FCMAT
Vista Unified School District Report
special education department and program review
Read the report at Vista Unified School District ↗
Vista Unified School District
Special Education Review
July 23, 2012
Joel D. Montero
Chief Executive Officer
Fiscal crisis & ManageMent assistance teaM
July 23, 2012
Devin Vodicka, Ed.D., Superintendent
Vista Unified School District
1234 Arcadia Avenue
Vista, CA 92084
Dear Superintendent Vodicka,
In March 2012, the Vista Unified School District and the Fiscal Crisis and Management Assistance Team
(FCMAT) entered into an agreement for a special education review. Specifically, the agreement stated that
FCMAT would perform the following:
Fiscal:
1. Conduct a comparison of the district’s special education encroachment on the
general fund with districts of comparable size.
2. Review all staffing levels for certified and classified special education employees.
Include management level and caseloads per full time equivalent.
3. Compare the percentage of students in nonpublic school to other districts in the
SELPA and region and make recommendations for alternative programs.
4. Analyze the allocation model for the NCCSE SELPA and determine if Vista
should become its own SELPA.
5. Analyze the infrastructure within the district to support single district status and
make recommendations for support ratios to make this transition.
6. Examine the costs of nonpublic agencies and the services provided and make
recommendations to reduce costs.
7. Examine high-cost programs such as California Avenue and Sierra Vista and deter-
mine if efficiency can be implemented.
Transportation:
1. Review the special education transportation system for efficiency and effectiveness
and determine any cost savings.
FCMAT
Joel D. Montero, Chief Executive Officer
. .
1300 17th Street - CITY CENTRE, Bakersfield, CA 93
.
301-4533 Telephone 661-6
.
36-4611 Fax 661-63
.
6-4647
422 Petaluma Blvd North, Suite. C, Petaluma, CA 94952 Telephone: 707-775-2850 Fax: 707-775-2854 www.fcmat.org
Administrative Agent: Christine L. Frazier - Office of Kern County Superintendent of Schools
2. Review the overall transportation delivery system, including but not limited to
reviewing the role of the IEP, routing, scheduling, operations and staffing.
Program:
1. Determine if the students are over identified for special education and make
recommendations for remediation if necessary.
2. Examine the exit rates and referral rates for special education and determine the
impact on over identification.
3. Review the special education delivery system and provide recommendations
to the district on additional classes or programs that would be necessary if the
district’s status changes to a single district SELPA.
4. Review state assessment results for special education subgroups and make recom-
mendations on how to improve results.
5. Through classroom and school visitations and interviews review the programs
and services available in the district for special education students and determine
efficiencies.
This final report contains the study team’s findings and recommendations in the above areas of
review. We appreciate the opportunity to serve the Vista Unified School District, and extend our
thanks to all the staff for their assistance during fieldwork.
Sincerely,
Joel D. Montero
Chief Executive Officer
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Table of conT enT s
Table of contents
About FCMAT .........................................................................................iii
Introduction ............................................................................................1
Background ......................................................................................................1
Study Team.......................................................................................................2
Study Guidelines ............................................................................................3
Executive Summary ..............................................................................5
Findings and Recommendations .....................................................7
Fiscal Analysis ..................................................................................................7
Staffing and Caseloads ...............................................................................15
Nonpublic Schools and Agencies (NPS/NPA) .....................................19
Single-District SELPA ...................................................................................27
Infrastructure .................................................................................................31
Program Efficiency.......................................................................................41
Transportation...............................................................................................49
Appendices ............................................................................................57
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Table of conT enT s
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About FCMAT
FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify,
prevent, and resolve financial and data management challenges. FCMAT provides fiscal and
data management assistance, professional development training, product development and other
related school business and data services. FCMAT’s fiscal and management assistance services
are used not just to help avert fiscal crisis, but to promote sound financial practices and efficient
operations. FCMAT’s data management services are used to help local educational agencies
(LEAs) meet state reporting responsibilities, improve data quality, and share information.
FCMAT may be requested to provide fiscal crisis or management assistance by a school district,
charter school, community college, county office of education, the state Superintendent of Public
Instruction, or the Legislature.
When a request or assignment is received, FCMAT assembles a study team that works closely
with the local education agency to define the scope of work, conduct on-site fieldwork and
provide a written report with findings and recommendations to help resolve issues, overcome
challenges and plan for the future.
Studies by Fiscal Year
90
80
70
60
50
40
30
20
10
0
92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11* 10/11**
*Projected
**Actual
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FCMAT also develops and provides numerous publications, software tools, workshops and
professional development opportunities to help local educational agencies operate more effec-
tively and fulfill their fiscal oversight and data management responsibilities. The California
School Information Services (CSIS) arm of FCMAT assists the California Department of
Education with the implementation of the California Longitudinal Pupil Achievement Data
System (CALPADS) and also maintains DataGate, the FCMAT/CSIS software LEAs use for
CSIS services. FCMAT was created by Assembly Bill 1200 in 1992 to assist LEAs to meet and
sustain their financial obligations. Assembly Bill 107 in 1997 charged FCMAT with responsi-
bility for CSIS and its statewide data management work. Assembly Bill 1115 in 1999 codified
CSIS’ mission.
AB 1200 is also a statewide plan for county office of education and school districts to work
together locally to improve fiscal procedures and accountability standards. Assembly Bill 2756
(2004) provides specific responsibilities to FCMAT with regard to districts that have received
emergency state loans.
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In January 2006, SB 430 (charter schools) and AB 1366 (community colleges) became law and
expanded FCMAT’s services to those types of LEAs.
Since 1992, FCMAT has been engaged to perform nearly 850 reviews for LEAs, including school
districts, county offices of education, charter schools and community colleges. The Kern County
Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D.
Montero, Chief Executive Officer, with funding derived through appropriations in the state
budget and a modest fee schedule for charges to requesting agencies.
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inTroduc Tion
Introduction
Background
With an enrollment of 22,500, the Vista Unified School District is one of the largest districts in
the North Coastal Consortium for Special Education in north San Diego County.
The district projects that a contribution of more than $14.5 million from the unrestricted general
fund to the special education budget will be necessary for the 2011-12 fiscal year. The SELPA
operates more than 100 special education programs and services for its 14 member districts, with
Vista USD as one of the largest providers of regional programs. The fiscal crisis in California has
prompted the district to review options to minimize the effect on its unrestricted general fund.
In March 2012 the district requested FCMAT to review its special education programs and
services. The study agreement specifies that FCMAT will perform the following:
Fiscal:
1. Conduct a comparison of the district’s special education encroachment on the
general fund with districts of comparable size.
2. Review all staffing levels for certified and classified special education
employees. Include management level and caseloads per full time equivalent.
3. Compare the percentage of students in nonpublic school to other districts in
the SELPA and region and make recommendations for alternative programs.
4. Analyze the allocation model for the NCCSE SELPA and determine if Vista
should become its own SELPA.
5. Analyze the infrastructure within the district to support single district status
and make recommendations for support ratios to make this transition.
6. Examine the costs of nonpublic agencies and the services provided and make
recommendations to reduce costs.
7. Examine high-cost programs such as California Avenue and Sierra Vista and
determine if efficiency can be implemented.
Transportation:
1. Review the special education transportation system for efficiency and effec-
tiveness and determine any cost savings.
2. Review the overall transportation delivery system, including but not limited
to reviewing the role of the IEP, routing, scheduling, operations and staffing.
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inTroduc Tion
Program:
1. Determine if the students are over identified for special education and make
recommendations for remediation if necessary.
2. Examine the exit rates and referral rates for special education and determine
the impact on over identification.
3. Review the special education delivery system and provide recommendations
to the district on additional classes or programs that would be necessary if the
district’s status changes to a single district SELPA.
4. Review state assessment results for special education subgroups and make
recommendations on how to improve results.
5. Through classroom and school visitations and interviews review the programs
and services available in the district for special education students and deter-
mine efficiencies.
Study Team
The study team was composed of the following members:
William Gillaspie, Ed.D. Laura Haywood
FCMAT Deputy Administrative Officer FCMAT Technical Writer
Sacramento, California Bakersfield, California
James “Sarge” Kennedy Larry Laxson
FCMAT Consultant FCMAT Consultant
Red Bluff, California El Cajon, California
Kerri Mills* JoAnn Murphy
Assistant Superintendent, Special Education FCMAT Consultant
Santa Barbara Unified School District Santee, California
Santa Barbara, California
Anne Stone
Tim Purvis* FCMAT Consultant
Director of Transportation Mission Viejo, California
Poway Unified School District
Poway, California
*As a member of this study team, this consultant was not representing his/her employer but was
working solely as an independent contractor for FCMAT.
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Study Guidelines
FCMAT visited the district on April 16 – 20, 2012, to conduct interviews, collect data and
review documents. This report is the result of those activities and is divided into the following
sections:
• Executive Summary
• Fiscal Analysis
• Staffing and Caseloads
• Nonpublic Schools and Agencies (NPS/NPA)
• Single-District SELPA
• Infrastructure
• Program Efficiency
• Transportation
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execuTive suMMary
Executive Summary
Vista USD contributes a greater portion of its unrestricted general funds to special education
than two districts of comparable size elsewhere in California and three of its neighboring districts
in the North Coastal Consortium of Special Education (NCCSE), of those FCMAT used for
comparison purposes.
Two separate factors control the level of unrestricted funds that must be expended for special
education programs and services. The first factor is the identification rate of disabled students
and the extent of the services they receive outside the general education classroom. The second
factor is the difference between federal, state and local funding and the excess costs for special
education services. Unrestricted funds must be used to pay for the funding shortfall and balance
the special education budget.
The district operates its programs and services on a traditional model with resource specialist
programs and special day classes. Caseloads for certificated staff are within statewide guidelines
and Education Code requirements. However, the nonseverely handicapped classes are overstaffed
with instructional aides compared to other districts, resulting in an excess cost of $480,000.
The district overidentifies students for special education. Its identification rate for disabled
students (K-12) is 11.79% compared to a statewide average of 10%.
The district lacks a comprehensive level of intervention for students at risk prior to referral for
special education. Attempts have been made to establish a Response to Intervention model, but it
is not applied consistently across the school sites. The district has limited options for non-English
speaking students, which results in referrals to special education.
A redesign of program offerings, such as a learning center model, would increase opportunities
for students to be educated in their home schools. In addition, it could eliminate approximately
10 bus routes and decrease transportation costs as much as $540,000.
The district rate of nonpublic school enrollment is .24%, which is slightly higher than other
districts in the SELPA but not significant. Greater efficiency can be achieved by reducing both
program and transportation costs by developing alternative program and service options in lieu
of nonpublic school enrollment.
The district’s current cost for nonpublic agency (NPA) services is $2,193,712. There are valid
reasons to use NPA services; however, the district should always monitor these expenditures and
ensure that whenever possible, district staff is utilized.
NCCSE has finalized a new allocation model to be implemented in the 2012-13 fiscal year. If
Vista USD became a single-district SELPA, it would receive the same average daily attendance
base rate and supplement that it would receive as a SELPA member. The district will need to
review this carefully when the new allocation model is implemented for factors such as growth or
decline in district enrollment, the effect of charter schools on funding and the provision of low
incidence programs that will require additional funds to be sent to NCCSE and will increase the
demands on the district’s SELPA infrastructure.
The district lacks the infrastructure to successfully operate as a single-district SELPA. The super-
intendent and other administrators have little confidence in the special education management
system, which impacts the department’s credibility. The staff lack confidence in district adminis-
tration to give accurate and consistent information. This is further impeded by a lack of defined
procedures in all levels of special education operation.
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A three-tiered bell schedule could achieve greater efficiency in transporting disabled students.
The current schedule is not sufficiently staggered to best utilize the district’s transport fleet. An
outline is included in this report that would efficiently stagger times and provide a savings of
approximately $120,000 to $240,000.
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fiscal analysis
Findings and Recommendations
Fiscal Analysis
At the district’s request, FCMAT determined that the total amount budgeted by the district for
the direct costs of special education in fiscal year 2011-12 was $41,438,559. Of this amount:
• $5,015,886 was budgeted for general and other unspecified services such as program
administration and supervision, school psychologists and nurses, and facilities and
maintenance.
