Siskiyou County Office of Education Report

Special Education Review August 21, 2024 Siskiyou County Office of Education Michael H. Fine Chief Executive Officer August 21, 2024 Allan Carver, County Superintendent of Schools Siskiyou County Office of Education 609 South Gold St. Yreka, CA 96097 Dear Superintendent Carver: In February 2024, the Siskiyou County Office of Education and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for FCMAT to conduct a review of the county office’s special education program. The agreement stated that FCMAT would perform the following: 1. Analyze special education teacher staffing ratios, class sizes and caseloads using statutory requirements for mandated services and statewide guidelines, and make recommendations for improvement, if any. 2. Review the efficiency of staffing allocations of special education paraeducators, per Education Code requirements and/or industry standards, and make recommendations for improvement, if any. Review the procedures for identifying the need for paraeducators, including considerations related to the least restrictive environment and the processes for monitoring the assignment of paraeducators and determining the need for continued support from year to year (include classroom and 1-to-1 paraeducators). 3. Analyze staffing and caseloads for related service providers, including but not limited to speech pathologists, psychologists, occupational/physical therapists, behavior specialists, adaptive physical education teachers and other staff who may be related service providers, and make recommendations for improvement, if any. 4. Review the Special Education Department's organizational structure and staffing with the central office of the county office of education to determine whether its administration, clerical and administrative support, program specialists, teachers on special assignment and overall function are aligned with those of county offices of comparable size and structure, and make recommendations for greater efficiencies, if any. 5. Review the county office’s professional development/training program as it relates to special education, and make recommendations for improvement, if any. 6. Provide one day of on-site technical assistance to the county office's business services administration to better understand the Special Education Local Plan Area's (SELPA's) funding model. 7. Review the Siskiyou County SELPA funding allocation formula. Conduct interviews with county office and SELPA personnel, as well as staff at member districts, to gain insights and perspectives on the allocation formula. Provide recommendations to the county office and SELPA, offering guidance on a potential process for revising the SELPA allocation model. Michael H. Fine • Chief Executive Officer 1300 17th Street – City Centre, Bakersfield, CA 93301-4533 • Tel. 661-636-4611 • Fax 661-636-4647 www.fcmat.org This report contains the study team’s findings and recommendations. FCMAT appreciates the opportunity to serve the Siskiyou County Office of Education and extends its thanks to all the staff for their assistance during fieldwork. Sincerely, Michael H. Fine Chief Executive Officer Table of Contents Table of Contents Table of Contents About FCMAT ...................................................................................................ii About FCMAT ...................................................................................................ii Introduction ......................................................................................................iv Background ...............................................................................................................iv Study and Report Guidelines .................................................................................v Study Team .................................................................................................................v Executive Summary ........................................................................................1 Findings and Recommendations................................................................3 Siskiyou County SELPA ..........................................................................................3 State Aid for Special Education ............................................................................6 County Office Special Education Program Budget Development and Monitoring ..................................................................................................................11 SELPA Funding Allocation Plan Review Items .................................................17 Siskiyou County SELPA Administrative Structure ...........................................19 Professional Development Plan .........................................................................25 Special Education Teacher Staffing ...................................................................28 Special Education Teacher Assistant Staffing ................................................30 Related Service Provider Staffing and Caseloads .........................................33 Appendix ........................................................................................................39 Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education i About FCMAT FCMAT’s primary mission is to assist California’s local TK-14 educational agencies to identify, prevent, and resolve financial, human resources 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, support the training and development of chief business officials and help to create efficient organizational operations. FCMAT’s data management ser- vices are used to help local educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and inform instructional program decisions. 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 LEA 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. 90 80 70 60 50 40 30 20 10 0 FCMAT has continued to make adjustments in the types of support provided based on the changing dynamics of TK-14 LEAs and the implementation of major educational reforms. FCMAT also develops and provides numerous publications, software tools, workshops and professional learning opportunities to help LEAs operate more effectively and fulfill their fiscal oversight and data management responsibilities. The California School Information Services (CSIS) division of FCMAT assists the California Department of Education with the implementation of the California Longitudinal Pupil Achievement Data System (CALPADS). CSIS also hosts and maintains the Ed-Data website (www.ed-data.org) and provides technical expertise to the Ed-Data partnership: the California Department of Education, EdSource and FCMAT. FCMAT was created by Assembly Bill (AB) 1200 in 1991 to assist LEAs to meet and sustain their financial obligations. AB 107 in 1997 charged FCMAT with responsibility for CSIS and its statewide data management work. AB 1115 in 1999 codified CSIS’ mission. seidutS fo rebmuN About FCMAT Studies by Fiscal Year 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 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21 21/22 22/23 Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education ii About FCMAT AB 1200 is also a statewide plan for county offices of education and school districts to work together locally to improve fiscal procedures and accountability standards. AB 2756 (2004) provides specific responsibili- ties to FCMAT with regard to districts that have received emergency state loans. In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to those types of LEAs. On September 17, 2018 AB 1840 was signed into law. This legislation changed how fiscally insolvent dis- tricts are administered once an emergency appropriation has been made, shifting the former state-centric system to be more consistent with the principles of local control, and providing new responsibilities to FCMAT associated with the process. Since 1992, FCMAT has been engaged to perform more than 1,400 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 Michael H. Fine, Chief Executive Officer, with funding derived through appropriations in the state budget and a modest fee sched- ule for charges to requesting agencies. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education iii Introduction Background Introduction Background Located in inland northern California, adjacent to the Oregon border, Siskiyou County is the fifth largest county in the state by area. According to DataQuest, Siskiyou County had an enrollment of 5,578 transi- tional kindergarten through grade 12 (TK-12) students in the 2023-24 academic year. In 2023-24, 11.03% of the county’s TK-12 students were identified as requiring special education, which is lower than the state- wide TK-12 average of 13.70%. The Siskiyou County Special Education Local Plan Area (SELPA), which is a regional service delivery model for special education, is a necessary small SELPA composed of 27 local educational agencies (LEAs), as shown in Table 1 below. Table 1: Enrollment and the Percentage of Students in Special Education in 2023-24 for the Siskiyou County SELPA’s LEAs TK-12 Special Education TK-12 Total Percentage of Students in LEA Enrollment Enrollment Special Education Big Springs Union Elementary 14 120 11.67% Bogus Elementary 1 15 6.67% Butte Valley Unified 27 302 8.94% Butteville Union Elementary 12 149 8.05% Delphic Elementary 3 62 4.84% Dunsmuir Elementary 6 76 7.89% Dunsmuir Joint Union High 15 65 23.08% Gazelle Union Elementary 5 35 14.29% Golden Eagle Charter 39 401 9.73% Grenada Elementary 13 207 6.28% Happy Camp Union Elementary 12 115 10.43% Hornbrook Elementary 7 38 18.42% Junction Elementary 2 23 8.70% Klamath River Union Elementary 1 5 20.00% Little Shasta Elementary 0 19 0.00% McCloud Union Elementary 4 50 8.00% Montague Elementary 13 154 8.44% Mt. Shasta Union Elementary 52 506 10.28% Northern United – Siskiyou Charter 14 124 11.29% Scott Valley Unified 50 624 8.01% Seiad Elementary 1 14 7.14% Siskiyou County Office of Education 70 70 N/A Siskiyou Union High 48 515 9.32% Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education iv Introduction Study and Report Guidelines TK-12 Special Education TK-12 Total Percentage of Students in LEA Enrollment Enrollment Special Education Weed Union Elementary 49 288 17.01% Willow Creek Elementary 7 40 17.50% Yreka Union Elementary 98 869 11.28% Yreka Union High 52 692 7.51% Total 615 5,578 11.03% Source: California Department of Education (CDE) - Enrollment for Charter and Non-Charter Schools With District Data - Siskiyou County. Note: Northern United – Siskiyou Charter and Golden Eagle Charter are authorized by the Siskiyou County Office of Education. In 2023-24 the share of students enrolled in special education varied among the SELPA’s LEAs, from a low of 0% in Little Shasta Elementary District to a high of 23.08% in Dunsmuir Joint Union High School District. In February 2024, the county office of education and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for FCMAT to conduct a review of the county’s regionalized special education program and recommend a process to revise the Siskiyou County SELPA’s allocation policy. Study and Report Guidelines FCMAT visited the county office of education on May 13, 14 and 15, 2024 to conduct interviews with staff from SELPA member LEAs, and with county office administrators, special education teachers, related service pro- viders, and other staff. FCMAT continued interviews via videoconferences on May 16 and 17, 2024. Following fieldwork, FCMAT reviewed and analyzed data and documents. This report is the result of those activities. FCMAT’s reports focus on systems and processes that may need improvement. Those that may be func- tioning well are generally not commented on in FCMAT’s reports. In writing its reports, FCMAT uses the Associated Press Stylebook, a comprehensive guide to usage and accepted style that emphasizes con- ciseness and clarity. In addition, this guide emphasizes plain language, discourages the use of jargon and capitalizes relatively few terms. Study Team The study team was composed of the following members: Carolynne Beno, Ed.D., CFE Colleen Patterson, MBA, CMA FCMAT Chief Analyst FCMAT Consultant Leonel Martínez FCMAT Technical Writer Those members of this study team who are otherwise employed by a local educational agency were not representing their respective employers but were working solely as independent contractors for FCMAT. All team members reviewed the draft report to confirm accuracy and achieve consensus on the final recommendations. