, and information technology. The 2012-13 maximum indirect cost rate allowable for the county office is 9.66% of total expenditures in any program that doesn’t specifically limit the allowable indirect costs. (See Appendix B, Indirect Cost Rates). The purpose of the indirect cost rate as described in the California School Accounting Manual, published by the California Department of Education is as follows: Indirect costs consist of agency wide business and administrative costs such as accounting, budgeting, personnel, purchasing, and centralized data processing. The standardized method for charging indirect costs to programs is the indirect cost rate (see Procedure 915 of the California School Accounting Manual). Direct costs charged to special education are limited to only those costs directly associated with each program. Positions directly charged to special education include account specialist, adminis- trative assistant, assistant superintendent, attendance technician, coordinator II (4), coordinator IV (3), director II, division director, executive assistant, food service program assistant, health care assistant, human resources tech II, licensed vocational nurse, maintenance worker, program manager I, program manager III, program support specialist, project liaison II, staff secretary, and technical support specialist. A 2100 Standardized Account Code Structure (SACS) function code was used for these posi- tions. As described in the excerpt from the California School Accounting Manual below, instruc- tional supervision and administration is properly classified in that function. 1000–1999 INSTRUCTION 1000 Instruction Instruction for Other Than Special Education—Locally defined (When reporting data to CDE, LEAs must roll up 1001–1099 these functions to Function 1000.) 1100–1199 Special Education Instruction 1110 Special Education: Separate Classes 1120 Special Education: Resource Specialist Instruction 1130 Special Education: Supplemental Aids and Services in Regular Classrooms 1180 Special Education: Nonpublic Agencies/Schools (NPA/S) 1190 Special Education: Other Specialized Instructional Services 2000–2999 INSTRUCTION-RELATED SERVICES 2100 Instructional Supervision and Administration 2110 Instructional Supervision 2120 Instructional Research 2130 Curriculum Development 2140 In-house Instructional Staff Development 2150 Instructional Administration of Special Projects 2200 Administrative Unit (AU) of a Multidistrict SELPA 2420 Instructional Library, Media, and Technology San Joaquin County offiCe of eduCation 22 FISCAL ANALYSIS 2490 Other Instructional Resources 2495 Parent Participation 2700 School Administration Identifying costs associated with specific programs was difficult because several nonstandardized discretionary codes were used in the account code structure. The county office assigns manage- ment codes and school codes to identify various levels of each program on both the expense and revenue accounts. This makes it cumbersome for the lay person to become familiar with the structure and to understand the funding. The county office reported that management code information is intended for internal use in operating its programs and is not distributed to the districts. Summary reports based on SACS data for revenues and expenditures are distributed to the districts and are reviewed with them throughout the year. Recommendations The county office should: 1. Identify the indirect costs charged to programs in each report provided to districts. 2. Identify the specific positions charged to individual programs and standardize the accounting. 3. Consider consolidating the use of the management and school codes in the account code structure for ease of understanding. Construction and Deferred Maintenance The SJCOE owns several facilities and has provided facilities to school district sites. Although the flexibility provisions of AB 825 allow the use of deferred maintenance funds for any educational purpose, the county office has elected to maintain the funds for their intended use. The county office was under no obligation to continue past practice once the funds were flexed. The county office also continues to fund the district match as it did prior to any flexibility. Funds are trans- ferred to the resource code designated for this purpose from the unrestricted general fund. This helps to avoid large or unexpected expenditures in any one year. Deferred maintenance funds are accounted for with an identifying resource code in the unre- stricted general fund. Within the resource code, the county office uses its management code system to account for each program area that is allocated these funds. The county office allocates these funds to county office needs, alternative education sites and special education sites. The beginning balance in this resource for 2012-13 was $514,486.50, and the anticipated ending balance for deferred maintenance is anticipated to be $510,386.50 on June 30, 2013, provided there are no emergency needs. The total resources available including current year apportionments are $828,469.50, and current year expenditures are budgeted to be $318,083. The county office has accessed state financial hardship funds for several building projects that did not require any matching funds. On completion of these projects, the county office gained Fiscal crisis & ManageMent assistance teaM 23 FISCAL ANALYSIS approval to use any excess funds for future projects. These funds were used for a recent 50% match requirement for the Colonial Heights School in the Lincoln USD. No charges were made to the districts for any of these building projects. Salary Comparisons FCMAT used the same county offices for the comparison in this section as were used in other sections of the report. The San Joaquin