• $1,408,735 was budgeted to provide services to children of preschool age.
• $13,302,861 was budgeted to provide special education services to school-age students
with severe disabilities (autism, severe intellectual disabilities, emotional disturbance,
visual and hearing losses or severe impairments, and severe orthopedic impairments).
• $21,711,077 was budgeted to provide services to school-age students with nonsevere
disabilities (specific learning disabilities, speech, voice, and language development
problems, and health impairments).
Additionally, $798,021 was indirectly charged to special education services for general district
support (district administration, business office, human resources, and landscape and building
maintenance).
The total expense budget for special education services for fiscal year 2011-12 is $42,236,580.
The district also asked FCMAT to determine the dollar amount needed from the unrestricted
general fund to balance the special education budget. Revenue to fund the excess costs of special
education comes from federal IDEA funds, state general funds and local property taxes, along
with the local unrestricted general funds necessary to balance the revenue and the total expendi-
tures.
By federal definition, excess costs for special education only begin to accrue after the costs of
educating disabled children exceed the district’s proportionate share of the average per pupil
expenditure calculated for all students. For example, a speech-impaired student spends very little
time receiving special education services, so 90% of his/her average per pupil expenditure will
be used in general education. On the other hand, the student who spends all of his/her time
receiving special education services will use all or nearly all of his/her average per pupil expendi-
ture for the special education he/she receives. Consequently, it is required that a school district’s
local general fund pay its share of the costs of special education first.
This is the first year that California districts have had to compute the average per pupil expendi-
ture (APPE) cost of special education. Based on the district’s total number of school-age students
with disabilities (approximately 3,048), previous percent of time receiving special education
services (36%), and the prior year’s APPE ($5,416), the threshold for arriving at excess costs is
approximately $5.9 million. The more students identified as having a disability plus the amount
of time they spend receiving special education services, the greater the amount the local unre-
stricted general fund will be required to provide before excess costs begin to accrue.
No provision is made in the state’s accounting system to enable a district to specifically budget
for this required use of general fund monies.
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California’s contribution toward the excess costs is based on AB 602 (1997-98), which sets
forth the state’s mechanism for allocating state aid for special education among the SELPAs.
Since then, that mechanism has been adjusted and has eroded the level of funding for SELPAs
throughout the state. The amount each district receives is determined by the SELPA, and
allocation plans for these funds vary widely throughout the state. Vista USD has budgeted state
revenues of $15,131,522 for fiscal year 2011-12.
Federal assistance primarily comes from IDEA Part B funding. At the outset, IDEA committed
to funding 40% of the national excess costs of special education. However, it has never reached
20% in the last 32 years, except 2009-10 when one-time funds brought the level up to 27%.
This has resulted in the local general fund having to support a much greater share of the excess
costs. The district budgeted $5,579,694 in federal revenue to assist with the excess costs of special
education.
The district has budgeted $20,711,216 for special education revenue. Subtracting the $6.4
million calculated above from the $20,711,216 leaves approximately $14.5 million required from
the local budget to pay the district’s share of the excess costs of special education and to balance
the special education budget.
Until recently, California has viewed the excess costs of special education as those costs that
exceed the state aid and federal local assistance provided for special education. The term given
to these excess costs was “encroachment.” It was as though the state aid and the federal local
assistance were intended to pay for the full costs of special education and if they didn’t, then the
district had to pay the balance from its unrestricted funds.
Fiscal comparisons among districts largely focused on the total expenditures from local sources.
However, current methods focus on the two factors (state and federal revenues) that affect the
levels of contribution that each district must make from their unrestricted funds.
The Individuals with Disabilities Education Act (IDEA) is essentially a civil rights act. As
such, it assumes that disabled children are entitled to their fair share of the district’s resources
as students of the district. Therefore, federal IDEA Part B funds can only be used to pay the
excess costs of special education. Recently the Office of Special Education Programs of the U.S.
Department of Education clarified the term “excess costs” and provided a format for computing
them.
CFR §300.16 Excess costs.
Excess costs means those costs that are in excess of the average annual per-student
expenditure in an LEA during the preceding school year for an elementary school or
secondary school student, as may be appropriate, and that must be computed after
deducting:
(a) Amounts received--
(1) Under Part B of the Act;
(2) Under Part A of title I of the ESEA; and
(3) Under Parts A and B of title III of the ESEA and;
(b) Any State or local funds expended for programs that would qualify for assistance
under any of the parts described in paragraph (a) of this section, but excluding any
amounts for capital outlay or debt service.
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(Authority: 20 USC 1401(8))
CFR §300.202 Use of amounts.
(a) General. Amounts provided to the LEA under Part B of the Act--
(1) Must be expended in accordance with the applicable provisions of this part;
(2) Must be used only to pay the excess costs of providing special education and related
services to children with disabilities, consistent with paragraph (b) of this section; and
(3) Must be used to supplement State, local, and other Federal funds and not to
supplant those funds.
(b) Excess cost requirement. (1) General.
(i) The excess cost requirement prevents an LEA from using funds provided under Part
B of the Act to pay for all of the costs directly attributable to the education of a child
with a disability, subject to paragraph (b)(1)(ii) of this section.
(ii) The excess cost requirement does not prevent an LEA from using Part B funds to
pay for all of the costs directly attributable to the education of a child with a disability
in any of the ages 3, 4, 5, 18, 19, 20, or 21, if no local or State funds are available for
nondisabled children of these ages. However, the LEA must comply with the nonsup-
planting and other requirements of this part in providing the education and services for
these children.
(2)(i) An LEA meets the excess cost requirement if it has spent at least a minimum
average amount for the education of its children with disabilities before funds under
Part B of the Act are used.
(ii) The amount described in paragraph (b)(2)(i) of this section is determined in accor-
dance with the definition of excess costs in §300.16. That amount may not include
capital outlay or debt service.
(Authority: 20 USC 1413(a)(2)(A))
The district must total all expenditures made for elementary and/or secondary students
(including those with disabilities) and then adjust that total by deducting specific expenditures.
The adjusted total is then divided by the total K-12 enrollment to arrive at an APPE.
The district must then determine a special education full-time student equivalency (FTSE) based
on the time each disabled student spends outside the general education setting receiving special
education services. For example, a student in a special class or nonpublic school would be 1.0
special education FTSE under this calculation. A student only receiving speech services twice
a week would be about a .05 special education FTSE. A student fully integrated in a general
education classroom with a full-time aide would be zero FTSE (he would be 1 FTSE in general
education and his full-time aide would be excess cost).
The district then totals the special education FTSE and multiplies that amount by the prior year’s
APPE to determine the level of unrestricted funds that must be expended. Once that amount is
expended, excess costs begin to accrue and IDEA Part B funds can be spent.
The effects of this factor are:
• a higher proportion of disabled students results in a higher level of unrestricted funds
that must be used before the district begins to accrue excess costs, and
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fiscal analysis
• the amount of time disabled students spend receiving services outside the general
education setting determines the amount of unrestricted funds that must be used before
the district begins to accrue excess costs.
FCMAT identified 10 comparable unified school districts in California, but only two responded
to the study team’s request for information. FCMAT compared the district’s special education
identification rate and special education FTSE with those of the two responding districts. The
information in these tables is derived from data used to calculate the excess costs of special educa-
tion, the maintenance of effort report known as SEMA, and relevant state data. The form used
by the district to calculate its excess cost can be found in Appendix A to this report.
Comparison Comparison
Vista USD District A District B
Adjusted total expenditures using IDEA
computation $139,975,764 $168,752,300 $184,595,103
Total K-12 enrollment (all students including
disabled) 25,843 26,822 26,574
Average per pupil expenditure (APPE) $5,416 $6,292 $6,946
Total unduplicated count of disabled stu-
dents (K-12) 3,048 2,021 2,434
Percentage of K-12 identified as disabled 11.79% 7.53% 9.16%
While the enrollments of the three districts are within 1,000 of each other, there are considerable
differences in their adjusted total expenditures ($30-$45 million) and less than $1,600 difference
among the average per pupil rates. The identification rate for Vista USD is much higher than
the two comparable districts. This will increase the level of APPE that will need to be expended
before excess costs begin to accrue.
Comparison Comparison
Vista USD District A District B
Full-time student equivalent of disabled students re-
ceiving services outside general education settings 1,094.61 666.08 870.05
FTSE as percentage of UDC 35.91% 32.96% 35.75%
Required expenditure of APPE funds before excess
cost accrues and IDEA funds can be expended $5,928,835 $4,190,975 $6,043,367
Vista USD’s disabled students spend considerably more time in special education settings than
students in the other two districts. As a result, although Vista USD has the lowest APPE rate, it
must spend almost $1 million more than Comparable District A and only $1.2 million less than
Comparable District B to meet the excess cost threshold.
As noted in the following chart, Vista USD must spend 4.24% of its total adjusted expenditures
to reach the excess cost standard, while the other two districts only need to expend 2.88% and
3.8% respectively to achieve that goal. This leaves a greater share of their unrestricted funds avail-
able for other uses.
The total amount of excess cost that each district expends is determined by subtracting the excess
cost threshold amount from each district’s total combined state and local expenditures for special
education programs and services.
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Comparison Comparison
Vista USD District A District B
Required expenditure of APPE funds before excess
cost accrues and IDEA funds can be expended $5,928,835 $4,190,975 $6,043,367
Required expenditures as a percentage of total
adjusted expenditures 4.24% 2.88% 3.87%
Total combined state and local expenditures for
special education $34,302,977 $33,432,632 $32,507,407
Excess costs of special education $28,374,143 $28,565,247 $25,371,696
Excess cost per K-12 pupil $1,098 $1,065 $955
Excess cost as a percentage of APPE 20.27% 16.93% 13.74%
Excess cost per UDC $9,309 $14,134 $10,424
Although the excess cost per UDC gives the impression that Vista USD has lower costs than its
two counterparts, its number of students identified as disabled is much higher than the other two
districts.
Vista USD has identified 11.79% of its K-12 enrollment as disabled, while Comparison District
A has identified only 7.53% and Comparison District B has identified 9.16%. Vista USD is well
above the statewide identification rate of 10% of the school-age population and above districts of
comparable size, which significantly affects its special education costs.
While Vista USD’s disabled students spend about the same proportion of time receiving educa-
tion services as those in the comparison districts, the higher identification rate means that a
proportionately larger share of Vista USD’s APPE, 20.27%, is spent providing special education
services. The comparison districts expend much smaller percentages of their APPE, 16.93% and
13.74%, to provide special education services.
FCMAT also compared two of the other three large unified school districts in the northern area
of the SELPA, Oceanside USD and Carlsbad USD. The data submitted by San Marcos USD,
the third large district in northern NCCSE SELPA, was not complete and couldn’t be used for
this comparison.
This comparison further shows the demand that is placed on a district’s unrestricted funds when
it overidentifies students as having a disability. This demand is exacerbated when the district does
not sufficiently emphasize placement in the least restrictive environment.
Oceanside Carlsbad
Vista USD USD USD
Total expenditures (EDP 365) $169,647,138 $147,540,632 $82,383,713
Current ADA 21,414 18,707 10,588
Current expense per ADA $7,922 $7,887 $7,781
Adjusted total expenditures using IDEA computation $139,975,764 $130,597,889 $70,429,883
Total K-12 enrollment (all students including disabled) 25,843 21,081 11,046
Average per pupil expenditure $5,416 $6,195 $6,376
Total unduplicated count of disabled students (K-12) 3,048 2,122 989
Percent of K-12 identified as disabled 11.79% 10.07% 8.95%
As noted above, both districts have lower identification rates than Vista USD.
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fiscal analysis
As shown in the table below, Oceanside USD has a much higher exit rate than Vista USD. As a
result, although it has a lower identification rate, the resulting effect on the use of APPE funds
for special education is greater than in Vista. Carlsbad USD’s lower identification and rate of
removal results in the least impact on its APPE funds.