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education v Executive Summary Study Team Executive Summary SELPA Governance Structure The Siskiyou County SELPA is composed of 27 LEAs and governed by a steering committee composed of its LEA’s superintendents. The SELPA also has an executive council whose role and function is not well defined in the local plan. Many SELPAs have a joint advisory committee composed of special education program administrators and chief business officials, who provide input on items such as SELPA policies and procedures, operation of the special education programs, and proposed budgets. In SELPAs that use this governance structure, the joint advisory committee typically evaluates and then makes a recommendation on an item that will later be presented to the committee with decision-mak- ing authority. The SELPA needs to consider whether there is an operational advantage to restructuring the executive council into a joint advisory committee, which would evaluate and suggest revisions to items before making a recommendation on them to the steering committee. SELPA Funding Allocation Plan Staff reported that the SELPA’s funding allocation plan, which was adopted in 2007-08, was revised slightly in the spring of 2024. The local plan and available county office documents lack sufficient detail to provide transparency about SELPA revenues, the SELPA administrative unit and county office special education program budgets and expenditures, and the bills LEAs receive for the excess costs of SELPA programs and services. Several SELPA member LEAs reported that they do not understand the exist- ing SELPA funding allocation plan and indicated a need for more transparency about SELPA revenues and expenditures. The SELPA needs to update its current local plan to clearly outline at least the items suggested in the “Siskiyou County SELPA’s Funding Allocation Plan” section of this report. If the SELPA decides to revise its local plan, the SELPA steering committee needs to carry out the process outlined in the “Recommended SELPA Funding Allocation Plan Revision Process” section of this report. Associate Superintendent/SELPA Director Position The SELPA is a necessary small, single county SELPA for which the county office functions as both admin- istrative unit and provider of special education regional programs and related services. These are two distinct and independent functions, and it is not required that both functions be performed by a single LEA. Only a few of the SELPA member LEAs interviewed understood the difference between the county office and the SELPA or regarded them as separate entitles. It would be beneficial to divide the 1.0 full-time equiv- alent (FTE) associate superintendent/SELPA director position into two positions to create distinction and delineation between the county office and the SELPA. This would also enable the SELPA director to focus on the redefined role of SELPAs to help member LEAs improve outcomes for students with disabilities as outlined in the state’s continuous improvement system of support. Professional Development Plan The county office would benefit from developing a comprehensive onboarding plan for the Special Schools and Services Department that is differentiated by position and addresses the items in the “Special Education Staff Onboarding” section of this report. Special Schools and Services Department staff need to be surveyed annually regarding their training needs, and the county office needs to prioritize providing training in the areas identified in the “Professional Development Plan” section of this report. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 1 Executive Summary Study Team County Office Special Education Staffing FCMAT found the county office’s special education teacher staffing to be higher than required to meet Education Code and industry standard caseload averages. However, staffing appears appropriate because students in the resource specialist program (RSP) are supported through an inclusive model, which requires higher staffing levels, and students from different parts of this relatively large county are clustered into regional special day classes (SDCs). If the number of SDCs were reduced to increase class sizes, certain students would need to travel unreasonable distances to attend school. The county office does not assign special education teacher assistants to its SDCs using industry-standard adult-to-student ratios. If the county office were to use industry-standard adult-to-student ratios to deter- mine base staffing for its SDCs, it could still increase support in certain SDCs to meet student needs and/or account for teacher assistant/driver schedules. This would help prevent an SDC from having more special education teacher assistant support than is necessary, which is costly and can limit students’ opportunities to gain independence. The county office has more adapted physical education (APE) teachers, credentialed school nurses, and teachers of students who are deaf or hard of hearing than the industry standard adult-to-student ratios. However, because of the long travel times between districts and schools, staffing for these positions appears appropriate. The county office has 1.71 FTE fewer school psychologists than the industry-standard adult-to-student ratio and should evaluate whether it needs to increase staffing in this area to better align with industry standards and support district, school and student needs using the factors outlined in the “School Psychologists” section of this report. The county office has 1.05 FTE fewer speech and language pathologists (SLPs) than the caseload size indi- cated in the Education Code. It needs to increase SLP staffing so that its average caseload size is less than the Education Code maximum and adequate to meet student needs. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 2 Findings and Recommendations Siskiyou County SELPA Findings and Recommendations Siskiyou County SELPA SELPAs In 1977, all school districts and county offices in California were required to form geographical regions of sufficient size and scope to provide for all special education needs of children residing within the region’s boundaries. Each region became known as a Special Education Local Plan Area (SELPA). The state has 136 SELPAs, which are configured in different ways and include the following types: • Single district. • Multidistrict. • Multidistrict/county office. • Multidistrict/multicounty. • SELPAs with joint powers agreements. • Charter only. The Siskiyou County SELPA is a multidistrict/county office SELPA. SELPAs facilitate high quality educational programs and services for students with disabilities, and training for parents and educators. The SELPA fosters coordination between general and special education for pre- vention and early intervention and works cooperatively with other public and private agencies to support a full complement of special education services for students. Each SELPA has a local plan that describes its policies and procedures, how special education services are provided for students, and the allocation of SELPA revenues to support shared priorities. Siskiyou County SELPA Governance Structure The Siskiyou County SELPA’s local plan describes the SELPA’s governance structure and its regional policy making process for coordinating and implementing the local plan. SELPA Administrative Unit Each SELPA must have an administrative unit, which serves as the legal entity and is responsible for func- tions such as receiving and distributing special education funds to LEA accounts, employing staff to support SELPA functions, and maintaining a SELPA office. The Siskiyou County Office of Education is the administra- tive unit for the Siskiyou County SELPA. Siskiyou County SELPA Steering Committee The local plan establishes a steering committee as the SELPA’s administrative governing body. It is com- posed of a superintendent or designee from each SELPA member LEA, with the county superintendent of Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 3 Findings and Recommendations Siskiyou County SELPA schools representing the SELPA administrative unit and the county office special education programs. The steering committee is responsible for actions such as: • Reviewing and determining changes to the local plan. • Adopting policies, regulations, and procedures related to the local plan. • Approving the SELPA’s annual service and budget plans. • Establishing a community advisory committee to facilitate parent involvement. • Directing the SELPA director regarding the development, revision, implementation, and review of the local plan. • Approving the SELPA allocation plan for distribution of federal, state, and local funds received for special education programs. • Advising on the number and type of SELPA staff employed by the county office to pro- vide regionalized services. The local plan indicates the steering committee receives and acts on information from the executive council, the community advisory committee and the SELPA director. Siskiyou County SELPA Executive Council The local plan states that executive council membership is limited to LEA superintendents and board desig- nees. The executive council has seven voting members representing LEAs and the county superintendent’s office. This council’s role and function are not well defined other than a statement indicating the steering committee will receive and act on information from groups that include the executive council. County office staff and SELPA member LEAs described the executive council as a group that provides input on SELPA policies and procedures, operation of the special education programs, and proposed budgets. The steering committee needs to clarify the executive council’s role and determine whether the executive council must formally approve an item, such as a new policy or the county office special education budget, before it is considered by the steering committee. Then the local plan needs to be updated accordingly. SELPA Joint Advisory Committee Many SELPAs have a joint advisory committee composed of special education program administrators and chief business officials. However, depending on the size and organization of a SELPA’s LEAs, superin- tendents and other staff also serve on joint advisory committees. Joint advisory committees exist to thor- oughly evaluate items such as changes to the local plan, policies and procedures, regional programs, and proposed budgets. Since joint advisory committees include staff with special education program and finan- cial expertise, they can thoroughly assess proposed actions. In SELPAs that use this governance structure, the joint advisory committee typically evaluates and makes a recommendation on an item that will later be presented to a committee that has decision-making authority, such as a superintendent’s council. During this process, items may be modified based on input from the joint advisory committee. The Siskiyou County SELPA does not have a joint advisory committee, in part because many of its LEAs do not have a chief business official or program administrator solely devoted to managing the special education program. However, some of the LEAs have such positions, and during interviews, many LEAs expressed interest in a joint advisory committee that could consider and discuss SELPA-related items from a fiscal and program perspective. Thus, the SELPA needs to consider whether there is an operational Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 4 Findings and Recommendations Siskiyou County SELPA advantage to restructuring the executive council into a joint advisory committee that would consider and potentially revise items before making a recommendation to the steering committee. Recommendations The SELPA should: 1. Outline the role and function of the executive council in the local plan, including an explanation of what the executive council is responsible for evaluating, potentially revising, and approving, before it is considered by the steering committee. 2. Consider whether there is an operational advantage to restructuring the executive council into a joint advisory committee, composed of representatives who have fiscal and special education program expertise, to consider items such as proposed budgets and policy changes and make a recommendation on them to the steering committee. 3. Update its local plan if it implements recommendation two. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 5 Findings and Recommendations State Aid for Special Education State Aid for Special Education Special education is defined by California Education Code (EC) 56031(a) as “specially designed instruc- tion, at no cost to the parent, to meet the unique needs of individuals with exceptional needs, includ- ing instruction conducted in the classroom, in the home, in hospitals and institutions, and other set- tings, and instruction in physical education.” As the cost of providing special education has increased because of factors such as rising employee costs, increased student behavioral and mental health needs, and the need to use contracted service providers due to special education staffing shortages, SELPAs throughout the state face ongoing obstacles in ensuring students with disabilities have mean- ingful access to a free appropriate public education (FAPE) to acquire the skills needed for postsecond- ary life. Assembly Bill (AB) 602, which became effective in the 1998-99 fiscal year, defines the formula through which SELPAs receive state aid for special education. According to AB 602, most of the state funds for spe- cial education are distributed to SELPAs based on the total number of TK-12 students in attendance, or the average daily attendance (ADA), in the LEAs that make up each SELPA. This is independent of the number of students who receive special education services or the cost of those services and programs. In addi- tion to the AB 602 apportionment, LEAs receive other state funding such as mental health and Workability funds, and federal aid from the Individuals with Disabilities Education Act (IDEA) to educate students with disabilities, all of which are intended to supplement the general education program, not provide a separate program. Under federal law, students with disabilities are entitled to a FAPE regardless of available funding. State and federal special education aid are insufficient to provide FAPE for all students, so LEAs trans- fer funds from the unrestricted general fund to pay for the portion of special education costs that exceeds program revenues. Because federal funds may be used only to cover the excess costs of providing special education and related services to students with disabilities, LEAs must annually show that they have spent at least the same amount of state and local funds on special education services in each succeeding year. This is known as meeting the maintenance of effort, or MOE, requirement. AB 602 Base Grant Per AB 602, a SELPA’s base grant entitlement is calculated by multiplying its funded base rate by the SELPA-wide funded ADA and is paid through the principal apportionment. SELPA Funded Base Rate Since AB 602 was enacted, per-ADA special education grant funding rates have historically differed significantly among SELPAs because funding was based on previous special education expenditures by the LEAs before the AB 602 legislation was adopted. The Siskiyou County SELPA historically received a higher per-ADA funding rate than most other SELPAs in the state and than the AB 602 statewide target rate (90% of the statewide average funding rate). For example, in 2018-19 the AB 602 statewide target rate was $539.67 per ADA, and the Siskiyou County SELPA was funded at $653.54 per ADA. The 2018-19 funding was reduced by 1.78%. According to the Coalition for Adequate Funding for Special Education, in 2018-19 just seven SELPAs in the state received a higher AB 602 per-ADA funding rate than the Siskiyou County SELPA. Beginning in 2019-20, all SELPAs that received less than the AB 602 statewide target rate began receiving $545 per ADA, and the SELPA base grant was prorated by only 0.24%. Then, in 2020-21, an Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 6 AB 602 base rate, or minimum funding rate, replaced the AB 602 statewide target rate, and the SELPA prorations stopped. In 2021-22, the statewide AB 602 base rate increased above the Siskiyou SELPA’s rate, so it began receiving that higher rate. AB 602 base rates have increased significantly since, and in 2023-24 the AB 602 base funding rate was $887.40 per ADA. The Siskiyou County SELPA’s base funding rate increased by $245.49 per ADA between 2018-19 and 2023-24 (inclusive of the proration factor in 2018-19). The AB 602 base funding rates from 2021-22 to 2023-24 (which were used to calculate the Siskiyou County SELPA’s AB 602 base grant), and the pro- jected base funding rate for 2024-25 from the Budget Act of 2024, are shown in Figure 1 below. Figure 1: SELPA AB 602 base funding rates, which were used to calculate the Siskiyou County SELPA’s AB 602 base grant Source: CDE AB 602 Special SELPA Funding Exhibits - First Principal Apportionment (P-1) and CDE Funding Rates and Fiscal Information for 2024-25 - Special Education Local Plan Area (SELPA) Base Rate, EC Section 56836.146. AB 602 Base Grant Entitlement Per AB 602, a SELPA’s base grant entitlement is calculated by multiplying its funded base rate by the SELPA’s funded ADA (using the SELPA-wide ADA for the current, prior, or second prior year, which- ever is greatest). The Siskiyou County SELPA’s funded ADA decreased by 334.53 from 2021-22 through 2023-24 as shown in Figure 2 below. 5,900.00 5,845.45 5,800.00 5,757.28 5,700.00 5,600.00 5,500.00 5,422.75 5,400.00 5,300.00 5,200.00 2021-22 - P-1 2022-23 - P1 2023-24 - P1 ADA dednuF Findings and Recommendations State Aid for Special Education Figure 2: Siskiyou County SELPA’s funded ADA from 2021-22 through 2023-24 Source: CDE AB 602 Special SELPA Funding Exhibits - First Principal Apportionment (P-1). Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 7 Findings and Recommendations State Aid for Special Education Despite declining SELPA-wide ADA, increases in the AB 602 base funding rates caused the SELPA’s base grant entitlement to increase by $695,714.84 from 2021-22 through 2023-24, as shown in Fig- ure 3 below. Figure 3: Siskiyou County SELPA’s AB 602 base grant entitlement from 2021-22 through 2023-24 Source: CDE AB 602 Special SELPA Funding Exhibits - First Principal Apportionment (P-1). Because AB 602 state aid is the main source of a SELPA’s special education funding, it is increasing- ly important for the SELPA to monitor its ADA; a decline in that number could lead to a decreasing SELPA base grant entitlement because future COLA increases to the AB 602 base rates are un- known. SELPA Funding Allocation Plans Each SELPA is required to have a funding allocation plan designed to meet local needs and agreed upon by the SELPA’s governance council. Because SELPAs are one of the earliest forms of local control, they allo- cate special education funds to their member LEAs in a variety of ways, including: • By total ADA. • By a combination of total ADA and funds allocated first for certain regional programs or services. • By a combination of ADA and special education pupil count. • By weighted formulas. • By retaining all funds generated by their member LEAs for things such as operating regional special education programs, with any remainders being distributed to mem- bers or members being billed for excess costs. A best practice is to annually review SELPA funding allocation plans so they can be revised to meet changing LEA and program needs and to accommodate funding shifts and SELPA dynamics. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 8 Findings and Recommendations State Aid for Special Education Siskiyou County SELPA’s Funding Allocation Plan FCMAT reviewed the SELPA’s funding allocation plan, which has been used since 2007-08. A simplified overview is shown in Figure 4 below. SELPA Administrative Unit (SCOE) Receives AB 602 State Aid for Special Education •Less $120,000 for an Extraordinary Cost Pool. Adjusted State Aid is •Less $37,000 for a Reduced nonpublic school (NPS) pool. •After funding SCOE's Remaining State Aid special education program budget, any remaining is Allocated to the funds go to the SELPA County Office member LEAs based on an ADA formula. Figure 4: Graphic depicting a simplified version of the Siskiyou County SELPA’s funding allocation plan Source: FCMAT, based on the Siskiyou County SELPA Local Plan. A best practice is for a SELPA to have a clearly written funding allocation plan outlining items such as: • SELPA revenues collected on behalf of its member LEAs, including federal, state and local revenue. • SELPA administrative unit expenditures, including items such as salaries and benefits (for the SELPA director, SELPA executive assistant, other employees), supplies, facilities, and indirect costs. • Regionalized special education program and service expenditures, including items such as salaries and benefits (for special education teachers, instructional assistants, related ser- vices providers, other employees), services, equipment, facilities, and indirect costs. • The funding distribution or bill-back method used. Although Siskiyou County SELPA’s local plan provides some information about its funding allocation plan, FCMAT found the local plan and available county office documents lack sufficient detail to provide trans- parency regarding SELPA revenues, the SELPA administrative unit and county office special education program budgets and expenditures, and the LEA bill-backs. A bill-back is when a SELPA member LEA is charged for a percentage of the total cost of a service they have used during the school year. During inter- views, most LEAs requested a more detailed account of what they are billed for, and certain LEAs reported that they are surprised by the amount on their bills yearly because the cost of services is unclear at the beginning of the year. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 9 Findings and Recommendations State Aid for Special Education The Siskiyou County SELPA needs to consider revising its local plan to clearly outline at least the following: • The SELPA’s revenue sources. • The components of the SELPA administrative unit’s budget. • The parts of the county office’s special education program and services that are funded off- the-top (i.e., paid for at the SELPA-level and accessible by any LEA at no additional cost). • The portions of the county office’s special education programs or services that an LEA may access at an additional cost for which it will be billed for (i.e.,fee-for-service program or service). • An explanation of how LEA bill-backs are calculated for the county office’s special educa- tion fee-for-service programs and services. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 10 Findings and Recommendations County Office Special Education Program Budget Development and Monitoring County Office Special Education Program Budget Development and Monitoring County Office’s Special Education Program Budget According to the local plan, the county office’s special education budget is built based on the remaining AB 602 state aid (after funding the extraordinary cost and NPS pools), the revenue from 75% to 100% of the federal IDEA funds received by the SELPA, and the revenue for program specialist/regionalized services. These services, which are part of the AB 602 apportionment, are for regionalized operations and ser- vices and direct instructional support for program specialists. The county office special education budget includes a 4% reserve to “address unknown issues such as: allocation changes, prior year adjustments, COLA and deficit changes, negotiations, high needs student, etc.” The local plan states that, at year-end, any excess funds remaining in the county office special education budget will be reallocated to the districts. The SELPA’s federal IDEA revenue for 2023-24 (as of January 2024) was $1,412,498. The county office’s 2023-24 special education program budget included 78.38% of these funds, and the SELPA distributed the remaining 21.62%, or $305,382, to the Yreka Union Elementary and Yreka Union High school districts. Using 78.38% of the SELPA’s federal IDEA revenue to partially fund the county office’s special education program is aligned with its local plan, which allows the county office to use 75% to 100% of these revenues. However, the local plan does not explain why a portion of the federal IDEA funds are distributed to only two districts, and staff interviewed did not know the reason. Thus, it is not clear why other SELPA member LEAs do not receive part of the SELPA’s IDEA funds. In addition, staff did not know why the distribution amount of the federal IDEA funds to the two districts has remained the same for at least 10 years despite the SELPA’s federal IDEA revenue increasing by 28.78% during that time. County Office Special Education Program Budget Development and Monitoring A best practice is for a regional special education program operator (such as the county office) to present its budget annually to its SELPA’s governing body for approval, and to regularly update and discuss its budget, staffing and SELPA member LEA needs throughout the fiscal year. SELPA member LEAs should receive updates, and a variance analysis, at least at the interim budget reporting periods, so they can be aware of any changes in revenues and/or expenditures affecting these budgets and potential allocations or bill-backs to the SELPA member LEAs. The local plan indicates that the executive council will review and approve the county office’s special education budget in June of each year, and that the executive council will receive budget updates at first and second interim reporting periods to “allow for discussion and understanding of specific issues related to program delivery and budget impact.” However, SELPA member LEAs reported that they have not regularly received SELPA administrative unit or county office special education pro- gram budget updates at first and second interim reporting periods or estimated actuals. This means they cannot predict bill-back changes and how these may affect their own LEA’s ending fund balance. Without regular budget updates, SELPA member LEAs also cannot monitor their county office special education service bill-back throughout the year to verify its accuracy. In addition, without regular county office special education program budget updates, SELPA member LEAs are missing an opportunity to discuss and provide input on at