COE salary costs are somewhat higher than the other county offices. Because each county has a different work year for its teachers, a daily rate column was included in the comparison. This better represents the real cost than using the annual salary. All county offices used in the comparison have health benefit caps of some type. Salaries for Comparable Size County Offices BA + Daily BA + Daily BA + Daily Masters Health Cred. Rate Cred. Rate Cred. Rate Stipend Benefits Step 1 + 45 + 75 Units Units Step 8 Last Step Fresno COE 42,441 231.92 52,942 289.30 70,764 386.69 600 $891.67/mo. cap (183 days) Monterey COE 42,615 232.87 59,429 324.75 73,870 403.66 950 Caps at each plan (183 days) level Placer COE 39,055 211.11 56,272 304.17 74,389 402.10 800 $730/mo. cap (185 days) San Joaquin 40,308 226.45 54,458 305.94 76,068 427.35 1,500 $762.09/mo. cap COE (178 days) Sonoma COE 40,232 227.30 53,864 304.32 74,297 419.76 500 COE pays 85% of (177 days) premiums Recommendation The county office should: 1. Ensure that member districts know that the San Joaquin COE has competi- tive salaries and benefits. Make these comparisons annually to ensure that the county remains competitive. Teacher Salary and Benefit Comparison FCMAT was asked to review and analyze the San Joaquin COE teacher salary and benefits costs relative to the districts that the SELPA serves, except for Banta Elementary, New Hope and Oak View. Lodi and Stockton are not part of the San Joaquin County SELPA; however, they were included in the comparison because they are located in the same region as the San Joaquin COE. The table below is a summary of district/county office teacher salary/benefits and includes the teacher FTEs and total duty days for each. San Joaquin County offiCe of eduCation 24 FISCAL ANALYSIS Teacher Salary/Benefits Cost Comparison Total Salary + District Teacher FTE Benefits COST/FTE No. of Duty Days Lincoln 35.90 $3,294,930 $91,780 180/182 Manteca 107.30 $8,878,276 $82,742 180 Tracy 76.60 $6,099,980 $79,634 183 SJCOE 67.00 $5,232,908.87 $78,103 178 Escalon 15.02 $1,119,628 $74,542 177 Linden 10.00 $723,561 $72,356 178 Ripon 8.00 $577,158 $72,144 175 New Jerusalem 3.25 $229,673 $70,668 184 Lammersville 9.10 $632,108 $69,462 183 Jefferson 10.90 $688,080 $63,126 182 Lodi Area 172.87 $13,386,208 $77,435 175 Stockton Unified 195.60 $16,965,860 $86,737 183 Note: The data contained in this table was obtained directly from the respective districts and COE listed. The number of teacher duty days ranges from a low of 175 in Ripon Unified to a high of 184 in New Jerusalem, with the average for all districts and the San Joaquin COE at 180. San Joaquin COE teachers are assigned 178 duty days, which is consistent with the average. The lowest average cost of salary and benefits per FTE is $63,126 in Jefferson Elementary and the highest is $91,780 in Lincoln Unified. The average cost of salary and benefits for all districts in the San Joaquin County SELPA is $75,161, and the San Joaquin COE average is $78,103. The San Joaquin COE average is comparable to the districts in the SELPA. The median average cost of salary and benefits of the nine districts in the San Joaquin County SELPA is $72,356. San Joaquin COE average salary and benefits are slightly higher than the median average of the nine districts. Lodi Area and Stockton Unified are not part of the San Joaquin County SELPA; each is a sepa- rate SELPA in San Joaquin County. The average salary and benefits costs per teacher in Lodi Area is $77,435; in Stockton Unified it is $86,737. San Joaquin COE average salary and benefits are comparable to that of both Lodi Area and Stockton Unified. Teacher Salary Step and Column Comparison FCMAT reviewed the San Joaquin COE teacher salary step and column relative to the districts that the SELPA serves, except for New Hope and Oak View. Lodi Unified, Stockton Unified, and Stanislaus County Office of Education are not part of the San Joaquin County SELPA; however, they were included in the comparison because they have similar demographics. The table below is a summary of district/county office teacher salary step and column for steps one, eight, 10, and the final step, and includes the number of work days for teachers in each district and county office and the daily rate for each step. It also includes the available stipends, where applicable, and health benefit caps. Fiscal crisis & ManageMent assistance teaM 25 FISCAL ANALYSIS District/COE Salary Step/Column Comparison BA BA BA Health District/ Days Daily Daily Daily Final Daily MA + 30, + 45, + 60, Benefit COE Worked Rate Rate Rate Step Rate Stipend Step 1 Step 8 Step 10 Cap $800 < 75 Banta 183 $38,169 $209 $46,634. $255 $57,910 $316 $71,569 $391 units; $1,200 $10,008 w/ 75 units Escalon * ** 177 $40,049 $226 $50,904 $288 $55,968 $316 $75,820 $428 $0 $7,440 $1,200 Jefferson 182 $40,843 $224 $54,159 $298 $59,456 $327 $72,778 $400 MA before $10,000 75 units Lammersville 183 $40,751 $223 $52,892 $289 $58,107 $318 $71,634 $391 $1,800 $10,752 $1,000 MA; Lincoln 183 $41,390 $226 $52,168 $285 $58,245 $318 $77,393 $423 N/A $1,000 Sp Ed $1,700 MA; Linden 178 $40,413 $227 $50,177 $282 $56,460 $317 $71,575 $402 $7,163 $1,584 Sp Ed $8,609 - Lodi 175 $40,301 $230 $50,932 $291 $56,008 $320 $76,129 $435 $1,000 $20,466 Manteca ** 180 $42,685 $237 $53,876 $299 $60,950 $339 $79,027 $439 $0 $8,287 New 184 $39,772 $216 $46,988 $255 $51,355 $279 $74,735 $406 $500 $10,200 Jerusalem $5,934 - Ripon * ** 177 $40,544 $229 $49,946 $282 $54,801 $310 $74,143 $419 $0 $9,078 $1,456 MA; Stockton 183 $40,532 $221 $52,456 $287 $59,951 $328 $75,526 $413 $13,770 $1,237 Sp Ed $1,623 MA; Tracy 183 $43,975 $240 $55,874 $305 $61,913 $338 $81,401 $445 $8,482 $1,623 Sp Ed $1,500 Sp San Joaquin Ed 178 $42,111 $237 $54,458 $306 $59,776 $336 $78,348 $440 $9,145 COE $1,700 LSH Stanislaus 182 $44,639 $245 $60,876 $334 $67,963 $373 $94,672 $520 $1,000 $14,360 COE Average 181 $41,155 $228 $52,310 $290 $58,490 $324 $76,768 $425 * BA = 36/48 not 30/45 ** MA built into column Source: District-provided data / EdData.org In the comparison, the number of teacher work days ranges from a low of 175 in Lodi to a high of 184 in New Jerusalem, with the average across districts and county offices at 181. San Joaquin COE teachers work 178 days, which is three days less than the average. A comparison within each salary step is made using the district-provided data and EdData.org data. For the Step 1 salary per full-time teacher, the lowest is $37,623 with a daily rate of $206 in Linden, and the highest is $44,639 with a daily rate of $245 in Stanislaus COE. The average Step 1 salary is $40,999 with an average daily rate of $224. The San Joaquin COE Step 1 salary is $41,876 with a daily rate of $229. The San Joaquin COE Step 1 salary is higher than the average salary and daily rate of districts and COEs used in this comparison. New Jerusalem has the lowest Step 8 salary at $46,988 with a daily rate of $257. Stanislaus COE has the highest Step 8 salary at $60,876 with a daily rate of $334. The average Step 8 salary is San Joaquin County offiCe of eduCation 26 FISCAL ANALYSIS $52,806 with an average daily rate of $268. San Joaquin COE’s Step 8 salary is $54,154 with a daily rate of $296, which is higher than the average salary and daily rate for districts and COEs in this comparison. Salary data shows that New Jerusalem has the lowest Step 10 salary at $51,355 and a daily rate of $281. Stanislaus COE has the highest Step 10 salary at $66,963, with a daily rate of $368. The average Step 10 salary is $58,479 with an average daily rate of $320. San Joaquin COE’s Step 10 salary is $59,442 and the daily rate is $325. The San Joaquin COE Step 10 salary is higher than the district and county office average salary and daily rate. The final step salary comparison shows Linden has the lowest final salary of $71,575 with a daily rate of $391. Stanislaus COE has the highest final step salary of $94,672 with a daily rate of $520. The average final step salary is $76,843 with an average daily rate of $420. The San Joaquin COE final step salary is $77,910 with a daily rate of $426, which is higher than the average salary and daily rate. Most districts and county offices provide a stipend for teachers who have a master’s degree. Stipends range from a low of $500 in New Jerusalem to a high of $1,800 in Lammersville. San Joaquin COE provides a master’s stipend of $1,500 and an additional stipend of $1,700 for special education teachers. The practice of providing special education teachers an additional stipend is common among county offices of education, whose teachers are required to serve the most severely disabled population of students and are often required to provide services at distant school sites. The average master’s stipend for area districts and county offices is $1,278. The master’s stipend provided by San Joaquin COE is higher than the average stipends provided by districts and COEs in this comparison. The average health benefit cap is $10,259. The health benefit cap for San Joaquin COE is $9,145. Recommendation The county office should: 1. Continue to utilize this data to support future budgetary planning and decision-making. Comparative Analysis of COE Programs FCMAT was asked to compare the total costs of special education programs operated by the San Joaquin COE to the total costs of like programs operated by other SELPAs. FCMAT asked each of the identified counties to provide their total costs to operate programs. Lincoln USD is concerned that an excessive amount of state aid may be used to support programs that are not entirely efficient. All of the funding from state aid and federal assistance used to operate these programs goes to the San Joaquin COE before allocation to the districts (off the top), which precludes any excess funding from being available for the districts to help pay the excess costs of special education programs they operate. The district and COE should meet annually to discuss this concept and potential funding plans that would benefit the districts if any excess funds exist. Lincoln USD has 87 students placed in county-operated programs. Of these, 31 are in autism, three are in deaf and hard of hearing, one is in an autism spectrum class, 12 are in emotionally disturbed, and 40 are in orthopedically handicapped or severely handicapped programs. San Fiscal crisis & ManageMent assistance teaM 27 FISCAL ANALYSIS Joaquin COE operates five classes in Lincoln USD. The county office serves students with more severe and pervasive needs, requiring labor-intensive services. The total cost of these programs is comparable to other counties of similar size. The district should analyze the potential cost of delivering those services to determine if it can deliver the same quality of service in a more cost- efficient model. The table below indicates the counties that are similar in size to San Joaquin County SELPA and provides their approximate total costs to operate special education programs. County Program Cost Comparison County Office of Education Total Cost to Operate County Programs Fresno County $22,757,000 Monterey County $35,000,000 Placer County $20,000,000 San Joaquin County $22,468,815 Sonoma County $22,332,600 Note: Costs to operate county programs provided by COEs are approximations. Recommendations The county SELPA should: 1. Analyze the costs to operate specific special education programs as compared to other county offices. 