Oceanside Carlsbad
Vista USD USD USD
FTSE of disabled students receiving services outside general
education settings 1,095 1,389 241
FTSE as a percentage of UDC 35.91% 65.48% 24.36%
Required expenditure of APPE funds before excess cost ac-
crues and IDEA funds can be expended $5,928,835 $8,608,025 $1,535,864
Carlsbad USD requires less of its APPE funds (which are unrestricted) to begin to accrue
before excess costs than the other two districts. For that reason, its excess costs per K-12 pupil,
per APPE, and per UDC are much higher. However, state aid and federal local assistance are
provided to assist the district with those excess costs.
Oceanside Carlsbad
Vista USD USD USD
Required expenditure of APPE funds before excess cost
accrues and IDEA funds can be expended $5,928,835 $8,608,025 $1,535,864
Required expenditures as a percentage of total adjusted
expenditures 4.24% 6.59% 2.18%
Total combined state and local expenditures for special
education $34,302,977 $23,366,935 $15,741,012
Excess costs of special education $28,374,143 $14,758,911 $14,205,148
Excess cost per K-12 pupil $1,098 $700 $1,286
Excess cost as a percentage of APPE 20.27% 11.30% 20.17%
Excess cost per UDC $9,309 $6,955 $14,363
The following table shows how the excess costs are funded and the source of those funds.
Oceanside Carlsbad
Vista USD USD USD
Actual total cost of special education $41,268,595 $28,353,713 $17,381,381
Required expenditure of APPE funds before excess
cost accrues and IDEA funds can be expended $5,928,835 $8,608,025 $1,535,864
Excess costs of special education $35,339,760 $19,745,688 $15,845,517
Federal share of excess costs $6,965,618 $4,986,777 $1,640,369
Remaining excess costs $28,374,143 $14,758,911 $14,205,148
State share of local costs $15,368,000 $11,207,572 $4,427,642
Local share of excess costs $13,006,143 $3,551,339 $9,777,506
Total local only expenditures reported $18,934,977 $12,159,363 $11,313,370
Total actual local support $(5,928,835) $(8,608,025) $(1,535,864)
Adjust for PCRA $5,812,645 $6,990,113 $2,584,982
Adjust for required APPE expenditure $5,928,835 $8,608,025 $1,535,864
Total local only expenditures $5,812,645 $6,990,113 $2,584,982
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fiscal analysis
The data strongly suggest that, if districts closely monitor their identification rate of disabled
students and increase the use of least restrictive settings, they can reduce the need for unrestricted
funds for special education purposes without making any other operational changes.
Recommendations
The district should:
1. Review and monitor identification processes to appropriately reduce the
identification rate of disabled students.
2. Develop and implement placement criteria that will ensure increased place-
ments in the least restrictive settings.
3. Implement changes to decrease costs and increase program efficiencies (see
the Program Efficiency section of this report).
4. Educate all stakeholders regarding the excess costs of special education and its
impact on the unrestricted general fund.
Vista UniFied school district
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sTaffinG and caseloads
Staffing and Caseloads
Resource Specialist Program
The district maintains average caseloads of 23 students in the resource specialist program, which
is within the statutory maximum caseload of 28 (Education Code Section 56362).
Education Code 56362 (6) (f) states that “at least 80 percent of the resource specialists within a
local plan shall be provided with an instructional aide.” The district exceeds the statutory instruc-
tional staffing level by 14 six-hour positions, or $448,000. In an effort to avoid layoffs the district
is reducing instructional aide hours from six to five per day through attrition. This has decreased
hours by the equivalent of 2.6 six-hour positions ($83,000), reducing the excess staffing costs to
$365,000. Currently, 45.6 full-time instructional aides and 16 five-hour aides support resource
specialist programs. If the district continues to reduce hours each year, the excess costs will even-
tually be eliminated.
Special Day Classes
The district operates both severely handicapped and learning handicapped classes for K-12. The
average class size for severely handicapped is 11 students and the average class size for learning
handicapped is 12.5. These averages are consistent with guidelines established by School Services
of California (SSC). The preschool special day classes at California Avenue School will be
analyzed in another section of this report.
Instructional aide staffing for severely handicapped classes is consistent with the statewide average
reported by SSC; however, the staffing for learning handicapped classes at the elementary exceeds
statewide levels. Each class has two six-hour aides, while average staffing is one six-hour aide per
class. The additional staffing costs approximately $480,000. The learning handicapped classes at
the middle school and high schools are staffed consistent with SSC guidelines. Additional staffing
provided for students requiring 1:1 aides is not included in these calculations.
Average SDC and Instructional Aide Support vs. 2008 SSC Guidelines
SDC Classes/No. SSC Average Vista Average SSC Aides Vista Aides
of Aides Assigned Students Per Class Students Per Class Per Class Per Class
LH/48.8 12-15 13 1 aide (6 hr.) 2 aides (6 hr.)
SH/21 8-10 11 2 aides (6 hr.) 2 aides (6 hr.)
School Psychologists
The ratio of psychologists to general education enrollment in California is 1:1466 as reported
by the California Department of Education’s (CDE’s) CalEdFacts (2010-11). The district ratio
is 1:1454. While the district’s psychologist staffing is in line with recent practice in California,
the staff indicated concern over the lack of pre-referral interventions, potentially increasing the
identification rate.
FCMAT found that over a three-year period the number of referrals remained consistent, yet the
number of referrals that led to eligibility decreased. As the district engages in strategic planning
for special education, the referral and identification rates should be addressed in the context of
developing an effective Response to Intervention model.
Vista UniFied school district
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sTaffinG and caseloads
Referral Rate vs. Eligibility for Special Education (districtwide)
School Year No. of Referrals Eligible
2009-10 280 221
2010-11 298 232
2011-12 274 188
The administrative and teaching staff reported that students who are English language learners
are often found eligible for special education because of limited resources. At some sites special
education is the only option to support these students. Staff also reported that these students are
not exited from special education and do not make significant progress while in the program.
Initial assessments are not routinely conducted in the student’s native language, and until
recently triennials were not completed for any secondary-level student. These two factors have
contributed to English language learner students being inappropriately placed and kept in special
education.
Some students are found eligible for special education when behavior is the primary reason for
their lack of success in regular education. Although the assessment teams try to differentiate
between behavioral and special education eligibility, pressure from school sites, families and advo-
cates as well as lack of other services have resulted in these students being inappropriately placed
in special education.
The district has a student study team (SST) process at each school, but it is inconsistent among
schools. Staff reported that in some cases the SST is still considered the gatekeeper for special educa-
tion assessment. In other cases it is a problem-solving group that only considers special education
after specific intensive interventions have been implemented and found to be unsuccessful.
The level of Response to Intervention (RtI) also varies among schools. Schools that are in
Program Improvement tend to have funds to support some RtI while other schools do not. All
schools have been given curriculum to support students prior to a special education referral, such
as the program Language!, but curriculum implementation varies by site.
In some cases the special education teacher provides the RtI intervention. This may mean that
only some general education students or only some special education students receive this
intervention. If the intervention is designed to move students from just below basic to basic and
improve AYP scores, then many special education students who would benefit from the interven-
tion do not have access to it.
Designated Instruction Services
District caseloads for staff providing designated instruction services (DIS) were compared to
SSC’s recommended guidelines, Education Codes 56441.7(a) and 56363.3 and CBEDS data and
outlined in the following table.
Average DIS Caseloads vs. SSC Guidelines and Education Code
SSC Guidelines/
DIS Position Education Code District
Speech Therapist Average 55 50
Occupational Therapist Average 55 55
Adaptive Physical Education Average 55 55
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sTaffinG and caseloads
The district’s caseload numbers fall within the Education Code and SSC guidelines.
Recommendations
The district should:
1. Continue to reduce six-hour instructional aide positions in the Resource
Specialist program to five hours per day through attrition to staff instructional
support at the mandated level outlined in Education Code Section 56362.
2. Reevaluate the current practice of staffing elementary SDC/LH classes with
instructional aides at a level that exceeds statewide averages.
3. Monitor student study teams at each site and ensure that consistent processes,
forms and data are used to determine RtI interventions and assessment for
special education.
4. Review the RtI plans at each site to ensure more consistency among sites as to
the interventions provided and the level of special education staff support to
provide them.
5. Train administrators in the use of effective RtI interventions.
6. Identify appropriate interventions for all sites to use.
7. Continue to maintain DIS caseloads with statewide guidelines.
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nonP ublic sc Hools and a Gencies (nP s/nP a)
Nonpublic Schools and Agencies (NPS/NPA)
Nonpublic Schools
A nonpublic school (NPS) is defined in the California Education Code as a “private, nonsec-
tarian school that enrolls individuals with exceptional needs pursuant to an individualized educa-
tion program and is certified by the department. It does not include an organization or agency
that operates as a public agency or offers public service, including, but not limited to, a state
or local agency, an affiliate of a state or local agency, including a private, nonprofit corporation
established or operated by a state or local agency, or a public university or college. A nonpublic,
nonsectarian school also shall meet standards as prescribed by the Superintendent and board.”
(Education Code 56034). In addition, “... These services shall be provided pursuant to Section
56366, and in accordance with Section 300.146 of Title 34 of the Code of Federal Regulations,
under contract with the local educational agency to provide the appropriate special educational
facilities, special education, or designated instruction and services required by the individual with
exceptional needs if no appropriate public education program is available.” (Education Code
56345 (a)).
FCMAT reviewed the percentage of students attending an NPS in each of the SELPA member
districts. The June data includes all students enrolled in an NPS during the school year. Vista
USD’s rate of 0.24% is slightly higher than the other unified districts in the SELPA. Elementary
districts tend to have fewer NPS placements, while the high school districts tend to have more
NPS placements than unified districts. Therefore, it is most accurate to compare Vista USD with
the other SELPA unified districts.
Nonpublic School Placements by SELPA Member Districts
Nonpublic School District enrollment Percentage of students
District Students 2010-11 2010-11 in a nonpublic school
Bonsall Elementary 1 1967 0.05%
Cardiff Elementary 0 769 0.00%
Carlsbad Unified 20 11,063 0.18%
Del Mar Elementary 12 4,387 0.27%
Encinitas Elementary 1 5,475 0.02%
Fallbrook Elementary 0 5,816 0.00%
Fallbrook HSD 3 2,867 0.10%
Oceanside Unified 27 20,987 0.13%
Rancho Santa Fe
Elementary 0 674 0.00%
San Dieguito HSD 64 12,485 0.51%
San Marcos Unified 41 19,117 0.21%
Solana Beach
Elementary 2 2,879 0.07%
Vallecitos Elementary 0 661 0.00%
Vista USD 62 25,739 0.24%
Source: June 2010 California Special Education Management Information System (CASEMIS) data with each district’s 2010-11
enrollment data from Data Quest.
Vista UniFied school district
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nonP ublic sc Hools and a Gencies (nP s/nP a)
The NCCSE SELPA member districts use the same NPS contracts and negotiated rates. Unlike
most county offices of education in California, the San Diego County Office of Education does
not operate special day programs for disabled students. Therefore, this county has a higher NPS
usage.
The district contracts with 14 nonpublic schools, four of which have a residential component.
Fifty-three Vista USD students attend these schools, nine in residential placement and 44 in day
programs.
Residential NPS programs are indicated by a star in the table below. In the past, the Department
of Mental Health had been the determining agency for the residential placements and funded
that portion of the placement. Changes in legislation (Assembly Bill 114, Chapter 43) now
require school districts to assume responsibility for both the educational and residential costs.
With changes in funding and in the agency that the district contracts with to provide therapeutic
services, the number of students in residential placement may decrease. Providing the appropriate
educational program and therapeutic support will be the key to bringing those students into a
district program.