least the following: Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 11 Findings and Recommendations County Office Special Education Program Budget Development and Monitoring • County office regional special education program and service implementation. • The needs and goals of SELPA member LEAs. • County office regional special education program enrollment and related service provider caseloads. • Possible staffing changes for the next school year. Accordingly, the steering committee needs to adopt calendars for county office special education program budget development and budget monitoring with at least the activities shown below. The county office needs to discuss the activities in each of these calendars with the executive and steering committees and seek approval from the steering committee for items as noted in Tables 2 and 3 below. Table 2: Suggested County Office Special Education Program Budget Development Calendar Month Activity Budget development calendar discussion and approval Monitor county office special education program and service implementation August - October Identify county office special education program and service priorities and goals for the following school year Project county office special education program enrollment and related service needs for the November - January following school year January Discuss county office staffing needs for the following school year Develop and approve budget assumptions for the county office special education budget February Discuss and approve staffing changes for the following school year so layoff notices may be issued to classified and certificated employees if needed no later than March 15 March First review of county office’s proposed special education budget for the next fiscal year Continue review of county office’s proposed special education budget for the next fiscal year April - May Public hearing and budget adoption of county office’s special education budget for the next fiscal year Source: FCMAT. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 12 Findings and Recommendations County Office Special Education Program Budget Development and Monitoring Table 3: Suggested County Office Special Education Program Annual Budget Monitoring Calendar Month Activity Monitor county office special education program and service implementation and program/student needs August - October Monitor county office special education program ADA Track and revise county office special education program estimated revenues and expenses Review and adoption of first interim budget revision report for county office special education November programs and services Monitor county office special education program and service implementation and program/student needs November - January Monitor county office special education program ADA Track and revise county office special education program and service estimated revenues and expenses County office to update income to reflect final annual certification February Review and adoption of second interim budget revision report for county office special education programs and services Monitor county office special education program implementation and program/student needs Monitor county office special education program ADA February - June Track and revise county office special education program and service estimated revenues and expenses Review and adoption of year-end budget report for county office special education program and August services Source: FCMAT. Recommended SELPA Funding Allocation Plan Revision Process FCMAT was asked to review the Siskiyou County SELPA’s funding allocation plan and provide recommen- dations on a process the SELPA could use if it were to revise its plan. Staff reported that limited revisions, most recently in the spring of 2024, have been made to the SELPA’s funding allocation plan, which was adopted in 2007-08. FCMAT made recommendations for the SELPA to provide a more detailed description of its current funding allocation plan in the “Siskiyou County SELPA’s Funding Allocation Plan” section of this report. In addition to clarifying its current funding allocation plan, if the SELPA were to also revise its plan, the SELPA’s steer- ing committee would need to carry out the process outlined in Figure 5 below. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 13 Findings and Recommendations County Office Special Education Program Budget Development and Monitoring 1. Meet with all SELPA member LEAs to increase their understanding of the current county office special education programs 2. Form a multidisciplinary 3. Present proposed and services they are billed SELPA funding allocation revisions to the SELPA's for, and how their bill is plan ad-hoc committee to funding allocation plan to calculated. develop proposed changes the steering committee for to the SELPA’s plan for the formal consideration and steering committee’s potential approval. Elicit suggestions from consideration. each LEA regarding possible changes to the current SELPA funding allocation plan. Figure 5: Graphic depicting an overview of FCMAT’s recommended process if the SELPA were to revise its SELPA funding allocation plan Source: FCMAT. Below is a detailed description of FCMAT’s recommended SELPA funding allocation plan revision process. 1. Meet with all SELPA member LEAs to increase their understanding of the current funding allocation plan, which county office special education programs and services they are billed for, and how their bill is calculated. Elicit suggestions from each LEA regarding possible changes to the funding allocation plan. The SELPA should schedule time for the county office’s associate superintendent of business services, county office’s budget technician who implements the SELPA funding allocation plan, and the SELPA director to meet with each SELPA member LEA (this could be 1-to-1 or in group sessions) to: a. Review the 2024-25 county office special education budget and increase all LEAs’ understanding of at least the following: i. Which of the county office’s special education programs and services are funded off-the-top (available for all LEAs to use at no additional cost). ii. Which of the county office’s special education programs and services an LEA may opt out of, and whether there is a resulting reduction in their bill-back. iii. Which of the county office’s special education programs and services are fee-for-service (available for LEAs to use at an additional cost that they will be billed for at the end of the year). iv. The estimated cost of each fee-for-service program and service from the county office’s special education budget. b. Identify the continuum of special education services available for students in each LEA and discuss at least the following: i. The LEA’s enrollment in the county office special education programs. ii. The LEA’s use of other county office services (e.g., speech and language therapy, occupational therapy, transportation, etc.). Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 14 Findings and Recommendations County Office Special Education Program Budget Development and Monitoring iii. Any areas of need the LEA has that may be preventing it from offering a full continuum of special education services while ensuring students with disabilities are educated in their least restrictive environment (i.e., with their nondisabled peers in general education settings to the greatest extent possible). c. Recognize the pros and cons of the current SELPA funding allocation plan and discuss possible changes. 2. Form a multidisciplinary SELPA funding allocation plan ad-hoc committee to develop proposed changes to the SELPA’s plan for the steering committee’s consideration. The SELPA funding allocation plan ad-hoc committee could be facilitated by the SELPA director and composed of the county office’s associate superintendent of business services, the county office’s budget technician who implements the SELPA funding allocation plan, and a representative (e.g., superintendent, director of fiscal services, special education program director) from at least half of the SELPA member LEAs to explore possible ways to revise the existing SELPA funding allocation plan. First, the SELPA’s funding allocation plan ad-hoc committee should develop a set of core principles (e.g., stability and predictability of funding, timely and accurate projections, transparency, serving students in the least restrictive environment, minimizing out-of-county placements) to provide a foundation for current and future evaluation and revision of the SELPA’s funding allocation plan. Then, the SELPA’s funding allocation plan ad-hoc committee should consider the suggestions from SELPA member LEAs about how to revise the funding allocation plan. 3. Present the proposed revisions to the SELPA’s funding allocation plan to the steering committee for formal consideration and potential approval. Potential revisions to the SELPA funding allocation plan should be presented to the steering committee for formal consideration and possible action following the process outlined in the local plan. If changes are adopted, the SELPA’s local plan should be updated accordingly. Recommendations The SELPA should: 1. Monitor the ADA of its SELPA member LEAs because a decline in that number could lead to a decreasing SELPA base grant entitlement since future COLA increases to the AB 602 base rates are unknown. 2. Revise the Siskiyou County SELPA’s local plan to more clearly outline at least the following components of its current plan: • The SELPA’s revenue sources. • Components of the SELPA administrative unit’s budget. • The parts of the county office’s special education program and services that are funded off-the-top (paid for at the SELPA level and accessible by any LEA at no additional cost). Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 15 Findings and Recommendations County Office Special Education Program Budget Development and Monitoring • The parts of the county office’s special education program that an LEA may access at an additional cost for which it will be billed for (fee-for-service program or service). • An explanation of how LEA bill-backs are calculated for the county office special education fee-for-service programs and services. 3. Consider adopting county office special education program budget development and budget monitoring calendars to provide regular updates to the executive council and steering committee on budget changes and how they will affect LEA bills. 4. Consider following the process outlined in the “Recommended SELPA Funding Allocation Plan Revision Process” section of this report if the SELPA decides to revise its funding allocation plan. 5. Update the local plan if the SELPA’s funding allocation plan is revised. 6. Review the SELPA’s funding allocation plan at least annually to determine if modifications are needed to meet changing student, LEA and program needs, funding shifts, and SELPA dynamics. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 16 Findings and Recommendations SELPA Funding Allocation Plan Review Items SELPA Funding Allocation Plan Review Items During FCMAT’s review of the SELPA’s funding allocation plan, FCMAT identified the following items as requiring review, regardless of whether the SELPA decides to revise its funding allocation plan. Special Education Revenues Received by the SELPA A SELPA has a fiduciary duty to collect funds on behalf of its member LEAs. The best practice is for SELPAs to account for all revenues in their funding allocation plan and share this information with SELPA member LEAs so all available funding is known and accounted for. Some revenue received by the SELPA is either not accounted for in its special education revenue allocation plan spreadsheet, or the use and/or allocation of the funds are not explained in the local plan; These revenue items are described below. • The following revenue received by the SELPA was not accounted for in its special edu- cation revenue allocation spreadsheet and/or local plan: IDEA/American Rescue Plan 611 local assistance entitlement funds, alternative dispute resolution funds, special education learning recovery support funds, and mental health funds. • The local plan does not explain how special education out-of-home care funding is used and/or distributed to SELPA member LEAs. This is funding that is received by the SELPA and must be used to support the needs of students who are foster youth, and who are placed in the short-term residential therapeutic program and three other types of facilities located within a SELPA’s geographic boundaries. • The local plan does not explain how low-incidence specialized service funding is used and/or distributed to SELPA member LEAs to meet the needs of qualifying students. This is funding that is received by the SELPA and must be used to support students with low-incidence disabilities including hearing impairments, vision impairments, severe orthopedic impairments, or any combination of these. Distribution of IDEA Funds to SELPA Member LEAs A best practice is for SELPAs to account for disbursements of all SELPA revenues in their local plan and funding allocation plan. As mentioned in the “County Office Special Education Program Budget Development and Monitoring” section of this report, just two SELPA member LEAs receive a fixed amount of IDEA funds. The SELPA needs to determine whether this arrangement should continue and update its local plan to reflect any distribution of IDEA funds to SELPA member LEAs. SELPA Bill-Backs • School Transportation -Generally Accepted Accounting Principles require matching the cause of expenses with the effect of generating income. The SELPA has been offsetting its school transportation bill-back to its member LEAs based on 2012-13 school transportation income apportioned from the CDE. However, The Budget Act of 2022 increased school transportation funding. Starting in the 2022-23 fiscal year, school transportation funding is equal to 60% of the prior year’s student transportation expenditures reported in Function 3600. At the time of FCMAT’s visit, the SELPA had not updated the school transportation bill-back to account for this additional income. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 17 Findings and Recommendations SELPA Funding Allocation Plan Review Items However, as of the publication date of this report, the SELPA is accounting for this addi- tional school transportation income in its bill-back formula. • Utilities - An explicit cost is a tangible and quantifiable expenditure such as wages, rent, materials or utilities. Measuring explicit costs requires meticulous tracking. SELPAs often agree on a rate they will be charged by SELPA member LEAs that host a regional SDC program at one of their school sites. The rate is typically based on a cost per square foot that includes utilities, custodial services and any other variables deemed reasonable. The Siskiyou SELPA’s bill-back for utilities is outlined in the local plan and based on an explicit cost model. Staff indicated the SELPA is billed for the cost of power at seven schools where regional SDC programs are located, based on a formula that uses a rate established in 2012-13. This formula does not appear to be supported by explicit cost data or the local plan. The SELPA needs to consider determining a rate per square foot that includes utili- ties, custodial and any variables deemed reasonable, and adjusting the utility bill-back in its local plan. Recommendations The SELPA should: 1. Report all federal and state special education funding it receives in its special education revenue allocation spreadsheet. 2. Update its local plan to explain how the Special Education Out-of-Home Care and Low Incidence funds are used at the SELPA level and/or distributed to SELPA member LEAs. 3. Determine whether it should continue distributing some of its IDEA funds to two LEAs, and update its local plan to reflect whatever the agreed-upon distribution of IDEA funds to SELPA member LEAs is. 4. Consider revising its utility bill-back to be based on a rate per square foot, which would help an LEA that hosts a regional program recover costs for items such as utilities and custodial services. If the utility bill-back is revised, update its local plan accordingly. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 18 Findings and Recommendations Siskiyou County SELPA Administrative Structure Siskiyou County SELPA Administrative Structure The county office serves as both the SELPA administrative unit and the operator of all regional special education classroom programs and related services for the SELPA. These are two distinct and independent functions that are not required to be performed by a single LEA. Even though the county office serves in both roles, it and the SELPA should be distinct entities. During interviews, SELPA member LEAs did not distinguish the functions and responsibilities of the SELPA from those of the county office, and most viewed them as the same entity. The SELPA has a 1.0 FTE associate superintendent/SELPA director who has two roles: implementing the SELPA’s local plan and administering the county office special education regional programs and services. The associate superintendent/SELPA director is employed by the county office, which is organized as shown in Figure 6 below. County Superintendent Deputy Associate Associate Associate Director Director Superintendent Superintendent Superintendent Superintendent Human DirectorHealth Director Maintenance Educational /SELPA District Support Business Resources Services Technology and Operations Services Director Services Figure 6: Simplified version of the Siskiyou County Office of Education’s organizational chart in 2023-24 Source: County Office-supplied documents. Associate Superintendent/SELPA Director Position Staff reported that the associate superintendent/SELPA director position has historically implemented the SELPA’s local plan and administered the county office special education regional programs and services. These dual roles have supported the belief that the SELPA and the county office are synonymous. However, the county office is one of the SELPA member LEAs; it is not the SELPA. To distinguish between the SELPA and the county office regional special education programs and services, the SELPA could consider splitting the 1.0 FTE associate superintendent/SELPA director position into two positions as described below. 1. A 1.0 FTE director of special education to lead the county office regional special education programs and services and be hired, directed, supervised, and evaluated by the county superintendent of schools. 2. A 1.0 FTE SELPA director who would be employed by the county office but selected, directed, supervised, and evaluated by the Siskiyou County SELPA’s governing board. If this change were made, the SELPA governing board and county superintendent of schools could deter- mine whether the SELPA could eliminate one of the county office’s principal/program manager positions, because the new county office director of special education could take on some of these duties. Splitting the associate superintendent/SELPA director position into two positions would also provide the SELPA director with time and capacity to facilitate the redefined roles and responsibilities of SELPAs as outlined in California’s System of Support (see details about the system below). Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 19 Findings and Recommendations Siskiyou County SELPA Administrative Structure California’s System of Support California’s public school accountability system, based on the Local Control Funding Formula (LCFF), includes a system of support as one of its central components. This new accountability and continuous improvement system includes a three-level framework: • Level 1 is support from state and local agencies for all LEAs and schools to improve perfor- mance across LCFF priorities. • Level 2 is differentiated assistance through county superintendents, the California Department of Education, charter authorizers, and the California Collaborative for Educational Excellence for certain LEAs to help improve low performance. • Level 3 is intensive intervention from the state superintendent of public instruction for LEAs that have persistent low performance. The main goal of California’s system of support is to help LEAs and their schools meet the needs of every student they serve. EC 52059.5(b) states that the purpose of the system of support is to build the capacity of LEAs in each of the following areas: • Support the continual improvement of student performance in each of the eight state prior- ities described in EC 52060(d). • Address the gaps in achievement between student groups identified in EC 52052. • Improve outreach and collaboration with education partners to ensure that the goals, actions and services described in school district and county office of education local control and accountability plans reflect the needs of students and the community, espe- cially for historically underrepresented or low-achieving groups. Because the LCFF holds LEAs accountable for improving student performance and narrowing performance gaps between student groups, and because the largest performance gaps are often among students with disabilities, SELPAs are uniquely positioned to use a network of well-established resources to help LEAs improve outcomes for these students. Role of SELPAs in California’s System of Support To help implement California’s System of Support, the SELPA Administrators of California have stated that the role and responsibilities of SELPAs need to shift to give priority to the following: • Participating in SELPA member LEAs’ Local Control and Accountability Plan (LCAP) process. • Building capacity of SELPA member LEAs to implement high-leverage and evidence-based practices. • Developing annual plans to ensure compliance with all federal and state laws and regula- tions, and with SELPA policies to align SELPA goals and services with SELPA member LEAs’ LCAP priorities. • Facilitating SELPA member LEA improvement efforts to ensure best practices and a culture of continual improvement. • Providing oversight and monitoring to ensure a full continuum of educational options (including oversight of NPSs). Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 20 Findings and Recommendations Siskiyou County SELPA Administrative Structure Although some of these new SELPA priorities are related to traditional SELPA roles and responsibilities, in the era of LCFF the SELPA Administrators of California have redefined the role of SELPAs to serve as capacity builders, facilitators, and connectors, as outlined in Table 4 below. Table 4: SELPA Administrators of California – Role of SELPAs SELPAs as Capacity Builders SELPAs as Facilitators SELPAs as Connectors SELPAs’ ability to connect is rooted in SELPAs provide targeted technical SELPAs facilitate equity in local decision- the foundation of shared leadership, local assistance resulting in quality programs making and access to the full continuum control, expertise in a variety of areas, and with aspirational goals for student of supports and services in the least relationships across many perspectives achievement and engagement in the least restrictive environment for students with - education, advocacy, community, and restrictive environment. disabilities. policy. As partners in quality assurance monitoring and differentiated assistance As a member of the system of support, processes, SELPAs use continual Leadership support for local governance SELPAs provide technical assistance, improvement as a framework for structures is provided by SELPAs in the including differentiated assistance and identifying equity gaps and improving allocation of resources and dissemination work with the LCAP development, to student outcomes. of essential information. improve student achievement. SELPAs encourage parent and community engagement within the LEAs through a SELPAs provide professional development community advisory committee (CAC) that on high-leverage and evidenced-based SELPAs collaborate with LEAs to provides a forum for collaboration, training, practices as well as collaborate with ensure alignment of statewide and local and advice about special education statewide reform efforts. improvement efforts. programs and services. Through interagency partnerships, SELPAs leverage resources and opportunities to help districts and families SELPAs build positive relationships among access specialized services and supports, education partners to ensure quality enhance learning opportunities, and outcomes for students by providing conflict develop innovative programs to improve prevention services and trainings. outcomes for children. Source: SELPA Administrators of California Website - SELPAs in the Statewide System of Support. Splitting the associate superintendent/SELPA director position into two positions would allow the SELPA director to focus on the redefined role of SELPAs to serve as capacity builders, facilitators, and connectors as outlined above. County Office Special Schools and Services Department Staffing In the 2023-24 fiscal year, the associate superintendent/SELPA director position oversaw six other positions in the Special Schools and Services Department, as shown in Figure 7 below. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 21 Findings and Recommendations Siskiyou County SELPA Administrative Structure Associate Superintendent/SELPA Director Executive Assistant Assistant SELPA Director Inclusion Principal/Program Principal/Program Principal/Program Specialist/Speech Manager Manager Manager Support Figure 7: Positions overseen by the Associate Superintendent/SELPA Director in 2023-24 Source: County-office-provided data. Staff reported that the assistant SELPA director position was removed from the 2024-25 county office special education program budget after it was not filled in 2023-24. Staff also stated that the county office added one principal/program manager position and eliminated the inclusion specialist/speech support position in its 2024-25 special education program budget for a total of four principal/program manager positions. Therefore, in the 2024-25 fiscal year, the county office Special Schools and Services Department will have 5.0 FTE administrator and leadership positions in the central office, as shown in Table 5 below. Table 5: County Office Special Schools and Services Department Administrator and Leadership Positions, 2024-25 Number of Position Title Positions Total FTE Associate Superintendent/SELPA Director 1 1.0 Principal/Program Manager 4 4.0 Total 5 5.0 Source: County-office-provided data. In the 2024-25 fiscal year, the county office Special Schools and Services Department will have 2.5 FTE administrative support staff, as shown in Table 6 below. Table 6: County Office Special Schools and Services Department Administrative Support Staff Positions, 2024-25 Position Title Number of Positions Total FTE Executive Assistant 1 1.0 Administrative Secretary 1 1.0 Data Management Specialist 1 0.5 Total 3 2.5 Source: County-office-provided data. Note: The department’s transportation supervisor and health services executive assistant were excluded from the total number of positions in this analysis and the below comparison becau2se7 n ot all county offices offer the services these positions provide. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 22 Findings and Recommendations Siskiyou County SELPA Administrative Structure Special Education Central Office Staffing Comparison FCMAT conducted an informal survey of county offices in California that are members of a multidistrict/ county office SELPA and have a countywide student enrollment similar to that of Siskiyou County. The survey focused on gathering information about county offices’ special education staffing in two areas: 1. Administrator/leadership positions, including positions such as directors, assistant directors, coordinators, program specialists, and teachers on special assignment (TOSAs). These positions do not necessarily require an administrative credential. 2. Administrative support positions, including positions such as secretaries, administrative assistants, filing clerks, and data technicians. Table 7 below compares Siskiyou County’s staffing to the responses from the two other county offices that replied to FCMAT’s survey. Among these comparison counties, the average number of FTE administrator/lead- ership positions that support special education is 3.5; Siskiyou County reports a higher figure of 5.0 FTE in this category. The special education administrative support positions in the central office average 2.0 FTE among the comparison districts, whereas Siskiyou County reports a slightly higher figure of 2.5 FTE. Table 7: Special Education Leadership and Support Staffing Comparison 2023-24 Special 2023-24 2023-24 2023-24 Census Education Administrator/ Administrative County Day Enrollment Enrollment Leadership Position FTE Support Position FTE Colusa County Office of Education 4,720 692 4.0 3.0 Inyo County Office of Education 3,946 526 2.9 1.0 Average FTE 3.5 2.0 Siskiyou County Office of Education 5,578 615 5.0 2.5 Sources: 2023-24 Enrollment By Subgroup Filtered by County - CDE and county office-provided information in response to FCMAT survey. Notes: Siskiyou County Office of Education was excluded from the average FTE calculations. Teachers on special assignments were included in administrator/leadership FTE if they performed special education program support functions in the county office. Any variances in FTE are due to FCMAT’s interpretation of the information shared via survey. The county office has 1.5 FTE more administrator/leadership positions and 0.5 FTE more administrative support positions for its special education program than the comparison county offices. Staff and SELPA member LEAs interviewed indicated that current staffing is appropriate given the large number of SELPA member LEAs, the great distance between districts, schools and SDCs in this relatively large county, and because only a few of the SELPA member LEAs employ their own special education staff. Recommendations The county office and SELPA should: 1. Consider splitting the 1.0 FTE associate superintendent/SELPA director position into two positions. 2. If the recommendation above is implemented, create a job description for a new county office director of special education position, and determine this position’s essential duties Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 23 Findings and Recommendations Siskiyou County SELPA Administrative Structure in the context of existing administrative positions that support the special education program. 3. If the first recommendation above is implemented, create a job description for a new SELPA director position that includes certain essential tasks from the current associate superintendent/SELPA director position and adds at least the following essential tasks: • Support SELPA member LEAs’ LCAP processes. • Build the capacity of SELPA member LEAs to implement highly effective evi- dence-based practices. • Develop annual assurance support plans to align SELPA goals and services with SELPA member LEAs’ LCAP priorities. • Support SELPA member LEA improvement efforts to ensure best practices and a culture of continual improvement. 4. If the first recommendation above is implemented, evaluate whether it can eliminate one principal/program manager position. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 24 Findings and Recommendations Professional Development Plan Professional Development Plan Special Education Staff Onboarding In addition to legally required trainings for new school employees, such as child abuse prevention training, a best practice is for new staff to receive information about an organization’s policies and procedures and training that is aligned with their job responsibilities. Staff reported that new county office staff receive mandated trainings and are required to participate in nonviolent crisis intervention training. However, most county office special education staff interviewed reported that their onboard- ing experience was inadequate to meet the needs of their positions in areas including electronic data management systems and Special Schools and Services Department policies and procedures. Staff turnover and the lack of a plan for training new employees contribute to these difficulties. This can cause inconsistent practices and may increase staff employee and turnover. The county office would benefit from developing a comprehensive onboarding plan for the Special Schools and Services department that is differentiated by position. The county office needs to consider providing training, as appropriate and based on a position’s job responsibilities, in at least the following areas: • County office mission and vision. • County office policies, procedures, organizational chart, and whom to go to with questions or when help is needed. • Special Schools and Services Department policies and procedures. • The SELPA-wide continuum of service options. • Positive behavior supports. • Nonviolent crisis intervention. • Use of curricular and instructional materials. • Use of electronic data management and reporting systems such as the student information system, and special education information system. Special Education Staff Ongoing Training The best practice is for special education staff to regularly receive training to develop their knowledge and skills and stay up to date with current research-supported, evidence-based practices. The county office annually sends some of its employees to training courses that are aligned with their job respon- sibilities. For example, in the past few years two school psychologists attended an Autism Diagnosis Observation Schedule training, a few special education teachers attended a Picture Exchange Communication System (PECS) Basic training, and the SELPA’s attorney provided training for some spe- cial education staff on special education-related legal requirements. Despite these opportunities, most county office special education staff interviewed reported needing additional training, and some staff reported that they had not been invited to attend a training they would have benefited from even though a colleague with the same or a similar job had attended. For example, a few special education teachers reported they would have benefited from attending the PECS Basic training, but only some teachers were able to attend. Contributing to these difficulties was staff turnover, a lack of Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 25 Findings and Recommendations Professional Development Plan substitutes so staff could be released to attend training, and the lack of enough paid time for training. This can hinder an employee’s job performance and increase staff stress and turnover. Based on interviews, the county office needs to consider offering professional learning for its special edu- cation staff in the following areas: • Trauma-informed care. • Sensory support needs. • Positive behavior supports. • Inclusive practices and differentiation. • Universal design for learning (UDL). Special Education Teacher Assistant Training The best practice is for special education teacher assistants to receive regular training so they gain an understanding of how to work with students with disabilities and stay up to date with research-supported, evidence-based practices. Staff reported that county office special education teacher assistants partici- pate in mandated training, and some receive additional formal training on topics such as nonviolent crisis intervention and/or informal training from their classroom teacher or by shadowing other special educa- tion teacher assistants. However, most county office staff members interviewed indicated that the county office’s special education teacher assistants have unmet training needs in critical areas such as: • Disability awareness. • Positive behavior supports. • Deescalation strategies. • Implementing accommodations and modifications. • Differentiation strategies. This training gap is exacerbated by staff turnover and a lack of substitutes that would allow for training to be provided during regular school hours. Identifying training time is particularly difficult in this county because many of the special education teacher assistants provide transportation for students before and after school, so training cannot be provided during those times. A lack of training may result in less effec- tive support for students and may create liabilities for the county office. Recommendations The county office should: 1. Develop a comprehensive onboarding plan for its special education staff, and ensure it is differentiated to meet the unique needs of each position and considers the areas mentioned in the “Special Education Staff Onboarding” section of this report. 2. Consider providing training for county office special education staff in the following areas: trauma-informed care, sensory support needs, positive behavior supports, inclusive practices and differentiation, and UDL. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 26 Findings and Recommendations Professional Development Plan 3. Survey the county office special education staff annually to understand their professional learning needs. 4. Develop a plan to facilitate better access for special education teacher assistants to professional development in areas such as disability awareness, positive behavior supports, deescalation strategies, implementing accommodations and modifications, and differentiation strategies. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 27 Findings and Recommendations Special Education Teacher Staffing Special Education Teacher Staffing FCMAT compared the county office’s special education teacher staffing for RSP and SDC programs to statewide guidelines and/or industry standards. Resource Specialist Program Staffing Education Code 56362(c) specifies a statewide guideline for RSP staffing and states: Caseloads for resource specialists shall be stated in the local policies developed pursuant to Section 56195.8 and in accordance with regulations established by the board. No resource specialist shall have a caseload which exceeds 28 pupils. In the 2023-24 fiscal year, the county office had 4.7 FTE RSP teacher positions. Based on caseload esti- mates provided by the county office, the 4.7 FTE RSP teachers managed the cases of 103 students, averag- ing 21.91 students per teacher, as shown in Table 8 below. Table 8: Resource Specialist Program Teacher Staffing, 2023-24 RSP Staffing Total RSP Teacher Total RSP Student Average RSP Teacher Above (+) or Below (-) FTE Caseload Caseload EC Standard 4.7 103 21.91 +1.02 Sources: County-office-provided data and EC 56362(c). SELPA-wide RSP teacher staffing is 1.02 FTE above what is needed to meet the EC 56362(c) standard. However, reducing RSP teacher staffing is not necessary because the EC 56362(c) standard is based on a maximum caseload, which is higher than the statewide caseload average commonly observed in LEAs with RSPs that have an inclusive model. Although its definition varies among California’s LEAs, the intent of an inclusive model is to enable students to attend their neighborhood schools, enroll and progress through the grade levels that match their chrono- logical ages, and access general education classes and curricula to the greatest extent possible. In addi- tion, under this model, specialized academic instruction is provided either in the general education class- room or through a pull-out service (in which a student is removed from the general education class setting for a period during the school day for specific skill building) depending on students’ needs. Overall, the SELPA’s LEAs use an inclusive model, which requires the current RSP teacher staffing to support students’ needs. The county office should continue to annually review data on RSP teacher caseload projections and student needs to determine whether adjustments to RSP teacher staffing are necessary. Special Day Class Teacher Staffing Self-Contained Classes for Students with Moderate-to-Severe Support Needs The county office operates regional, self-contained classes for students with moderate-to-severe support needs. The Education Code does not specify maximum caseloads for these programs, but the industry standard is 10-12 students per teacher. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 28 Findings and Recommendations Special Education Teacher Staffing In the 2023-24 fiscal year, the county office had 10.3 FTE teachers leading noncategorical moderate-to-se- vere SDCs. The county office reported that these teachers managed the cases of 77 students, as shown in Table 9 below. Table 9: Moderate-to-Severe Special Day Class Teacher Staffing in 2023-24 Total Total Teacher Teacher Student Caseload Industry Standard Caseload SDC Support Level SDC Focus FTE Caseload Average Range Moderate-to-Severe Noncategorical 10.3 77 7.48 10-12 students per teacher Sources: County-office-provided data and industry standards. The average caseload for teachers leading noncategorical moderate-to-severe SDCs is 2.52-4.52 students below the industry standard caseload range of 10-12 students per teacher. However, this appears appro- priate because students from different parts of this relatively large county are clustered into these regional SDCs. If the county office were to reduce the number of its noncategorical moderate-to-severe SDCs, some students would need to travel unreasonable distances to attend school. Self-Contained Classes for Students with Social- Emotional Needs The county office operates two regional, self-contained classes for students with social-emotional needs. The Education Code does not specify maximum caseloads for these programs and there is not an industry standard. In the 2023-24 fiscal year, the county office had 2.0 FTE teachers leading SDCs for students with social-emotional needs. The county office reported these teachers managed the cases of 11 students, for an average caseload of 5.5 students per teacher. This appears appropriate because the two classes cannot be combined into one because one class serves students in kindergarten through grade 8, and the other class serves students in grades 9 through 12. The county office will need to continue to annually review data on SDC teacher caseload projections and student needs to determine whether adjustments to SDC teacher staffing are necessary. Recommendations The county office should: 1. Continue to annually review data on RSP teacher caseload projections and student needs to determine whether adjustments to RSP teacher staffing are necessary. 2. Continue to annually review data on SDC teacher caseload projections and student needs to determine whether adjustments to SDC teacher staffing are necessary. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 29 Findings and Recommendations Special Education Teacher Assistant Staffing Special Education Teacher Assistant Staffing Special education teacher assistants, also known as instructional assistants or paraeducators, are trained professionals who work with students, usually under the direction of a classroom teacher. Special educa- tion teacher assistants work under different titles with distinct job descriptions to perform functions such as specialized academic instruction, specialized medical support, behavioral support, and 1-to-1 student support or special circumstance instructional assistance (SCIA). The county office employs special education teacher assistants under the following job titles: Behavior Management Assistant – The job description states, “Under the direction of a supervisor, this position will provide in-depth, intensive support to Siskiyou County stu- dents with behavioral issues including implementation of comprehensive positive behav- ioral support plans and effective behavior management strategies.” Speech Language Pathology Assistant – The job description states that under the direc- tion of a speech language specialist, this position, “…assists with language development, oral-motor control for speech production and vocalization. May also monitor the use of communication devices and systems.” Teacher Assistant – The job description states, “The Teacher Assistant performs a variety of general classroom assistance duties, physical assistance duties, specialized health care duties and does related work as required.” Teacher Assistant/Driver – The job description states, “The scope of duties includes a variety of general classroom assistance, physical assistance, specialized health care assis- tance, and providing transportation as defined in student IEPs.” Teletherapist Aide – The job description states, “Under the general supervision of a Speech/Language Specialist, the Teacher Assistant-Speech Aide assists with the instruc- tion, of developmentally, communicatively, or physically disabled children and youth to enable them to particulate in their environment as independently as possible.” Vocational Technician – The job description states that this position focuses on, “…increasing services for vocational education and community awareness and pupil programs.” Of these job categories, industry standard staffing ratios only exist for special education teacher assistants as described in the next section of this report. Special Education Teacher Assistant Staffing for Special Day Class Programs The industry-standard base staffing for SDCs is to assign one to two special education teacher assistants for every teacher in SDCs supporting students with mild-to-moderate and moderate-to-severe support needs. In SDCs for students with autism, the standard is two to four special education teacher assistants for every teacher. Additionally, the industry standard for staffing beyond the SDC base staffing is determined by an adult-to-student ratio, as shown in Table 10 below. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 30 Findings and Recommendations Special Education Teacher Assistant Staffing Table 10: Industry-Standard Teacher Assistant Staffing and Adult-to-Student Ratios Industry Standard Adult-to-Student SDC Support Level SDC Focus Special Education Teacher Assistant Staffing Ratio 1-2 six-hour special education teacher assistants Mild-to-Moderate Noncategorical depending on a class size of 12-15 1-to-7 1-2 six-hour special education teacher assistants Moderate-to-Severe Noncategorical depending on a class size of 10-12 1-to-5 2-4 six-hour special education teacher assistants All Autism depending on a class size of 8-10 1-to-3 Source: Industry standards. Notes: The industry-standard special education teacher assistant staffing should be determined by class size to meet the adult-to-student ratio. Both the classroom teacher and special education teacher assistant(s) are included in the adult-to-student ratio. Staff reported that the county office does not assign special education teacher assistants to its SDCs using adult-to-student ratios. In part this is because most of its SDCs have at least one teacher assistant/driver position, and in some SDCs all support staff are teacher assistant/drivers whose in-class hours are less than the full school day because they transport students. In addition, based on student needs, staff reported that some SDCs are assigned additional teacher assistant support. If the county office were to use industry-standard adult-to-student ratios to determine base staffing for its SDCs it could still increase support in certain SDCs to meet student needs and/or account for teacher assis- tant/driver schedules. Use of industry-standard adult-to-student ratios would help prevent an SDC from having more special education teacher assistant support than is necessary, which is costly and may limit the opportunities of students with disabilities to gain independence. 1-to-1 Student Support There is no industry standard for special education instructional assistants who provide 1-to-1 student support. Many LEAs throughout the state have taken steps to remove the designation of 1-to-1 support because it unintentionally reinforces the concept of one adult assigned to one student. Industry prac- tice commonly refers to both the assessment process and the special education instructional assistant descriptive title as an SCIA. The county office has licensed vocational nurses and one behavior management assistant who pro- vide 1-to-1 student support but does not have any special education teacher assistants who do so. The county office uses an SCIA process to assess whether a student requires 1-to-1 support, which is the best practice because it clarifies decision-making processes and procedures. This practice also recognizes that assigning 1-to-1 student support is a significant program decision that should be based on a thorough, data-driven evaluation that includes considering all less restrictive alternatives. Consistently requiring an SCIA assessment process to determine the need for 1-to-1 support ensures an LEA is making data-driven decisions and considering less restrictive alternatives before assigning 1-to-1 support. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 31 Findings and Recommendations Special Education Teacher Assistant Staffing Recommendations The county office should: 1. Assign special education instructional assistants to its SDCs using industry-standard base staffing and an adult-to-student ratio. 2. Consistently use its SCIA process to determine the need for 1-to-1 student support. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 32 Findings and Recommendations Related Service Provider Staffing and Caseloads Related Service Provider Staffing and Caseloads Related services are the developmental, corrective and other supportive services required to help a child with a disability benefit from special education (34 Code of Federal Regulations, 300.34). These services are written into students’ IEPs and include but are not limited to adapted physical education, speech and language therapy, and occupational therapy. FCMAT analyzed staffing ratios for the county office’s APE teacher, credentialed school nurses, teacher of students who are deaf or hard of hearing, teacher of students who are visually impaired, occupational therapists, school psychologists, and speech-language pathologists. Staffing ratios for other related service providers were not included in the analysis because there is no industry standard for those. The industry standards for related service providers are listed in Table 11 below. Table 11: Industry-Standard Provider-to-Student Ratios Industry Standard or Education Code Provider Type Provider-to-Student Ratio Psychologist 1-to-977 SLP (preschool) 1-to-40 SLP (ages five through 22) 1-to-55 APE Teacher 1-to-45-55 Physical Therapist 1-to-45-55 Occupational Therapist 1-to-45-55 Vision and Orientation and Mobility 1-to-10-30 Deaf and Hard of Hearing 1-to-15-25 Nurse 1-to-2,274 Source: Industry standards, EC 56363.3, and CalEdFacts - Publications (CDE). Adapted Physical Education In the 2023-24 fiscal year, the county office had a 1.0 FTE APE teacher who managed the cases of 21 stu- dents receiving direct services, as shown in Table 12 below. Table 12: APE Teacher Staffing in 2023-24 Staffing Number 2023-24 Total Caseload Industry Needed to Meet Industry Provider of FTE Caseload Average Standard Standard 0.47 FTE to meet 1-to-45 APE Teacher 1.0 21 21 1-to-45-55 0.38 FTE to meet 1-to-55 Sources: County-office-provided data and industry standards. Note: Only students receiving direct services from the county office’s APE teacher were included in the total caseload and related calculations. The county office needs a 0.47 FTE APE teacher to meet the 1-to-45 APE teacher to student ratio and a 0.38 FTE APE teacher to meet the 1-to-55 APE teacher to student ratio of the industry standard range. However, given that the county office’s APE teacher provides consultation for 64 students and has sig- nificant travel time to serve students countywide, current APE teacher staffing appears appropriate. The Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 33 Findings and Recommendations Related Service Provider Staffing and Caseloads county office needs to continue to annually review APE teacher caseload projections, the