2. Determine whether increased efficiencies could be gained in any of its programs. Revenue Resources FCMAT was asked to review the revenue sources for special education programs and services that are not included in the SELPA Allocation Plan. An allocation plan is required for all multidistrict SELPAs. The member districts determine the specifics of the plan based on the SELPA’s unique needs. For example, some SELPAs include the out-of-home and mental health funding in their base allocations to districts, and others do not. The revenue streams that are not in the base allocation include (1) revenues received to operate the SELPA such as regionalized services and program specialist funds; (2) revenues received by the SELPA and distributed to districts such as low incidence, out-of-home and preschool; and (3) revenues received by the San Joaquin COE for county office programs such as infant and Medi-Cal. A county office document titled Special Education Analysis Restricted and Designated Program 2012-13 First Interim Financial Report includes all three types of funding streams, specifying where the funds originate and how they are allocated. The document does not clearly differen- tiate the three types of revenue streams described above. This may lead to confusion and misun- derstandings about the funding received by the SELPA, the districts and the county office, and why certain funds are not included in the SELPA’s allocation to the districts. San Joaquin County offiCe of eduCation 28 FISCAL ANALYSIS The following tables show how funding is distributed. The data is from the interim financial report and the Fund 10 report, with clarification provided by SELPA and county office staff. The resource amounts are estimates from projected revenues. The tables demonstrate one way to distribute this information to the member districts that may help clarify why certain funds are not included in the allocation. SELPA Funding that Stays in the SELPA Fund Description Source How Funds Expended Amount Program Specialist Federal Grant Salaries/Benefits $24,665 Program Specialist Based on ADA Retiree Contracts/Salaries/ $727,335 Benefits/Office Expenses Regionalized Services Based on ADA Salaries/Benefits/Office $788,079 Expenses In-service Administration Workshop Generated Presenters/Materials $107,591 Positive Environment Network Workshop Generated Presenters/Materials $24,730 of Trainers (PENT) Winter Symposium Workshop Generated Presenters/Materials $43,353 Autism Forum Workshop Generated Presenters/Materials $13,677 Positive Behavioral Supports Workshop Generated Presenters/Materials $2,400 WorkAbility State WorkAbility Travel/Conference $3,398 Committee Alternative Dispute Resolution One time money from Presenters/Materials $20,158 Conference State ADR Preschool 94-142 Federal Grant Travel/Conferences $3,654 Alternative Dispute Resolution Federal Grant Retiree Contracts/ADR $15,000 (ADR) Conference Medi-Cal Administrative SELPA generated Assistive Technology Supplies $32,479 Activities (MAA) Fiscal crisis & ManageMent assistance teaM 29 FISCAL ANALYSIS Funds Received by SELPA and Distributed to Districts and County Office Fund Description Source How Funds Expended Amount Preschool Non-Rise Federal Grant Salaries/Benefits $743,431 Preschool Non-Rise Federal Grant Salaries/Benefits $271,780 Mental Health Part B Federal Grant Regional Mental Health Services $785,926 Mental Health Part B Carryover Federal Grant Board and Care $350,116 Low Incidence State Specific Funding Low Incidence Equipment $141,420 Out-Of-Home State Specific Funding 70/30 split for Nonpublic Schools $3,608,163 and Agencies Mental Health State Apportionment Contracts for Services and staff $2,676,744 based on ADA development Mental Health Charter School State Apportionment Mental Health Services $19,345 (Venture) WorkAbility State Grant Salaries/Materials $290,018 Low Incidence State Grant Low Incidence Services $12,401 Staff Development 94-142 State Grant Conferences $23,993 Funds Received by County Office for County Office Programs Fund Description Source How Funds Expended Amount Infant Part C State Allocation Salaries/Materials $91,558 Language Acquisition SJCOE Multilingual Department Training/Materials $5,655 Lottery - Restricted State Funding Instructional Materials $107,682 Designated Instructional Contracts with Districts Occupational Therapist Salaries $129,267 Services Infant Discretionary State Grant Materials/Supplies $3,760 Medi-Cal SJCOE Reimbursement Salaries/Materials $347,544 Medi-Cal Administrative SJCOE Reimbursement Salaries/Benefits/Materials $153,507 Activities Tire Grant Grant Repairs $115,470 Seratoma Grant Grant Materials/Supplies $1,195 PG&E Grant Grant Materials/Supplies $9,934 Oral Health Assessment State Categorical Materials/Supplies $328 Peer Assistance Review State Categorical Materials/Supplies $5,451 Math/Reading Professional State Categorical Materials/Supplies $7,383 Development State Development Buyback State Categorical Materials/Supplies $56,185 Library Act State Categorical Materials/Supplies $277 Carl Washington State Categorical Materials/Supplies $3,219 San Joaquin County offiCe of eduCation 30 FISCAL ANALYSIS Fund Description Source How Funds Expended Amount California High School Exit State Categorical Materials/Supplies $4,821 Exam Instructional Materials State Categorical Materials/Supplies $96,151 Arts and Music Block Grant State Categorical Materials/Supplies $6,007 Lottery - Unrestricted State Funds Materials/Supplies $95,656 Recommendations The county SELPA should: 1. Develop a method of providing separate information for all funding streams to clarify why some funds are not included in the LEA allocation. Nonmandated Services SELPA, county office and district staff have varying perceptions regarding the nonmandated services provided to students in county office programs. Some staff stated a belief that students may receive services