Vista Students in Nonpublic School Placements, April 2012
No. of Vista
Nonpublic School USD Students Grade Range and Types of Disabilities Served
Attending
Arch Academy 1 Grade 11 - Autism, emotional disturbance
Balboa 1 Grade 11 - Autism, intellectual disability
Banyan Tree 1 Grade 11 - intellectual disability
Institute for Effective Education 1 Transition - post high school
New Bridges 1 Grade 5 - Learning disability
New Haven ** 15 Grades 7-12 - Behavior
Oak Grove ** 3 Grades 4-11 - Behavior
Provo Canyon ** 2 Grade 11 - Emotional disturbance
San Diego Center for Children
3 Grades 7-10 - Emotional disturbance
Academy **
Sierra 4 Grades 7-12 - Emotional disturbance
Stein 3 Grades 7- post high school - intellectual disability
Summerhill 2 Grades 9-12 - Learning disabilities
Grades 4-post high school - Autism, behavior and
Terri 13
intellectual disability
Winston 3 Grades 6-11 - Learning disabilities
According to a School Innovations and Advocacy report dated April 2009, 61 district students
were placed in an NPS in 2007-08. The cost for those placements was $2,085,060. The current
cost for the 53 students in NPS placements is projected to be $1,427,016, or a reduction of
$658,044. Neither amount includes the cost for the residential portion of the student’s place-
ment because this was not a factor in 2007-08.
Los Angeles USD has provided SELPAs with its list of nonpublic schools and the fees associated
with those contracts. FCMAT compared that list with Vista USD’s NPS contracts to determine
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nonP ublic sc Hools and a Gencies (nP s/nP a)
if Vista’s rates were equitable. Only three sites were on both lists: New Haven, Oak Grove and
Provo Canyon. The rate paid by the district for New Haven was the same as for LAUSD, was $2
more per day for Oak Grove and was $13 more per day for Provo Canyon. If the district becomes
its own SELPA, this type of information will be helpful in negotiations.
District staff consistently expressed several concerns regarding the initial and continued place-
ment of students in an NPS. No clear, written process exists to refer a student to an NPS. This
may lead to students being referred to an NPS because of behavioral issues that have not been
fully addressed in the district program. Staff reported that when students are placed in an NPS,
goals and a transition plan to return the student to a district program are not included in every
individualized education program (IEP). The lack of a clear plan for transition and the lack of
district support available to address behavioral issues result in few students returning to district
programs from nonpublic schools.
Students who move into the district with an NPS placement in their IEP are immediately placed
into as similar a facility as possible. For example, students who are placed through probation or
other agencies into the New Haven residential facility are usually also placed at the New Haven
NPS. A written process is needed that requires consideration of district programs before an
interim placement at an NPS.
Students who no longer benefit from the North Coastal Consortium of Special Education
(NCCSE) day treatment program (NCCSE SELPA Handbook) have no district option to meet
their IEP requirements and are therefore placed into an NPS.
Regional classes for emotionally disturbed students, referred to as Social Emotional Academic
Support (SEAS) classes, have a capped number of students in each class based on grade. Students
who would be eligible for these classes are placed in an NPS when the SEAS class is at its caseload
limit.
The district does not have behavioral specialists to support students in general education or
special education. The SEAS programs are structured for emotionally disturbed students, not
behaviorally challenged students. Behavior plans and supports for emotionally disturbed students
are not appropriate for behaviorally challenged students. Yet, staff reported that students with
behavioral issues are often placed in the SEAS classes because no other district options exist for
those students.
Some students, due to their very specific and low-incidence disabilities, may always require an
NPS placement. However, providing district programs for most students in placements is cost
efficient and would enable the district to more closely monitor the students’ programs and
provide services in the least restrictive environment (LRE). This could include additional coun-
seling for some students, or classes that provide the level of structure needed for students with
significant behavioral issues.
The midpoint of the SELPA salary schedule was used to estimate the cost for the district to
develop a class for 10-12 students with significant behavioral issues.
One teacher $83,000
Three aides $120,000
1/2 psychologist/counseling $43,000
Total $246,000 or $20,500 to $24,600/student
Vista UniFied school district
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nonP ublic sc Hools and a Gencies (nP s/nP a)
The average cost of a Vista USD student in an NPS, based on the 2011-12 contracts, is $27,000
per student plus the cost of transportation. Providing a district program for these students would
save an estimated $24,000 without including the transportation costs. Educational reasons for
developing district programs in lieu of NPS programs include the benefit students receive by
being educated in their district of residence and the district’s ability to monitor the quality of
the educational program. These benefits include access to district curriculum, taking part in all
extracurricular activities, and increased opportunities for mainstreaming.
An even less costly way to serve some of the behaviorally challenged students who are now in
nonpublic schools, district SDC programs and regional SEAS classes is to form a team of highly
skilled behavior specialists and instructional assistants who could develop behavior plans, train
teachers and aides to implement behavior plans, model for teachers and aides and provide
immediate support in emergency situations. The team could help reduce NPS, district SDC and
regional SEAS placements, and the number of suspensions and expulsions.
This type of district support could be developed in the areas that staff stated were the main
reasons for the NPS placements: behavior associated with autism, learning disabilities
or emotional disturbance. The district has the start of this type of support in its Autism
Collaboration Teachers (ACT), which will be discussed later in this report.
The estimated cost for a behavior team using average district salaries is:
School psychologist or behavior specialists $86,000
Three trained instructional assistants $120,000
Total $206,000
Cost per student with 25 students per team $8,240/student
Recommendations
The district should:
1. Continue using the same contract as the other SELPA member districts, with
the SELPA negotiating the contracts for NPS placements to ensure appro-
priate contract language and consistent rates. If the district becomes its own
SELPA, participate with the other San Diego SELPAs in contract develop-
ment and rate negotiation.
2. Carefully review each residential placement and determine whether either a
current district/regional program or a new district program could meet the
student’s needs. If so, schedule an IEP to discuss returning the student from
the residential NPS.
3. Use information provided by the Los Angeles USD to assist with negotiating
contracts.
4. Develop clear procedures for determining when a student should be referred
to an NPS program. If the primary reason for placement is behavioral, ensure
that a functional analysis is completed and a full behavior intervention plan
developed and implemented before the referral.
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nonP ublic sc Hools and a Gencies (nP s/nP a)
5. Ensure that goals and a transition plan to return the student to a district
program are included in every nonpublic school IEP.
6. When a student enrolls with an IEP for an NPS, consider all district/regional
options. Discuss with the special education director whether developing
programs or services would enable the student to attend a district/regional
program.
7. Determine what additional classes may be needed because current classes are
at maximum capacity or because components of classes do not meet the needs
of students now in an NPS.
8. Train or hire staff highly skilled in developing and implementing intensive
behavioral plans for students with behavioral issues.
9. Continue placing students with unique needs in an NPS, with goals and
transition plans in every IEP to return them to a district/regional program.
Nonpublic Agencies
The Education Code for nonpublic schools is now the same as for nonpublic agencies. A
nonpublic agency (NPA) must “be under contract with the local educational agency to provide
the appropriate special educational facilities, special education, or designated instruction and
services required by the individual with exceptional needs if no appropriate public education
program is available.” (Education Code 56345 (a).
Vista USD contracts with 12 NPAs and 10 independent contractors to provide special education
related services for students. According to the School Innovations and Advocacy report dated
April 2009, the district was spending $2,386,056 for NPA services. The projected budget for
2011-12 is $1,968,035, which is $418,201 less. However, it was not clear from the SI&A report
if there were additional costs for independent consultants or if those costs were included in the
NPA costs. When the current independent contractor costs are added to the NPA costs, the total
amount is $2,193,712, which is still a reduction of $192,344.
The district provides these services through NPAs: autism, speech, physical therapy and nursing.
Vista Students Receiving NPA Services in April 2012
No. of Vista students Grade range and type
Nonpublic Agency
receiving services of service provided
ACES 1 Grade 6 - Autism
Autism Experts Empowering Families
2 Grades 5-6 - Autism
and Children Together
Autism Spectrum Consultants 2 Grades K-7 - Autism
Banyan Tree 1 Grade 12 - Behavior
EBS All grade levels Multiple - Speech
Dependable Nursing 5 Grades 1-12 - Nursing
Grades preschool - 5 -
Functional Therapy 7
Physical Therapy
Vista UniFied school district
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nonP ublic sc Hools and a Gencies (nP s/nP a)
No. of Vista students Grade range and type
Nonpublic Agency
receiving services of service provided
Interim Health Care 1 Nursing
Maxim 5 Nursing
Pathways 2 Speech All grade levels Multiple - Speech
Progressus All grade levels Multiple - Speech
Summit All grade levels Multiple - Speech
The district also contracts for autism, nursing, occupational therapy and speech services. When
a district provides these services through an independent contractor, it is usually because the
district could not find an NPA to contract with or because of a specific resolution with a family.
Services such as transition, escort, interpretation, music therapy and vision therapy are typically
provided under independent contract.
Independent Contractors
Grade range and type
Independent Contractor of service provided
BHR Speech Multiple - Speech
Coast Music Therapy Multiple - Evaluations/IEPs
Daniel and Daniel Optometry Multiple - Vision Therapy
Employment and Community Options 18-22 Transition services
Hebner Systems Occupational Therapy
Karen Lonsway Multiple - Speech
Network Interpreter Multiple - Interpreter
Palomar Pomerado Health Multiple - Nursing
The Autism Group Multiple - Autism
West Shield Adolescent Services Escort
The number of Vista USD students receiving services was not identified on these contracts.
For 2011-12 the district has estimated the cost of the independent contracts at $225,677. This
amount includes $160,000 that could be provided by an NPA. Contracting with an independent
contractor may or may not be cost effective for the district.
A significant portion of the NPA and independent contracting costs are for students with
autism. The estimated NPA costs based on the projected budget for 2011-12 is $229,013, plus
contracted services of $13,000, for a total of $242,013. Alternatives to these costs are discussed
in the section of this report regarding district programs.
The district expends $419,106 in NPA nursing services and $75,000 in contract nursing services.
In some cases, due to the medically fragile nature of a specific student or the agreement through
the IEP with a student’s family, hiring a nurse through an NPA or independent contract may be
necessary. Hiring nursing staff can be very challenging. A close review is warranted to determine
whether it would be both programmatically effective and cost efficient to hire more nurses to
provide these specific services.
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Speech is another high-cost area for the district with regard to NPA and independent contracts.
Districts around the state contract with NPAs for speech therapists, who can be difficult to hire
because they are in high demand. Vista USD has 17.85 FTE who are contracted speech thera-
pists out of a total 39.45 FTE for a projected cost of $2,386,056. This is $677,509 less than the
2009-10 fiscal year. Based on the total cost of the NPA and independent contracts, the average
cost of a contracted speech therapist is $80,649, which is approximately $6,000 less than the
average cost of a district-employed speech therapist.
This is certainly a cost savings, but has significant drawbacks. District employees tend to stay
with the district, while contract employees often change yearly. Contract employees tend not to
invest in working relationships with district staff; district staff must provide training yearly on
how the district provides services; the district does not evaluate the contracted employees, and
therefore the quality of therapy may not be at the level of district employees. These factors should
be considered in deciding whether to hire more speech therapists as district employees or to
continue contracting.
Occupational therapists also are an area of high cost, both through the NCCSE Regional costs
and an additional MOU with NCCSE. The district also has a $75,000 contract with an occu-
pational therapist. As with speech therapists, it can be difficult to hire an occupational therapist.
The district does not have certified occupational therapy assistants (COTAs). Districts often hire
COTAs to provide some occupational therapy to students, allowing the occupational therapist to
provide evaluations, develop treatment plans and attend IEP meetings. Employing COTAs also
enables the occupational therapist to carry a larger caseload since they do not deliver all of the
daily therapy.
The NCCSE charges for services should be considered in the cost of NPA and independent
contractor services. These include two occupational therapists at $209,644, one speech and
language pathology assistant at $54,011, and six sign language interpreters at $255,450. The
NCCSE also charges $649,743 for assistive technology support, program specialist and occu-
pational therapist services that are first paid from the NCCSE budget and then charged to the
district based on the district’s ADA.
Recommendations
The district should:
1. Determine if it is cost efficient to contract with an NPA rather than an inde-
pendent contractor for each service that an NPA could provide.
2. Review all IEPs that include nursing services to determine if the district could
provide those services through newly hired or current district employees at a
cost savings.