assessment load, direct and consultation service minutes, travel time, and student needs to determine APE teacher staffing. Credentialed School Nurses In 2023-24, the county office had 6.00 FTE credentialed school nurses, each of whom managed an average caseload of 930 students, as shown in Table 13 below. Table 13: Credentialed School Nurse Staffing in 2023-24 2023 Census Day Staffing Number of Countywide Caseload Industry Above (+) or Below (-) Provider FTE Enrollment Average Standard Industry Standard School Nurse 6.00 5,578 930 1-to-2,274 +3.55 FTE Sources: County office-provided data, CalEdFacts - Publications (CDE), and 2023-24 Enrollment for Charter and Non-Charter Schools - Siskiyou County. The county office is staffed at 3.55 FTE above the industry standard for credentialed school nurses. However, because of the significant travel time between districts and schools in this relatively large county, the county office’s staffing for credentialed school nurses cannot be compared to the industry standard. The county office needs to continue to review countywide enrollment, the assessment load, the number of districts and schools each school nurse is supporting, the travel time between them, school nurse duties, and student needs to determine if it needs to change school nurse staffing. Occupational Therapy In 2023-24, the county office did not employ any of its own occupational therapists but contracted with a nonpublic agency and independent contractors, who managed the cases of 115 students re- ceiving direct services, as shown in Table 14 below. Table 14: Occupational Therapist Staffing, 2023-24 Staffing Number 2023-24 Total Caseload Industry Needed to Meet Industry Provider of FTE Caseload Average Standard Standard Occupational 2.56 FTE to meet 1-to-45 Therapist N/A 115 N/A 1-to-45-55 2.09 FTE to meet 1-to-55 Sources: County-office-provided data and industry standards. Note: Only students receiving direct services from occupational therapists were included in the total caseload and related calculations. If the county office could recruit and hire its own occupational therapists, it would need 2.56 FTE occu- pational therapists to meet the 1-to-45 occupational therapist-to-student ratio, or 2.09 FTE occupational therapists to meet the 1-to-55 occupational therapist-to-student ratio of the industry-standard range. Hiring occupational therapists is difficult because of the statewide staffing shortage, so the county office is con- tracting for occupational therapists and a certified occupational therapy assistant, which meets present student needs. The county office will need to continue to annually review occupational therapist caseload Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 34 Findings and Recommendations Related Service Provider Staffing and Caseloads projections, the assessment load, direct and consultation service minutes, travel time and student needs to determine occupational therapist staffing. School Psychologists In 2023-24, the county office had 4.00 FTE school psychologists, each managing an average caseload of 1,394.5 students, as shown in Table 15 below. Table 15: School Psychologist Staffing, 2023-24 2023 Census Staffing Number Day Countywide Caseload Industry Above (+) or Below (-) Provider of FTE Enrollment Average Standard Industry Standard School Psychologist 4.00 5,578 1,394.5 1-to-977 -1.71 FTE Sources: County-office-provided data, CalEdFacts - Publications (CDE), and 2023-24 Enrollment for Charter and Non-Charter Schools - Siskiyou County. The county office is staffed at 1.71 FTE below the industry standard for school psychologists, partly because a staff member performing the comprehensive role of a school psychologist changed positions midyear to fill a position aligned with their credential. Inadequate staffing could cause staff to be unable to meet special education assessment timelines, and it limits the work a school psychologist can perform outside of special education assessment in areas such as prevention and intervention, crisis preparedness and response, instructional support, schoolwide practice development to support learning and positive student behavior, support for social-emotional learning, data collection and analysis, counseling, and mental health interventions. The county office employs other staff, including a 1.0 FTE marriage and family therapist who provides counseling services, and 2.0 FTE behaviorists who perform part of the comprehensive role of the school psychologist. Despite this, to determine if it needs to increase school psychologist staffing to better align with industry standards and support district, school and student needs, the county office needs to review at least the following: • The number of initial psychoeducational assessments in the current school year. • The number of annual and triennial psychoeducational assessments expected next school year. • The number of early reassessments expected next school year. • The number of specialized programs in the county and their support needs. • Countywide student enrollment. • Countywide special education enrollment. • Individual district and school needs. • Students’ direct and consultation service minutes provided by a school psychologist. Speech and Language Pathologists Education Code 56363.3 establishes the maximum caseload for SLPs who serve students ages five to 22 at 55 students, while EC 56441.7(a) establishes a maximum caseload of 40 students for SLPs who serve preschool-age students exclusively. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 35 Findings and Recommendations Related Service Provider Staffing and Caseloads Preschool and School-Age Blended SLP Staffing In 2023-24, the county office had 6.4 FTE SLPs serving students in the infant, preschool and school-age programs. Each managed an average caseload of 52.81 students receiving direct services, as shown in Table 16 below. The county office employs 2.4 FTE of these positions and contracts with a nonpublic agency for the other 4.0 FTE. Table 16: Infant through Grade 8 SLP Staffing, 2023-24 Staffing Number 2023-24 Total Caseload Industry-Standard Blended Below (-) Industry Provider of FTE Caseload Average SLP-to-Student Ratio Standard Infant through Grade 8 SLP 6.4 338 52.81 1-to-47.5 -0.72 FTE Source: County-office-provided data and EC 56363.3 and 56441.7(a). Note: Only students receiving direct services from an SLP were included in the total caseload for comparison with the industry standard. A blended average of the industry standards for preschool (1-to-40) and K-12 (1-to-55) was used (1-to-47.5) because the county office’s SLPs serve both groups of students. School-Age SLP Staffing In 2023-24, the county office had 2.0 FTE SLPs serving school-age students; both were contracted through a nonpublic agency, and each managed an average caseload of 64 students receiving direct services, as shown in Table 17 below. Table 17: School-age SLP Staffing, 2023-24 Number 2023-24 Total Caseload Industry Staffing Below (-) Provider of FTE Caseload Average Standard Industry Standard School-age SLP 2.0 128 64 1-to-55 -0.33 FTE Sources: County-office-provided data and EC 56363.3. Note: Only school-age students receiving direct services from an SLP were included in the caseload average for comparison with the industry standard. The county office is staffed 0.72 FTE below the industry standard for SLPs who serve students in the infant, preschool, and school-age programs, and 0.33 FTE below the industry standard for SLPs serving students in the school-age program only. The statewide shortage of SLPs contributes to the county office being staffed below the industry standard for SLPs. Adequate staffing allows county office SLPs to meet special education assessment timelines and provide students with both direct and consultation services. Given current staffing, SLPs are unlikely to be able to provide schoolwide support for language-related preven- tion and intervention. If SLPs were able to provide prevention and intervention services, it could reduce the need for special education identification. The county office needs to increase SLP staffing so that its average caseload size is under the Education Code maximum and adequate to meet student needs. In addition, the county office needs to annually review SLP caseload projections, the assessment load, time spent on direct and consultation services, travel time, and student needs to determine if it needs to change SLP staffing. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 36 Findings and Recommendations Related Service Provider Staffing and Caseloads Teacher for Students who are Deaf or Hard of Hearing In 2023-24, the county office had a 0.6 FTE teacher for students who are deaf or hard of hearing. This teacher managed the cases of seven students who received direct services, as shown in Table 18 below. Table 18: Teacher Staffing for Students who are Deaf and Hard of Hearing, 2023-24 Staffing Number 2023-24 Total Caseload Industry Needed to Meet Industry Provider of FTE Caseload Average Standard Standard Teacher for Students who are 0.47FTE to meet 1-to-15 Deaf or Hard of Hearing 0.6 7 7 1-to-15-25 0.28 FTE to meet 1-to-25 Sources: County-office-provided data and industry standards. Note: Only students receiving direct services from the county office’s teacher for students who are deaf or hard of hearing were included in the total caseload and related calculations. The county office needs a 0.46 FTE teacher to meet the 1-to-15 teacher-to-student ratio and a 0.28 FTE teacher to meet the 1-to-25 teacher to student ratio of the industry standard range. However, because the county office’s teacher for students who are deaf or hard of hearing provides consultation for one student who has a long travel time between districts and schools in this relatively large county, current teacher staffing appears appropriate. The county office will need to continue to annually review caseload projec- tions for this teacher position, the assessment load, direct and consultation service time, travel time, and student needs to determine staffing. Teacher for Students who are Visually Impaired In 2023-24, the county office had a 0.6 FTE teacher for students who are visually impaired. This teacher managed the cases of 15 students who received direct services, as shown in Table 19 below. Table 19: Teacher Staffing for Students who are Visually Impaired, 2023-24 Staffing Number of 2023-24 Total Caseload Industry Needed to Meet Industry Provider FTE Caseload Average Standard Standard Teacher for Students who 1.0 FTE to meet 1-to-15 are Visually Impaired 0.6 15 15 1-to-15-25 0.6 FTE to meet 1-to-25 Sources: County-office-provided data and industry standards. Note: Only students receiving direct services from the county office’s teacher for students who are visually impaired were included in the total caseload and related calculations. The county office needs a 1.0 FTE teacher to meet the 1-to-15 student-to-teacher ratio and a 0.6 FTE teacher to meet the 1-to-25 student to teacher ratio of the industry-standard range for teachers for stu- dents who are visually impaired. However, because this teacher provides consultation for six students and has a long travel time between districts and schools in this relatively large county, current teacher staffing appears appropriate. The county office needs to annually review caseload projections for the teacher for students who are visually impaired, the assessment load, direct and consultation service minutes, travel time, and student needs to determine if it needs to change staffing. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 37 Findings and Recommendations Related Service Provider Staffing and Caseloads Recommendations The county office should: 1. Continue to regularly analyze whether all related service provider staffing ratios are aligned with current laws and industry standards and are adequate to meet student needs. 2. Review school psychologist staffing using at least the factors mentioned in the “School Psychologists” section of this report to determine if it needs to increase school psychologist staffing to better align with industry standards and support district, school, and student needs. 3. Increase SLP staffing so that the average caseload size is under the Education Code maximum and is adequate to meet student needs. Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 38 Appendix Appendix Study Agreement Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 39 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 40 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 41 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 42 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 43 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 44 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 45 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 46 Appendix Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 47 Appendix Digitally signed by Michael H. Fine Michael H. Fine Date: 2024.02.06 10:09:10 -08'00' Fiscal Crisis and Management Assistance Team Siskiyou County Office of Education 48