not included in Education Code 56363. FCMAT reviewed the services provided to San Joaquin COE students as shown in the Special Education Information System (SEIS). All related services provided to San Joaquin COE students are included in this code. A perception was expressed by both district and San Joaquin COE staff that some students in San Joaquin COE special day classes from smaller districts would not be in those classes if they were from one of the larger districts. The concerns were that the students did not qualify for San Joaquin COE services but received them because the smaller district did not have an appropriate program, and that these students took slots that should be filled by students from the larger districts. FCMAT reviewed the document Students Served in County Program by District and Disability, dated 9-14-12, which is distributed to the SELPA member districts yearly. This document shows the percentage of each district’s ADA in the SELPA compared to the percentage of students in the San Joaquin COE classes. It does not include speech and hearing students. Percentage ADA vs. Percentage of Students in SJCOE Programs District Percentage ADA Percentage in SJCOE One 0.48 0.31 Two 4.28 3.89 Three 3.82 3.73 Four 13.31 12.91 Five 3.48 3.42 Six 34.65 38.41 Seven 1.89 0.00 Eight 4.65 4.98 Fiscal crisis & ManageMent assistance teaM 31 FISCAL ANALYSIS District Percentage ADA Percentage in SJCOE Nine 25.96 28.46 Ten 4.28 0.00 Two of the three largest districts have a higher percentage of students in the San Joaquin COE programs than in the SELPA. Only one of the seven smaller districts has a higher percentage of students in the SJCOE programs than in the SELPA. Although a few students from the smaller districts in the SJCOE program might not have been referred by the larger districts, the data does not support the perception that the smaller districts are taking places that would be available to the larger districts. Another perception of nonmandated services is that the staffing provided in the San Joaquin COE classes, teacher and aides, and the related services caseloads is above the required or recom- mended level. However, the San Joaquin COE classes and related services are within the required or recommended levels, as discussed earlier in this report. The last perception is that even though staffing levels are appropriate, more students receive related services than would be expected. All related services that students receive are listed on their individualized education program (IEP). However, both district and San Joaquin COE staff reported that although districts are regularly invited to all of their students’ IEPs, district staff do not regularly attend. In some cases, the district staff may not have observed the student in several years and therefore is unable to determine if the related services are needed. They may assume the services are excessive or may not even realize that their students are receiving related services. No state standards or best practices exist to measure the level of related services provided in the San Joaquin COE classes. However, to better understand why this may be of concern to the districts, the most common related services provided to the students in 61 SDC classes, preschool through adult, were reviewed in the SEIS. There are 589 students in these 61 classes. Of these, 464 (78.8%) receive speech and language services, 211 (35.8%) receive occupational therapy services, and 71 (12%) receive adaptive physical education. Recommendations The county office should: 1. Continue providing each district’s percentage of students in the SELPA with their percentage in SJCOE classes on a yearly basis. 2. Continue to invite and encourage district staff to attend IEP meetings and to visit their students’ classes to increase their understanding of San Joaquin COE programs and services. 3. Develop a format to provide each district with a list, by class, of their students that attend San Joaquin COE programs, including the related services that each student receives. San Joaquin County offiCe of eduCation 32 FISCAL ANALYSIS Legal Expenses Education Code 56501 covers due process hearing procedures. The San Joaquin County SELPA’s legal costs for due process were compared to SELPAs of similar size: Monterey, Placer and Sonoma. The average expense for due process for these SELPAs in 2011-12 was $41,600. The average expense for San Joaquin County during 2011-12 was $11,000. In any given year, one due process filing can significantly affect these expenditures. Due Process in Comparable Size SELPAs SELPA Legal Costs 2011-12 Monterey $125,000 Placer $10,000 SJCOE $11,000 Sonoma $60,000 The San Joaquin SELPA has successfully contained legal costs for due process through proactive use of alternative dispute resolution strategies to facilitate contentious IEP meetings. FCMAT found a strong commitment to staff development for the facilitated IEP process, which has proved highly successful for resolving disputes at the lowest level. In addition, administrators are trained in defensible IEPs, random file reviews to determine training needs, and filing for media- tion. Recommendation The SELPA should: 1. Maintain proactive efforts to institute alternative dispute resolution strategies to resolve due process differences. Fiscal crisis & ManageMent assistance teaM 33 FISCAL EFFECT IF LINCOLN USD WITHDRAWS FROM SELPA Fiscal Effect if Lincoln USD Withdraws from SELPA Lincoln Unified had 86 students in county-operated programs at the time of this study. The table below indicates the disability type and grade level of students served by San Joaquin COE. Also included are the itinerant deaf and hard of hearing and visually impaired designated instructional services (DIS). Lincoln USD Students