3. Contract for speech therapists when necessary, and continue to recruit district
speech therapists to provide more stability in services.
4. Review all IEPs requiring occupational therapy to determine if these services
are still required. Then determine the number of occupational therapists
needed to provide the services and whether hiring district staff and COTAs
would be more cost efficient than the SELPA contract.
Vista UniFied school district
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sinGle- disTricT sel Pa
Single-District SELPA
The SELPA has begun to review its funding allocation model to achieve greater funding equity
among its members. This is fairly common among California’s SELPAs. When the transition was
made from the prior J-50 funding model to the AB 602 funding model, most SELPAs, including
NCCSE, established allocations that ensured minimal fiscal harm to any member.
Despite significant demographic changes over the last decade, little was done to determine
whether or not the funding allocation was equitable. As many SELPAs have discovered, “equal”
and “equitable” are not synonymous.
Among the ten guiding principles for the creation of funding models for special education
services contained in the Master Plan for Special Education are:
• Provide adequate resources to assure equality of educational opportunity for all
individuals with exceptional needs.
• Provide levels of support for special education programs which will promote programs
and services of equal quality.
• Ensure equity in support levels among various program components.
(California Master Plan for Special Education, California State Board of Education, Jan. 10, 1974, Pages 36-37).
Because SELPAs are responsible for disabled students residing within their boundaries, the
funding model should ensure that all these students receive the same level of service. For
example, if a student were to move from Carlsbad or Vista to Vallecitos, the funding model
should ensure that Vallecitos is financially able to provide the same services the child previously
received.
This concept is also found in guiding principles adopted by a number of SELPAs for use in
developing equitable funding models, which include:
• The allocation plan is the means by which the SELPA distributes funds it receives from
county property taxes, state, and federal sources to the local educational agencies to assist
in paying the excess costs of providing special education services.
• These are communal monies, not the property of the recipient. Each member has a
legitimate stake in the equitability of the allocations and in how other members use the
resources.
• No member should accrue undue benefit at the expense of other members. Thus, the
allocation model must be fair, equitable, and transparent to all members.
A preliminary review of the allocation model of the NCCSE (SELPA) indicates that Vista USD
would receive net funding from the SELPA in 2012-13 of $15,299,617, or $628 per ADA. This
would be $3,633,427 less than it receives under the current model.
If Vista USD became a single-district SELPA, it would receive the same base rate of $639.10 and
supplement of 72.8 cents that NCCSE receives. Based on enrollment of 24,307, it would receive
$15,592,608. It would also receive the same property taxes as it does now, but that amount
would be subtracted from the base funding of $15.5 million. That’s neither a gain nor a loss,
because property taxes are a part of the calculated base funding.
Based on information from CDE, the single-district SELPA would receive an additional
$4,532,063 in IDEA funding. The SELPA distributes IDEA funds based on the unduplicated
Vista UniFied school district
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sinGle- disTricT sel Pa
pupil count, while the state must follow the federal formula. This formula provides the same
amount the district would have received in the base year (1999) of $1,523,730 and prorates any
additional funds on an 85% basis based on the relative California Basic Educational Data System
enrollment compared to the rest of the state ($2,570,250), and a 15% basis based on its relative
rate of poverty compared to the rest of the state ($430,083).
If growth occurs between this year and next, it will be based on a comparison of Vista USD’s
current-year ADA with that of the previous year, and the increase would be computed using the
state target rate ($465.44), a much lower figure than its base rate ($639.1728).
If enrollment decline continues, it would be calculated using the greater of the prior year or the
second prior year and computed using the base funding rate of $639.1728.
Charter schools can have a very serious effect on the SELPA’s funding. Any additional ADA
reported by the charter to contribute to growth will be at a lower target rate, and if the school
closes, relocates, or joins another SELPA, the ADA loss will be computed at the much higher
base rate per ADA rate.
Regionalized services and program specialist funding generates $15.10 per ADA. Education
Code Section 56836.23 requires this funding to be used to provide services such as program
specialists, management information systems, curricular coordination, staff development and
other activities to support the SELPA statewide.
Many SELPAs, such as the NCCSE, have added services such as low-incidence programs, highly
specialized related services and out-of-school placements. This will require additional funding
from the district because in the current allocation model, the SELPA funds its own expenses
before distributing resources to the districts (sometimes known as off-the-top funding). The
district should determine how it would address these issues and services. It may be possible to
provide low-incidence programs for the hearing or visually impaired more cost effectively. For
example, if low-incidence services are available in Escondido, the district could enter into a
contractual agreement with the North Inland SELPA.
Other small federal and state grants would accrue directly to Vista that are now allocated or used
by the SELPA.
While there are advantages to becoming a single-district SELPA, Vista USD’s declining enroll-
ment tends to erode many of those advantages.
It is far too late in the year to take the steps to become a single-district SELPA beginning July 1,
2012. The required timeline for notification is one year plus one day. While it might be possible
to obtain unanimous agreement from the NCCSE governing board, it is too late to notify CDE
so that the fiscal office can change the CASEMIS software.
Secondly, some members of the State Board of Education reportedly are concerned that prior
state boards gave insufficient consideration to the size and scope requirements (see Appendix B
to this report). If that is the case Vista USD’s declining enrollment is likely to make it an unlikely
candidate to be an exception to those criteria because it is already below the size standard.
In 2012-13, the NCCSE will implement a new student data system for special education. This is
a costly and time-consuming process, and it will be to Vista USD’s advantage to have a system in
place before becoming a single-district SELPA.
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Recommendations
The district should:
1. Weigh the advantages and disadvantages of becoming a single-district SELPA
over the next year.
2. Participate in the new data system installation and work with the SELPA to
continue to make the allocation model more equitable.
3. Make the necessary programmatic changes to improve its fiscal situation with
regard to special education.
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Infrastructure
Management Structure
FCMAT found several issues in the special education department structure with regard to IEP
meetings, program specialist roles, and the special education reporting structure. Procedural
direction from administration to staff is inconsistent, which has resulted in a lack of confidence
and credibility.
Every IEP meeting must have an administrative designee who represents the district (Education
Code Section 56341). The district has complied with the requirements of this section; however,
(4) (C) of that same section requires that the district representative “is knowledgeable about the
availability of resources.”
The program specialists frequently serve as administrative designees at IEP meetings, but any
decisions regarding the expenditure of district funds rest with the director of special education,
who cannot attend all IEP meetings. As a result, the IEP team suspends the meeting to get
authorization to use district resources and then reconvenes to finalize the IEP. This can lead to
serious compliance issues.
As a member of the NCCSE, the district is required to adhere to established practice regarding
program specialist services. Three program specialists who work full time for the district are
employed by the San Diego County Office of Education. This creates issues for the district
because they are not district employees, have little knowledge of the availability of district
resources and have no authority to allocate them. The SELPA is changing this practice, and by
2013-14 the program specialists will be assigned to the districts and will not be hired by the San
Diego COE. A single-district SELPA could choose to hire its own program specialists.
Staff do not clearly understand the job responsibilities of the director of special education,
particularly regarding budget oversight and management. Special education interacts with every
major district division, and effective communication is essential.
Some staff, such as the Business Services employees, are unfamiliar with the laws/regulations the
Special Education Department must follow to provide services, which makes budgeting more
difficult and complicates the accounts payable process. Special education staff lack understanding
of what Business Services needs from them to be able to track and document expenditures and
budget accurately.
No process exists for providing critical staffing information to Business Services to build a
projected budget each year. This affects Business Services’ ability to budget accurately. For
example, in November 2011 the board had to take action on expenditures of $288,000 for
additional instructional aide positions for special education. The written rationale for this request
clearly showed that these issues all should have been communicated in budget development for
the 2011-12 fiscal year.
Communications between the Special Education Department and other key departments should
include at least the following elements:
Business Services
1. Quarter 1: Review the working budget for the current school year;
confirm nonpublic school contracts with Sept. enrollment; close contracts
for students who no longer reside in the district; confirm total FTE of
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all special education staff. Develop an agenda for other issues from both
departments.
2. Quarter 2: Begin to discuss information needed for the 2013-14
projected budget; set timelines and due dates; define the process for
requesting new resources; share plans for reductions or program changes.
3. Quarter 3: Direct supervisor of special education and the finance depart-
ment finalize projected budget.
4. Quarter 4: Review expenditures for the current year; review nonpublic
school placements and confirm for the fall.
Learning Support Services
1. Quarter 1: Review available statewide assessment data. Set department
goals for access to core curriculum; develop training schedules.
2. Quarter 2: Review CASEMIS report from June 30; examine exit rates
and identification rates; review status of curriculum implementation.
3. Quarter 3: Discuss plans for statewide testing for disabled students;
resolve any issues regarding test administration.
4. Quarter 4: Review progress on yearly goals; determine next steps, identify
problem areas.
Human Resources
1. Quarter 1: Align caseload lists with payroll, human resources and finance.
2. Quarter 2: Review alignment of NCLB compliance requirements for
special education; identify any potential staff layoffs.
3. Quarter 3: Finalize staffing plan for 2013-14; report progress on staff
evaluation; resolve staffing discrepancies between payroll, business and
special education; select positions to close, if any.
4. Quarter 4: Review staffing plan for 2013-14; discuss extended school year
staffing and plans for next year.
Transportation
1. Quarter 1: Align transportation lists; troubleshoot problem areas.
2. Quarter 2: Discuss training schedules and options for staff development
between special education and transportation.
3. Quarter 3: Budget projections for the 2013-14 school year; discuss
extended school year plans.
4. Quarter 4: Review transportation needs for fall 2013; provide special
education class lists by name and location to transportation.
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Special education operating procedures are not written or defined, resulting in inconsistent direc-
tion to staff. Both district and site staff indicated that the accuracy and consistency of procedural
guidance depends on who gives it. Therefore, the site staff avoid contacting the central office staff
because they have little confidence in their ability to provide consistent direction. Instead, each
school site relies on its own procedural interpretation and implementation, which can lead to
compliance issues.
The current management and reporting structure does not provide consistent communication
to itinerant staff such as psychologists, speech therapists, adapted PE teachers and occupational
therapists. Psychologists and adapted PE specialists are supervised by the administrator of
California Avenue School, a preschool for disabled students. An administrator from Sierra
Vista supervises the speech therapists. A program specialist employed by NCCSE supervises the
occupational therapists. Greater efficiency can be achieved with leadership and support from the
director, who should have primary responsibility to oversee all itinerant groups.
Direct supervision and support from the director of special education to psychologists and speech
therapists would provide better communications with front-line staff and improve procedural
consistency.
A department structure that delineates elementary from secondary would align with Education
Services. Using the resources from an open program specialist position would allow the depart-
ment to have a director and three program supervisors: preschool, elementary and secondary.
Proposed Organizational and Responsibility Chart for Special Education
Director of Special
Education/SELPA
District Special Education Programs and Services
Staffing Plan (Certificated and Classified)
CASEMIS/Student Records
Compliance and Operational Procedures
Due Process/Complaints
Nonpublic Schools and Agency Contracts
Special Education Budget
Administrative Liaison with NCCSE SELPA
Psychologists
DIS Speech, APE, OT
Program Supervisor, Program Supervisor, Program Supervisor,
Preschool Elementary Secondary
Preschool @ California Ave. Program Support Elementary Program Support Secondary
Preschool Speech Districtwide Curriculum and Instruction Curriculum and Instruction
Staff Development Preschool Caseload Monitoring Caseload Monitoring
CCS Medical Therapy Unit Job-Alike Elementary Job-Alike Secondary
Nonpublic Schools Staff Development Staff Development
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Recommendations
The district should:
1. Ensure that the director of special education understands the administrative
reporting structure and all areas of responsibility including the budget.
2. Determine who will serve as an administrative designee to fulfill all the IEP
requirements outlined in statute and authorize the provision of necessary
district resources. Provide training and support.
3. Continue to discuss options with NCCSE to return regionalized service funds
for program specialists as early as 2012-13.
4. Establish clear reporting structures to which special education staff should be
held accountable.
5. Establish communication protocol between special education and the director
or assistant superintendent of Business Services, Education Services, Human
Resources and Transportation.
6. Finalize written procedures to ensure special education complies with all
applicable laws and regulations.
7. Ensure that procedural changes are clearly communicated and that staff on
the front line are supported in implementing the procedures.
8. Reinforce procedural consistency through regular job-alike meetings with
teachers, psychologists, and DIS staff (speech therapists, occupational thera-
pists and adapted physical education).
9. Structure the Special Education Department to delineate elementary from
secondary education and align with Educational Services.
Programming
Three types of programs or services were reviewed to determine if the district would need to
provide additional classes or programs as its own SELPA. They were: 1) Out of district students
attending regional classes operated by Vista; 2) Vista students attending regional classes operated
by other districts; and 3) Classes or services operated by NCCSE.
Starting in 2012-13, NCCSE will implement a new allocation model that affects the amount
the district will receive and the cost of operating regional classes. The district of operation will be
totally responsible for the classes, which will be staffed at a predetermined level. That district will
be able to charge at a predetermined level for out-of-district students who attend these classes,
and the students will still need to be referred through a process agreed to by the member districts.
The regional classes are separated into three different types:
Type 1 classes are moderate/severe, transition and preschool. These classes must be capped
at eight students for preschool, 10 for K-6, 12 for 7-12 and 12 for transition. Staffing is one
teacher and three six-hour aides, with a set amount included for occupational therapy, speech
and adapted physical education. One-to-one aides, nursing services, and physical therapy are not
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included in the base rate and will be billed for out-of-district students at a cost determined by the
SELPA and the district.
Type II classes are for emotionally disturbed students (SEAS). These classes are capped at 10 for
K-6 and 12 for 7-12. Staffing is one teacher and two six-hour aides. Services for students who
require occupational therapy, speech or adapted physical education will be billed at predeter-
mined rates set by the SELPA and the district. In addition, costs for one-to-one aides, nursing
services and physical therapy will be billed for these students.
Type III classes are general special day classes that are capped at 12 for K-12. Staffing is one
teacher and one six-hour aide, and any related service incurs additional cost.
The district will operate 23 regional classes plus the preschool classes at California Avenue School
under this new model. Two of the current regional classes, the medically fragile and behavior
classes at California Avenue, will continue to be operated by NCCSE.
If the district becomes a single-district SELPA, it will need to be determined whether the district
will continue to operate these classes as open to the region and if so, whether the capped number
of students in the class and the staffing ratios will be retained. If there are no out-of-district
students, the district will need to determine whether there are enough district students in the
class to warrant operating it. The table below lists each of the Type I and Type II classes that will
be operated by Vista USD next year.
A discrepancy was found between two SELPA-generated lists. The first listed all students enrolled
in regional classes in February 2012 and the second listed the number of students who were in
or out of district in regional classes as of April 2012. The first list included four preschoolers, 18
SEAS students and 40 moderate/severe students for a total of 62 students, while the second list
included four preschoolers, 19 moderate/severe students and 18 SEAS for a total of 41 students.
The lesser number of students was used for the table below so as not to overestimate projected
income. However, accurate numbers of students will be needed.
Classes with asterisks may be appropriate to (1) combine, (2) continue to operate with additional
district students who are now in an NPS or receiving NPA services, (3) operate as another type of
class or (4) close.
Vista-operated regional classes per data provided by the SELPA - April 18, 2012
Class Description District Out-of-District
and Grade Level Current Location Students Students
Autism K-1 California Ave. 7 1
Moderate/severe 3-5 Temple Heights 10 1
Moderate/severe K-1 Temple Heights 11 0
Moderate/severe 3-5 Mission Meadows 9 0
Moderate/severe 6-8 Madison Middle 12 1
Moderate/severe 6-8 Roosevelt Middle 9 1
Moderate/severe 6-8 Washington Middle 8 0
Moderate/severe 9-12 Rancho Buena Vista High 10 0
Moderate/severe 9-12 Vista High 9 0
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Class Description District Out-of-District
and Grade Level Current Location Students Students
Moderate/severe - be-
4
havior 6-12 Sierra Vista ** 3
Moderate/severe -
11
medical 6-transition Sierra Vista ** 3
Moderate/severe -
8
transition 18-22 Sierra Vista ** 3
Moderate/severe -
9
transition 18-22 Sierra Vista ** 3
Moderate/severe -
10
transition 18-22 Sierra Vista ** 3
SEAS 3-3 Grapevine ** 7 3
SEAS 3-5 Grapevine 10 0
SEAS 6-8 Washington Middle ** 9 2
SEAS 6-8 Sierra Vista ** 3 3
SEAS 9-12 Sierra Vista ** 7 5
SEAS 9-12 Sierra Vista ** 3 2
SEAS 9-12 Sierra Vista 11 1
SEAS 9-12 Rancho Buena Vista High 5 1
SEAS 9-12 Vista High 10 1
93 (3.5 regional,
Autism Preschool 4.5 local) 4
Changes in the funding stream will prompt all NCCSE member districts to carefully consider
whether to continue sending students to classes outside their district. For the first year of the new
agreement, the district operating a regional class will be able to bill the sending district for 34%
of the predetermined cost/student, increasing to 67% the second year and 100% the third year.
Staffing costs (including salary and benefits) that the SELPA has agreed to reimburse are:
Teacher (1.0 FTE) $84,169.42
Aides (0.75 FTE) $36,462.17
Speech therapist (1.0 FTE) $90,439.84
Occupational therapist (1.0 FTE) $84,440.11
Costs were calculated to estimate the average cost per student in a regional class. Since programs
vary by cost, sending students to a Type II class and receiving students into a Type II class may
not result in equal related services charges.
The average cost for out-of-district students in a Type I class does not include the time of the
speech therapist and occupational therapist. The basic rate only was used for this study because
the percentages of staff assigned to each class could vary.
Preschool $24,194.49
K-6 $19,355.59
6-12 and transition $16,129.66
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The average cost for out-of-district students in a Type II class would be:
K-6 $15,709.38
7-12 $13,091.15
FCMAT did not find any out-of-district students in a Type III class.
Assuming no changes in the number of students per class, the funding model or the average
costs, the estimated income for the out-of-district students in the regional classes would be
$165,826 for year one, $437,361 for year two and $603,188 for year three. This is a small offset
from the significant decrease in funding under the new SELPA allocation model. However, if the
district were its own SELPA, it would determine the charges per student and the staffing ratio.
The district could decide to charge out-of-district students using the NCCSE model or an actual
fee for service. Staffing could utilize the NCCSE ratio or could decrease or increase based on the
students’ needs in each class.
FCMAT also reviewed the 16 Vista students who attend a regional program in another district
that will continue to be operated by that district. This number was consistent between the
February and April lists. These placements were made either because the Vista USD program
was at capacity or there was a specific IEP agreement. In the past, cost was not considered when
placing a student in a regional class outside the district. However, as stated above, this is no
longer the case.
Vista students in out-of-district programs
Class Description and Grade Level Current Location No. of Vista Students
Moderate/severe 7-12 San Marcos 2
Moderate/severe transition San Marcos 1
Moderate/severe transition Oceanside 1
Autism K San Marcos 1
SEAS 7-12 Carlsbad 1
SEAS K-6, and 7-12 Oceanside 8
SEAS K-6 Encinitas 1
SEAS 7-12 Bonsall Union 1
The per-pupil cost for these students was calculated in the same way as the out of district
students in a Vista program. A rough estimate of the cost for these students is $85,778 in year
one, $174,155 in year two and $259,933 in year three. These costs reduce the level of income
generated by the out of district students into Vista programs.
The last area reviewed was the programs and related services that NCCSE will continue to
operate under the new model: the day treatment program and two classes housed at California
Avenue, the medically fragile class and the autism/behavior class. District staff indicated that
these classes provide important services, but they do not currently have enough district students
to warrant an independent class. In other districts NCCSE will continue to operate the deaf/hard
of hearing classes. It also provides itinerant vision services, deaf/hard of hearing itinerant services,
occupational therapy and assistive technology. NCCSE will bill districts 100% of the cost for
students in those classes beginning in year one of the new model. It would be difficult for the
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district to provide its own deaf/hard of hearing program because of a shortage of appropriately
credentialed teachers and the level of interpreter services required in such a program.
With operating funds from the member districts, NCCSE provides staff development, manage-
ment information through the computerized IEP, CASEMIS reporting, monitoring of the
required local plan and all other state reporting. With this funding it will also provide program
specialists, occupational therapy, and assistive technology.
If the district becomes its own SELPA, it will be required to develop its own local plan and report
directly to the state for the yearly budget plan, staffing plans, and CASEMIS, along with any
other state reporting requirements.
NCCSE and the district will need to determine who will operate the NCCSE classes housed in
the district. If NCCSE continues to operate them, they may stay in the district or be moved to
an NCCSE member district. Vista may or may not continue to have access to those programs.
The district and NCCSE will also have to determine whether the itinerant services will be
provided through a contract or MOU, or by the district itself.
Specific classes/programs operated by NCCSE that will need to be either replicated by Vista or
contracted with NCCSE to provide if Vista USD is its own SELPA are listed below. Program
specialists, who are NCCSE staff, are not included in this list because of the agreement already
in place to transfer those funds and hiring responsibilities to the district for the 2013-14 school
year.
• Deaf/hard of hearing classes
• Deaf/hard of hearing itinerant services
• Vision itinerant services
• Assistive technology assessments and support
• Medically fragile NCCSE class
• Autism/behavior NCCSE class
• Day treatment
• Occupational therapist
• Speech and language assistants
Recommendations
If the district becomes a single district SELPA, it should:
1. Ensure that enrollment data is accurate for out of district students in 2012-13
regional classes to ensure appropriate invoicing for them.
2. Review each of the 2012-13 regional classes by enrollment numbers and
student needs to determine which classes may be open to out-of-SELPA
students, what the cap and staffing of those classes would be and to determine
whether to continue classes as currently structured or restructure them to
better meet district needs.
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3. Review the funding model for each regional class to determine the percentage
of time assigned for speech and occupational therapy, and include that in the
total cost of invoicing Type I classes while remaining in the SELPA and if the
district becomes its own SELPA.
4. Review the funding model for each regional class the district would continue
to operate as a SELPA. Determine whether the district will use the average
costs or actual costs for each class and if it will continue to use the current
billing percentages or will bill at 100% of actual costs including indirect and
all related services.
5. Review each Vista USD student attending a class outside the district, other
than the deaf/hard of hearing program, and determine if a district program
could fulfill the IEP. If so, convene an IEP to return the student to the district
for the 2012-13 school year. Continually monitor these students and return
them to district programs as appropriate.
6. Determine whether to continue contracting with the SELPA for deaf/hard of
hearing classes, itinerant vision and hearing, occupational therapy and assis-
tive technology, or hire staff for these services. Develop a plan with NCCSE
to determine which entity will operate the two NCCSE regional classes at
California Avenue School and which districts will have access to those classes.
7. Continue working with NCCSE to ensure the district can hire its own
program specialists or supervisors for 2013-14.
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Pro GraM efficiency
Program Efficiency
Identification
The statewide special education identification rate is 10%, and Vista USD identifies students
for K-12 at 11.79%. The staff reports that special education is used as the only intervention for
students at risk in the absence of an effective Response to Intervention (RtI) model.
Exit Rates
The annual exit report for special education submitted to CASEMIS indicates that the district
exited 174 students from special education during the 2010-11 school year. In addition, 155
graduated with a diploma; 14 received a certificate of completion; 82 graduated with a diploma
using an exemption; and 25 graduated with a diploma using a waiver. No data was available
from the SELPA on the exit rates from its other member districts. The district is encouraged to
compare its exit rate with other K-12 districts with regard to the numbers of students returning
to general education, graduating with a diploma, and graduating with a certificate of completion.
There is a perception in the district among teaching and administrative staff that students do
not exit special education, but it cannot be verified unless the district begins to track its exit rate
through CASEMIS and compares itself to other districts.