Served in County Program Program Level # LUSD 1:1 Support Extra Students Support Autism Pre-K 15 2 K-3 13 1 4-8 2 1 9-12 1 Autism Total 31 4 Deaf & Hard of Hearing (DHH) K-3 2 9-12 1 DHH Total 3 ASC 7-12 1 1 Emotionally Disturbed (ED) K-3 4 1 4-6 2 7-12 6 ED Total 12 1 Orthopedically Handicapped/ K-8 1 Severely Handicapped (OH/ 9-12 1 SH) OH/SH Total 2 Severely Handicapped (SH) K-8 2 K-4 9 1 4-8 13 1 1 9-12 3 1 Young Adult 11 1 SH Total 38 3 2 Total Placement 86 3 8 Note: Itinerant Designated Instructional Services (DIS): Teacher of Visually Impaired (5 students), Teacher of Deaf and Hard of Hearing (11 students) If Lincoln decides to withdraw from the SELPA it will pull away a higher base rate and all districts will lose funding. All funding the other districts receive from AB 602 will decrease. The table below demonstrates the negative effect on the other member districts. San Joaquin County offiCe of eduCation 34 FISCAL EFFECT IF LINCOLN USD WITHDRAWS FROM SELPA Funding loss is estimated at $6.05 million, mostly from AB 602. The acquiring SELPA may not be funded at the same rate. If ADA from all other member LEAs remained the same, the ADA loss of approximately 8,539.94 from Lincoln Unified would create a declining ADA adjustment of $5,402,368. This is the base rate of $632.60 times the ADA loss. CDE calculates declining ADA using the SELPA’s total ADA for (a) current year, (b) prior year, and (c) prior prior year (two years ago). The CDE Exhibit formula subtracts the greater of either the prior or prior prior year ADA from the greater of either the prior or current year ADA. All three federal funding sources for basic local assistance and preschool would also decrease, because the 1999 base funding, the enrollment, and the free and reduced price meal counts attributed to Lincoln Unified would go to the new SELPA. However, the inverse funding rela- tionship with AB 602 and the federal IDEA basic local assistance and special education property tax funds means any loss in federal or property tax amounts will increase AB 602 funding. However, this will not occur with the two federal preschool funding sources. Program specialist/regionalized services funding also is estimated to decrease. The 2012-13 funding was $14.50 per ADA, which totals $123,815.12 for Lincoln Unified. Low incidence materials and equipment is funded by the prior year pupil count for low incidence. At a rate of $327.09, the estimated loss is over $11,000. County-operated special education programs would also experience a loss in the SDC revenue limit transfer. The amount received in 2011-12 for Lincoln ADA was $372,330.46. Out of home care is funded based on an April bed count. San Joaquin County SELPA received at least $67,950 in out of home care funds from bed counts for Lincoln Unified. However, this does not include beds at foster family homes, small family homes, and foster family agencies, because the data is not available on the CDE website. Mental health funds will decrease because of the loss of ADA and CASEMIS count. The state mental health allocation for 2012-13 was based on $29.13575239 per ADA. Lincoln’s ADA of 8,539.94 provides $248,817.58 of the total funding. In 2012-13, CDE divided the federal IDEA mental health funds into two grant awards: one based on CASEMIS data and one based on ADA. The ADA-based federal mental health funding for 2012-13 was at a rate of $2.88, with $24,595.03 due to Lincoln Unified. Grants such as low incidence services, personnel development, infant discretionary and pre- kindergarten staff development will be affected by the loss of either ADA or pupil count. The table below indicates the estimated losses if Lincoln Unified withdraws from the SELPA. Fiscal crisis & ManageMent assistance teaM 35 FISCAL EFFECT IF LINCOLN USD WITHDRAWS FROM SELPA Funding Loss if Lincoln USD Withdraws from SELPA Entitlement or Grant Funded by 2012-13 Rate Lincoln 2011-12 Data Estimated Funding Drop AB602 for Declining ADA Adjustment ADA Formula 632.6002200870 8,539.94 ($5,402,367.92) Program Specialist/Regionalized Services ADA Formula 14.4983590751 8,539.94 ($123,815.12) Low Incidence Materials and Equipment PY Dec Pupil Count 327.0926201090 34 ($11,121.15) SDC Revenue Limit Transfer ADA Formula 4,977.68 74.80 ($372,330.46) Out of Home Care Bed Count Varies 8 identified beds ($67,950.00) State Mental Health ADA Formula 29.13575239 8,539.94 ($248,817.58) Federal Mental Health-1 CASEMIS Formula Varies Not Available Unknown, To be determined Federal Mental Health-2 ADA Formula 2.88 8,539.94 ($24,595.03) 1999 Base Funding with 85%/15% IDEA Basic from enrollment and free/reduced Unknown Not Available Unknown, To be determined counts 1999 Base Funding with 85%/15% IDEA Preschool Grant from enrollment and free/reduced Unknown Not Available Unknown, To be determined counts 1999 Base Funding with 85%/15% IDEA Preschool Entitlement from enrollment and free/reduced Unknown Not Available Unknown, To be determined counts Sp Ed Property Tax Formula Unknown Unknown Unknown, To be determined J-50 Infant IPS Units 0 No IPS Units $0.00 Prior Year Corrections R3 less R1, and R1 less P2 0 Not Available Unknown, To be determined Legal/NPS Claims Approved Claims from Members Claims Claims $209,693.00 Pre-K Staff Dev PY Dec Pup Count 3-5 Not listed on CDE website Unknown Unknown, To be determined Infant Part C Specific Cost Impacts Unknown Unknown Unknown, To be determined Alternative Dispute Resolution flat amount n/a n/a n/a Unanticipated direct service impacts of Infant Discretionary transitioning to the new Part C Unknown Unknown Unknown, To be determined Low Incidence Services Base plus per student Unknown Unknown Unknown, To be determined Personnel Development PY Dec Pupil Count 6-21 4.33 928 ($4,018.24) Transportation Base Funding plus COLA, etc. Unknown Unknown Unknown, To be determined ($6,045,322.50) 1Does not include Foster Family Home, Small Family Home, and Foster Family Agency. Data not available on CDE website. 