Statewide Assessment
The district API for 2011 increased over 2010 by six points: from 786 to 792. The students with
disabilities decreased, from 648 to 641. Two years ago the Special Education Department was
told to test with the California Modified Assessment for any students having trouble meeting
academic proficiency standards and exceeded 3% of the allowable cap; the next year the test was
given correctly and the scores dropped. All subgroups except special education made significant
gains in API. The special education subgroup has not reached proficiency in either English-
language arts or math.
Program Delivery
FCMAT visited several schools that housed resource, special day mild/moderate and moderate/
severe programs to review the special education delivery system and seek efficiencies.
The district uses the model of resource specialist and SDC mild/moderate classes. In some cases,
the resource specialist provides a form of learning center where non-identified students receive
some instruction, but often the SDC students do not have this access. At the elementary level the
SDC students are clustered at three elementary schools and require transportation.
A concern expressed by staff was that the students in the SDC classes do not receive the most
effective instruction because one teacher is required to provide instruction to a range of abili-
ties and grade levels. It was also a concern that although the SDC teachers have access to core
materials, they are not always used for primary instruction. When students have been in an SDC
class for several years, the likelihood of their ability to move into a less restrictive environment
decreases significantly.
Staff expressed concern regarding the current SDC model for mild/moderate students because it
is difficult to mainstream those students at all grade levels. When general education classes are at
their maximum class size, teachers are naturally reluctant to accept mainstreamed students, both
mild/moderate and moderate/severe. This means that many students cannot access the general
education classes that could be of benefit. In addition, when resource specialists have a maximum
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caseload and are taking general education students into their programs, they are naturally
reluctant to take SDC students into their classes even when the student could benefit from the
instruction. Also, when SDC classes are clustered at the elementary level, opportunities for main-
streaming are further reduced because of the high numbers of SDC students at the site.
Staff stated that the lack of a strong district team to provide behavior plans, modeling and imme-
diate support for intensive behavior issues to special or general education students is a primary
cause of student referrals to special education. Once a student is in special education, behavior is
often the reason for referral to an SDC, a class for emotionally disturbed students, or to an NPS.
Requests for additional classroom aides or one-to-one aides also result from these special educa-
tion placements.
Ample research supports student placement in general education for instruction whenever
possible. This does not mean that all special education students should be fully included, but that
access to general education and a range of special education instruction should be available to all
students as appropriate. Limited mainstreaming opportunities deny this access.
The district has begun discussing an alternate model for special education that includes learning
centers and collaboration. However, what this model would include is unclear. The special
education staff is concerned about changing the RS/SDC labels and general education teachers
are concerned about having SDC students in their classes full time. Also needing clarification are
teachers’ caseloads, how to use RtI as a primary condition of determining special education eligi-
bility, who will staff learning centers, and the role of special education teachers and aides in the
general education classroom. A task force is scheduled to begin meeting this summer to discuss
these issues.
Learning center models work successfully, along with a strong RtI model, in many districts
throughout the country. Extensive training and planning are necessary to implement any new
special education delivery model.
In other districts that operate learning centers, the titles of resource specialist and special day class
teacher are eliminated and replaced with another title such as specialized academic instructor.
The Code of Federal Regulations Title 34, Part 300.18, defines specialized academic instruction
as follows:
“... adapting, as appropriate to the needs of the child with a disability the content,
methodology, or delivery of instruction to ensure access of the child to the general
curriculum so that he or she can meet the educational standards within the jurisdiction
of the public agency that apply to all children.”
Defining the special education program as specialized academic instruction and the staff as
specialized academic instructors may better indicate a program based on the least restrictive envi-
ronment requirement. Caseload is an important factor in the success of a learning center model,
but the statutory caseload limit of 28 for a resource specialist would no longer apply under this
model.
Students can be assigned to a learning center from a few minutes a week to most of their day, and
can use the learning center to receive tutoring or homework support. Regular teaching staff can
provide instruction in the learning center to all students, and special education staff can provide
short-term intervention instruction to students not identified as special education students. This
provides flexibility for most special education students to receive the education support they
need at their home school and in the least restrictive environment. This could be implemented
without increasing the number of staff.
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Moderate/severe special education students would continue to be served in an SDC class at
specific sites.
Specific classes structured to address the unique needs of behaviorally challenged students along
with support staff trained to develop behavior intervention plans and assist staff in implementing
these plans would reduce the number of students in SDC behavioral classes, reduce the number
of NPS placements, and ensure that classes for the emotionally disturbed are not populated with
behaviorally disordered students.
FCMAT also identified an elementary program for autistic students as both a cost savings and
as necessary for a full continuum of options. The autism collaboration teaching (ACT) staff
attempts to work with as many of the autistic students as they can except for those at California
Avenue School. This has resulted in large caseloads and little time for developing and monitoring
individual behavior plans, providing training in data collection and implementing the plans.
Four staff members with a variety of backgrounds are employed in this role.
The development of two elementary autism classes and possibly an additional middle school class
would enable the students most in need of autism behavioral services to receive them more effec-
tively and cost efficiently. In addition, shifting from four credentialed staff to two highly skilled
staff in autism with four to six highly trained instructional assistants for autistic students who are
not in an autism SDC program would also be cost effective. This would reduce the number of
one-to-one aides and more restrictive placements.
Both these additions to the current programs for autistic students could significantly reduce the
$242,013 spent on NPA and independent contractor services and the cost of sending Vista USD
students to nonpublic schools or regional programs in other districts.
At the high school, the focus of instruction in the general education program is graduation with
a diploma by meeting the district’s requirements and passing the California High School Exit
Exam. Staff reported that a significant number of special education students are receiving credit
for subjects that they have not legitimately earned so they may be granted a diploma. No data
was available regarding the actual number. The goal of staff is to keep the students in school so
they may graduate with a diploma. This is certainly a reasonable goal. However, if this informa-
tion is accurate, then students who are not capable of passing a class, even with appropriate
modifications, are given credits and a diploma because no other alternatives are available.
A program designed for students who are not on a diploma track is now available only to
moderate/severe students. This leaves a significant group of students, according to staff, without
the skills needed to prepare them for employment and with a diploma that does not reflect their
abilities. Students who are appropriately enrolled in an alternative program gain life skills and
graduate with a certificate of completion. They enter the program in the junior and senior years,
enabling them to complete their credit requirements for graduation. Developing this type of
program is a high priority for the high schools, but it is time intensive and would require board
action. Other districts in the state operate alternative programs and NCCSE, through the SELPA
organization, should be able to connect Vista USD with these districts.
Staff reported that special education students cannot access the magnet schools or the alterna-
tive education schools when they need more than 50% of their day in specialized instruction.
Changing the delivery system from resource and special day to a more generic instructional
delivery system would enable students to access these programs.
All of these program recommendations are costly. However, these costs can be largely offset
by redistributing staff based on the needs of each school, identifying fewer students for special
Vista UniFied school district
44
Pro GraM efficiency
education, significantly reducing transportation costs, reducing placements in nonpublic schools,
providing IEP services through the district rather than contracted personnel, and increasing
student scores through more effective delivery of instruction.
California Avenue and Sierra Vista Sites
Disabled students’ access to public education dates back to civil rights legislation in the 1960s.
Congress passed the Rehabilitation Act in 1973, the first significant piece of legislation designed
to ensure equal opportunity and access for people with disabilities.
In 1975, Congress enacted the Education for All Handicapped Children Act, which was renamed
the Individuals with Disabilities Education Act (IDEA) in 1990. With each reauthorization
Congress has provided clear language regarding the instruction of disabled students in integrated
settings with non-disabled peers.
Although Education Code Section 56041.1 (b) permits the removal of individuals with excep-
tional needs from the regular education environment, this may occur “only if the nature or
severity of the disability is such that education in the regular classes with the use of supplemen-
tary aides and services cannot be achieved satisfactorily.”
FCMAT made on-site visits at both California Avenue and Sierra Vista and also interviewed staff.
California Avenue School
California Avenue School offers a comprehensive range of preschool services including autism
programs and services, typical integrated preschool programs, and designated instruction services
such as speech, adapted physical education and occupational therapy. It operates 15 special day
classes for students with qualifying disabilities. Twelve classes for preschool age children and three
classes for children ages 6-11 are offered, with a total enrollment of more than 300 students. All
of these classes are open to 14 school districts throughout the NCCSE. The operating budget is
$3,067,431.
While technically this is a segregated site, it has many opportunities for integration with age
appropriate peers and mainstreaming. This program was developed as an alternative method of
providing programs and services for autistic students. As a result, the district has been able to
provide appropriate levels of service for these students without the excessive costs of NPS agen-
cies charging more than $140,000 per student for home services. All services are delivered at the
school by qualified staff at a significant savings.
Some costs also are recouped from the MOU with other districts in the SELPA who access this
program at a rate of 100% of the cost. There is a tuition fee for the integrated preschool that is
also used to offset programming costs.
The special education classes at the California Avenue School, while costly in terms of budget,
meet the standards of appropriate service for students with autism and intensive physical needs.
These are high cost students and by regionalizing this program, NCCSE provides services for
member districts at a reasonable cost. It offers opportunities for mainstreaming and integration
and, therefore, meets the intent of the statute for integration with nondisabled peers.
Sierra Vista School
Sierra Vista School is a small segregated school site dedicated to serving students ages 14-22 with
severe handicaps. There are four classes for students with emotional disturbance (one for middle
school and three for high school students); two classes for severely disabled high school students,
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Pro GraM efficiency
and five transition programs for severely handicapped students ages 18-22. The number of
students served is 118 and the budget is $2,560,616.
The staff expressed concern about the appropriateness of the referral and placement procedures.
They do not feel that all of the placements are appropriate, yet they do not have input into the
placement decisions that are made by the sending schools.
Sierra Vista School is a segregated site. Students on this campus have no opportunities to
integrate with age appropriate peers or mainstream on high school campuses. Students in the
emotionally disturbed classes have been on comprehensive high school campuses and require a
more restrictive setting; however, they should always have access to the least restrictive environ-
ment at an appropriate level.
Students in transition programs do not need to be on a segregated site. The programs are
community based and in some instances access college-level programs and services.
When the district begins strategic planning for special education this summer, the planning team
should discuss the appropriateness of these students remaining on an isolated site with no access
to age appropriate peers. There are certainly issues related to the legal requirements of state and
federal law for disabled students, but there should also be discussion about the value of students
being removed from their schools of residence. Finally, there are fiscal concerns over the efficiency
of serving students on a separate site. This requires a separate facility, maintenance, front office
staffing, and administrative supervision, which adds to the costs. At a cost of $21,700 per
student, the district will need to determine whether this type of service delivery is cost effective.
Procedural Efficiency
The district has adopted the NCCSE forms for determining the need for a one-to-one aide or
special circumstances instructional assistant (SCIA). These are considered by staff to be thorough
but also cumbersome, so they are not always completed before the IEP team makes the determi-
nation for the aide. In addition, the forms are rarely used, usually when the student first has the
SCIA on their IEP. All future IEPs may discuss the continued use of the aide, but no forms are
required. The IEPs that do include a SCIA do not usually list goals for the student to become
independent or include a fading plan for the SCIA, which would provide essential guidance.
Forms for a more streamlined process are included in Appendix C to this report.
The district also does not have forms to clarify process and procedure for extended year services
or transportation. Staff reported that all students in an SDC program are eligible for extended
year services and generally also for door-to-door or curb-to-curb special education transportation.
Forms and guidelines for special education procedures are readily available. Many SELPAs have
these on their websites, and examples of these forms are included in Appendix D to this report.
Communication with Business Services
The business department is responsible for generating the NPS contracts and the individual
service agreements for all students placed in an NPS. Business Services is usually informed that
a student is being placed in an NPS after the placement IEP meeting, but on some occasions
the department has not known about the placement until an invoice arrives from the NPS. On
occasion Business Services has not been informed that a student has moved out of the district or
receives related services that were not included in the base rate for the NPS. Regular communica-
tion with Business Services regarding NPS students is essential for budgeting and for accurate
invoice processing.