2Claim paid in 2011-12 The classes that Lincoln students are placed in are regionalized and include students from other districts in the SELPA. If Lincoln withdraws from the SELPA and removes its students from county-operated classes, some of those classes will need to be collapsed. A lower number of students in many county-operated classes will increase the per pupil cost to districts, and the remaining SELPA districts will be required to pay the increased cost. As indicated in the above table, the estimated fiscal impact is $6,045,322.50. However, if the county is able to reduce staff and collapse classes at an estimated $1,042,553; the overall loss is expected to be $5,002,769.50. The San Joaquin COE provided the following information on the impact to districts if Lincoln withdraws from the SELPA, including the staff reductions and their respective approximate cost to county-operated programs. San Joaquin County offiCe of eduCation 36 FISCAL EFFECT IF LINCOLN USD WITHDRAWS FROM SELPA Staff Reduction if Lincoln Unified Withdraws from SELPA Staff Position FTE Annual Salary & Benefits Teacher 3.0 $243,942 Instructional Assistant 7 $218,268 Speech Therapist .40 $33,203 Behavior Intervention Specialist (BIS) .20 $21,101 Occupational Therapist .20 $23,047 Extra Support 8 1:1 Instructional Assistant 3 $342,992 EIBT 5 $160,000 TOTAL $1,042,553 The county office owns several facilities and has provided some sites for school district use. Although the flexibility provisions of AB 825 allow the use of deferred maintenance funds for “any educational purpose,” the county office has elected to maintain the intended use of these funds. Deferred maintenance funds are accounted for with a resource code in the unrestricted general fund. The county office allocates these funds to county office needs, alternative education sites, special education sites, and special education. However, there is no obligation to do so with current flexibility provisions. The table below indicates the impact to facilities if the withdrawal occurs; i.e., they will no longer be supported by deferred maintenance funds. Facilities Impact Facility Type Quantity 960 sq. ft. classrooms including kitchen/bathroom/office 3 1440 sq. ft. portable @ Sierra Middle 1 960 sq. ft. portable @ Sierra Middle 1 Recommendations The county SELPA should: 1. Ensure that Lincoln USD understands the number and severity of the students served by the San Joaquin COE. 2. Ensure that all member LEAs clearly understand the fiscal impact on the SELPA if Lincoln USD decides to withdraw. 3. Determine how the SELPA will adjust to the decreased funding if Lincoln USD withdraws from the SELPA. 4. Meet with the member districts to discuss the fiscal impact on services and programs. 5. Determine how the county office facilities located in Lincoln USD will be handled. Fiscal crisis & ManageMent assistance teaM 3377 APPENDDRICAEFST Appendices Appendix A - Distribution of Special Education Resources to LEAs Appendix B - Indirect Cost Rates Appendix C - Study Agreement San Joaquin County offiCe of eduCation 3388 DARPPAEFNTDICES Appendix A DISTRIBUTION OF SPECIAL EDUCATION RESOURCES TO LEAs [Education Code 56205(b)(1)(A-G), 56836.05(b) 1. a. As a result of changes allowed by the passage of AB 602, Special Education funding will be allocated by the State Department of Education to the Admin- istrative Unit of the San Joaquin County SELPA. Funding will then be allo- cated by the Responsible Local Agency (RLA) directly to the Districts based on decisions made pursuant to the process described herein. The Council of Directors shall recommend the distribution of funding based on dollars avail- able, utilization of dollars in each of the districts, and requests for any LEA to operate programs. This process allows for the reallocation of funding when necessary and for addressing recapture of funding should the SELPA experi- ence declining enrollment. The final decision regarding the allocation plan shall be made by the Council of Superintendents. Preliminary data gathering will take place after the December Pupil Count. Priorities for additional regionalized classes will be set in February. All fiscal recommendations will be sent to the Council of Superintendents for review and action. The Annual Budget Plan shall be adopted at a public hearing held by the Council of Superintendents. b. The Council of Directors shall recommend the allocation of funding for instructional personnel. 2. The district of residence has the financial responsibility for transporting all its students. Should a student be transported by an agency other than the district of residence, and should the cost exceed the apportionments and other funds received for such services by the providing agency, the district of residence shall reimburse the providing agency its prorated share of the excess costs. 3. Regionalized service funds shall be allocated to the RLA for operation of re- gionalized services specified in Education Code 56220 (c). Should the cost for regionalized services exceed the apportionments and other funds received for such services, such excess costs will be prorated to each district on the basis of its most recent unduplicated special education pupil count. 4. The audit trail of utilization of federal flow-through funds shall be maintained by setting up a separate budget. The SELPA Director prepares the annual re- ports based on budget expenditure information. 5. The staff development committee of the SELPA shall prepare the annual plan for staff development based on yearly needs assessments. The SELPA staff shall prepare the staff development budget based on recommendations from the Council of Directors regarding the distribution and utilization of state per- sonnel development funds. Fiscal crisis & ManageMent assistance teaM 3399 APPENDDRICAEFST 6. Low incidence funds shall be maintained in two separate budgets of the RLA. a. Based on IEP justification that the equipment requested will promote the least restrictive environment for the student and minimize the necessity for services on an isolated site, a district may request an expenditure of funds for equipment with a written request presented to a Low Incidence Com- mittee for approval. Upon approval, the equipment is purchased by the SELPA office. b. Specialized services funds are generated and allocated to districts based on prior December pupil count. Reimbursement for specialized services shall be based on IEP documented needs. 7. Changes in funding distribution shall be recommended by the Council of Di- rectors to the Council of Superintendents. Changes in budget allocation will be reflected on the reporting documents required by the California Department of Education of the appropriate district(s). All budgets, district and county, are approved at public meetings. 8. Proposed changes by an LEA that would impact another LEA’s budget or program(s) shall be presented to the Council of Directors for discussion in ac- cordance with the “Changes Calendar” developed by the Council of Directors. Items on this calendar shall include, but need not be limited to, (1) changes in service being provided by an LEA, (2) changes in facility needs, (3) program- ming requests, and (4) proposed excess costs. The calendar shall also delineate when recommendations from the Council of Directors shall be presented to the Business Advisory Group as an informational item and to the Council of Superintendents for action. 9. The district of residence has the financial responsibility for program costs for all its students. Should a student be educated by an agency other than the district of residence, and should the programming costs exceed the apportion- ments and other funds received for such services by the providing agency, the district of residence shall reimburse the providing agency its prorated share of the excess costs. In 1997-98 San Joaquin SELPA’s Model for Distribution of Funds established an adjusted base from each district and the county office. COLA, growth and supplements to base are then added to the base of each member LEA each year. MODEL FOR DISTRIBUTION OF FUNDS (Used 2011-12 Annual Accrual August 2012) Part I – SELPA Special Education Programs 1. Establish 1997-98 adjusted funding base for each district and county of- fice: a. 1997-98 J50 $40,522,361 b. 94-142 & specific federal grants -$9,929,699 San Joaquin County offiCe of eduCation 4400 DARPPAEFNTDICES c. Phase I equity d. County Special Education Taxes -$2,169,760 e. Total 1997-98 Adjusted Funding Base $28,422,902 2. Determine total SELPA revenues: a. Total Prior Year Funding Base $28,422,902 b. Total Estimated COLA $0 c. Total Estimated Growth $297,998 d. Total Estimated Phase III Equity $4,605 e. Total SELPA Revenues $28,725,505 3. Allocated estimated COLA (line 2.b.) to COE and districts on a per K-12 ADA basis. 4. Allocated estimated SELPA growth funds (line 2.c.) to COE and districts that actually grew, based on those growth districts’ proportionate share of growth ADA. 5. Allocated Phase III [Supplement to Base] equity funding (line 2.d.) as follows: a. 25% toward full funding of Phase I Equity. Continue each year un- til Phase I fully funded. b. 75% balance distributed to COE and districts on a per K-12 basis. c. After Phase I Equity is fully funded, 100% of Phase III Equity to be distributed on per K-12 ADA basis. 6. Subtract COE total base funding from total SELPA revenues to determine funding factor denominator. a. Total SELPA Revenues (line2.e.) $28,725,505 b. Minus COE total base funding -$2,500,180 c. [Minus Ongoing Maximization to SELPA Reserve] -$402,194 d. Funding factor denominator $25,823,131 7. Determine the unfunded County Program Costs: a. COE funding base (line 6.b.) $2,500,180 b. Plus additional revenues $ 6,132,283 c. Plus prior year program carryover $0 Fiscal crisis & ManageMent assistance teaM 4411 APPENDDRICAEFST d. Minus total estimated county program costs -$22,456,181 e. Equals unfunded county program costs -$13,823,718 8. Adjustments for revenue targets (+ or -) a. Replenish NPS Pool (Prior year district reimbursement) $1,300,000 b. Replenish SELPA Reserve (Not less than 3%) $402,194 c. [Reimburse 70% NPS/A Districts] $1,406,327 d. [Replenish Mid-Year Class Reserve $180,000 e. Total reserve adjustments $3,288,521 9. Determine the amount of SELPA revenues available which establishes the funding factor numerator: a. Total SELPA Reserve (line 2.e.) $28,725,505 b. Minus COE base total base funding (line 6.b.) -$2,500,180 c. Minus Unfunded adjustments (line 7.e.) -$13,509,278 d. Minus reserve adjustments (line 8.c.) -$ 3,288,521 e. Balance of funds available to districts $9,427,526 10. Determine funding factor: Divide line 9.e by line 6.c 0.36508 a. If less than or equal to 1.0, the funding factor used to prorate allo- cated funds from/to districts. b. If greater than 1.0, the factor becomes 1.0 and SELPA must decide how to use surplus dollars, i.e. distribute or put in reserve. San Joaquin County offiCe of eduCation 4422 DARPPAEFNTDICES Appendix B Fiscal crisis & ManageMent assistance teaM 4433 APPENDDRICAEFST Appendix C San Joaquin County offiCe of eduCation 4444 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4455 APPENDDRICAEFST San Joaquin County offiCe of eduCation 4466 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4477 APPENDDRICAEFST San Joaquin County offiCe of eduCation