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Pro GraM efficiency
Business Services also is responsible for generating NPA contracts and independent contractor
agreements. The department usually is informed that a student will receive these services.
However, on occasion Business Services is not informed that a student has moved out of the
district or that services have changed. As stated above, regular communication with Business
Services regarding NPA students is essential for budgeting and for accurate invoice processing.
Recommendations
The district should:
1. Based on staff input, prioritize the areas where the district lacks or needs to
revise procedures and criteria. Develop these procedures and criteria, provide
them on the district website to all special education and site administrators
and train each of these groups. Consider distributing and training on the new
procedures after each identified area or group of identified areas is completed
so staff can begin to implement key procedures.
2. Convene a district task force this summer to determine a new special educa-
tion delivery system. Visit key RtI and learning center sites, such as Yucaipa
in San Bernardino County.
3. Review the use of resource specialist and special day class titles to determine
if changing these to specialized academic instruction teachers would enable
more collaboration, mainstreaming and increase student performance by
reducing the separation of special education students.
4. Develop a plan to ensure that mild/moderate students who require specialized
instruction for more than 50% of their day are taught at their home school
through learning centers and collaboration. Information regarding learning
centers is included as Appendix E to this report.
5. Ensure that administrators for both regular education and special education
are trained in all changes to the delivery system before implementation.
6. Develop clear criteria for determining which types of coursework will lead to
a diploma or certificate of achievement. For mild/moderate students who will
not receive a diploma, develop a comprehensive course of study to meet their
academic and life-skills needs.
7. Ensure that all students receive either a full triennial assessment or a review of
records with a written report for their triennial.
8. Develop programs to address the needs of the more behaviorally challenged
special education students.
9. Develop program or programs for autistic elementary students that address
their unique needs that are not met in a more traditional SDC.
10. Reconfigure the autism collaboration teacher program to increase the level of
support to students with autism in the least restrictive setting.
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Pro GraM efficiency
a. Consider forming a team of two highly qualified autism specialists and
4-6 high trained instructional assistants.
b. Establish criteria for accessing these services
c. Have this team provide on-site training to staff in developing behavior
plans, data collection and implementation of behavior plans and provide
parent training and support.
d. Assign the instructional aides to specific students to model for staff data
collection and plan implementation, and to fill in as needed when unex-
pected situations arise.
11. Develop a more intensive class for emotionally disturbed students with a
strong therapy component to reduce placements in the SELPA day treatment
program, nonpublic schools, and residential placements.
12. Develop criteria to determine how special education students can access the
programs at the magnet and alternative high schools if they require more than
50% of their day in specialized instruction. Train staff in this process.
13. Schedule quarterly meetings of business and special education leadership to
increase communication of budget issues, develop the projected budget for
each school year, and provide consistency and accuracy regarding NPS and
NPA billings.
14. Continue operating the California Avenue School and monitor staffing
closely to contain costs.
15. Request that the strategic planning team evaluate the effectiveness of oper-
ating programs and services for the Sierra Vista population on a segregated
site.
16. Consider whether options can be developed on comprehensive campuses to
foster integration and placement in the school of residence.
17. Consider the costs of operating a segregated site and determine whether there
are more efficient yet compliant ways to serve students.
Vista UniFied school district
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49
Trans PorTaTion
Transportation
Routing Efficiency
The district provides transportation service to approximately 2,679 students daily, more than
10% of the total district student population. District source documentation shows that the
district transports approximately 779 special education students, plus another 1,900 students
in general education home-to-school transportation. The number of special education students
receiving transportation service as an identified related service through their IEP has decreased by
almost 10% during the 2011-12 school year. This significant decrease is in marked contrast with
the steady increase of students identified for transportation services over the past five years. The
Transportation Department’s student intake listing and routing shows special education students
receiving transportation as follows:
Non-public program placement 62
Public schools outside Vista USD 30
Preschool 109
K through fifth grade 313
Sixth through eighth grade 99
Ninth through twelfth grade 129
Transition 37
Total 779
The Transportation Department operates 67 school bus routes, 51 of which transport the 779
special education students who require transportation. The program lacks sufficient buses to meet
the daily demand of special education routes. In an attempt to operate efficiently and address
the shortage of operational buses, 46 special education routes utilize the smaller Type II special
education buses, two routes utilize larger Type I school buses, two routes utilize district passenger
vans and one route utilizes a district truck.
Bus routing is input into Microsoft Word to begin the routing process. The district uses
Transfinder, an electronic routing system, to help develop and produce routing sheets and
optimize school bus routes. Staff who perform routing tasks have not yet been trained on the
software; however, the director is familiar with its operation. The district has owned the software
for approximately one to two years, but did not purchase on-site or off-site training. The sched-
uling staff and the operations supervisor need to become familiar with the software and how to
navigate the many modules the system provides to assist in scheduling.
Special education transportation requests are generated by the special education secretary, who
generates the request from the student’s IEP. A program specialist or the director of special
education reviews the request to ensure it is appropriate. The request form is then sent to the
Transportation Department, where it is logged into an intake spreadsheet containing specific
student data. This process appears appropriate and efficient. However, once transportation
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Trans PorTaTion
service is identified, no discussion occurs regarding how to accomplish it in the least restrictive
manner. A sample review of the requests suggests that the IEP team assumes that transportation
is provided curb-to-curb from the student’s residence to their school or program site.
A transportation request form generated concurrent with the student’s IEP would allow for
discussion with the IEP team about how to provide transportation in the least restrictive environ-
ment. For example, the student’s needs may be met by inclusion on a district home-to-school
route, if appropriate, or by walking to a central school bus stop or street corner to develop
independence.
Transportation decisions should be based on students’ needs rather than on the special education
program in which they participate. Not all students need specialized transportation to benefit
from education. In complicated cases, someone from the Transportation Department should
attend the IEP meeting. Transportation should be discussed at every IEP meeting, but this is not
always the district’s practice.
The district may benefit from using a decision tree or similar strategy to determine whether
transportation is warranted for a student to benefit from education, as in the following example
developed by the Fresno County Office of Education.
Is specialized transportation warranted?
IEP and need-driven Program placement-driven
Is it cost Should Ed Is it cost Does it meet
efficient? Code 41850 efficient? the needs?
(specialized
transportation)
Yes be utilized? No Does it follow No
Ed Code?
Does it meet Yes
the needs? No
Yes
Bell Schedule
A school district with transportation service to most of its school sites should have a master
multi-tiered school start and end time schedule to ensure optimum efficiency and use of its
school bus fleet. In addition, a standardized release schedule allows the driver to release the
students on arrival at the school or at a designated time, such as 15 to 30 minutes prior to the
start of school. Currently, each school site self-determines its acceptance of students on arrival,
which in some cases results in the bus waiting for staff until immediately prior to the first bell
sounding the start of school.
Vista USD has a three-tiered master bell schedule for its school sites, but the three tiers are not
sufficiently staggered to optimize bus usage. Approximately 35 minutes is all that separates the
three tiers. Given the travel times throughout the district, at least 45 to 50 minutes should sepa-
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Trans PorTaTion
rate each tier start and dismissal time. By strategically placing the schools within each start and
end time tier and separating each tier by 45 to 50 minutes, the district could reduce bus routing
by two to four routes. Data indicates that the salary and health and welfare benefit costs for an
average Vista USD school bus driver is $54,000; a potential savings of between $108,000 and
$216,000. An additional $12,000 to $24,000 in bus operational cost also could be realized for an
approximate total savings of between $120,000 and $240,000.
The transportation director and transportation operations supervisor reported that the district
has a calendar committee and bell schedule committee; but neither the director of transportation
nor a designee participates in these planning groups. Both the district calendar and master bell
schedule greatly affect transportation service efficiency. Transportation related input could help
the district produce a student calendar and bell schedules that are in the best interest of students
and parents.
Recommendations
The district should:
1. Provide on-site or off-site hands-on Transfinder routing software training for
the transportation operations supervisor and both transportation dispatcher-
schedulers.
2. Generate and implement a thorough special education transportation request
form that is generated with a student’s IEP to ensure service is provided in the
least restrictive environment.
3. Include the director of transportation or designee at IEP meetings that
include complicated transportation issues.
4. Implement a district-wide protocol for accepting students from a bus route
on arrival, such as 15 to 30 minutes prior to the beginning of school, to allow
the bus to move on to its next route on time.
5. Consider increasing the separation of time between each of the three master
bell schedule tiers from 35 minutes up to 45 to 50 minutes to allow for the
possible reduction of two to four school bus routes and a transportation
savings of approximately $120,000 to $240,000.
6. Add the director of transportation or a designee to the management team that
determines the district’s master bell schedule and school calendar.
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Trans PorTaTion
Staffing
The director of transportation conducts the administrative oversight, planning and supervi-
sion of the district’s comprehensive transportation program. An operations supervisor and a
vehicle maintenance supervisor assist the director. In the operations section, two transportation
dispatchers/schedulers aid the operations supervisor in creating and maintaining school bus
routes transporting approximately 2,679 students daily. The operations supervisor and schedulers
open the transportation facility at 5 a.m. and close the offices at 5:30 p.m., address the driver
coverage/absenteeism needs, adjust routes to staffing levels for the day, schedule new intakes
of special education students, schedule field trips and alter daily routing to support periodic
minimum school days.
As a result of fiscal challenges and budget reductions, the transportation program has reduced
its non-mandated home-to-school transportation service and some support staff over the last
few years. Special education transportation service has increased during the current school year
and remains significant. The transportation support staff has been reduced to a minimum level
as compared to other similar-size transportation programs FCMAT has reviewed. The district
provides transportation service to more than 10% of its total population and approximately
10% of the district’s identified special education students. The district operates 67 bus routes
transporting over 2,600 students daily along with transportation for more than 2,000 field trips
annually.
The district’s transportation support staff handles the home-to-school, special education and
field trip scheduling. In addition, these staff members handle the parent, school and community
telephone calls and the daily routing needs of school bus drivers. In comparable programs of this
size, recommended staffing for the operations section of transportation would be two to three
full-time transportation schedulers/dispatchers.
The staff struggles to meet their scheduling demands with one full-time transportation
dispatcher/scheduler and one transportation dispatcher/scheduler who works 199 days per fiscal
year with five weeks off. The assigned five weeks off are from the last week of June through July,
which is the busiest time for annual scheduling updates from special education, extended school
year transportation scheduling for the summer program, and the annual route planning for
home-to-school transportation. The loss of a scheduler during the busiest time period creates a
strain on staff and requires the operations supervisor to perform routine scheduling duties instead
of planning and overseeing work flows to prepare for the fall school start-up.
The district employs 65 permanent school bus drivers. Four of these drivers are not assigned to a
specific route and function as substitute drivers. There are six unassigned school bus routes, four
of which are special education routes. The district has nine qualified van drivers, who often are
driver candidates. However, this number fluctuates depending on the number of staff in training
for their school bus certificate. In addition, the district employs eight transportation assistants, or
bus aides. This number will fluctuate because two transportation assistants also are van drivers.
The Transportation Department organizational chart identifies only one bus driver trainer. The
California Department of Education School Bus Transportation Section recommends one trainer
per 25 certified school bus drivers. However, most school districts do not meet this recommen-
dation; they may augment their certified instructional staff by employing designated behind-
the-wheel instructors who work under the direction of a state certified instructor. The district
does not utilize behind-the-wheel instructors. The ratio of one bus driver instructor to district
certified school bus drivers is very high given the necessary record development, review, retention,
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Trans PorTaTion
behind-the-wheel training and classroom in-service training. The district’s certified school bus
instructor utilizes selected school bus drivers to perform driver proficiency evaluations. Although
specific instruction may not be occurring, official state training credit is being given on the state
Department of Education Training Certificate, form T-01. It is inappropriate for in-service
training time to be given without a state certified school bus driver instructor performing the
instruction or ride checks.
Recommendations
The district should:
1. Ensure that both schedulers are available for the high volume of scheduling
required over the summer.
2. Consider increasing the transportation dispatcher/scheduler positions from
two to three.
3. Recruit and train drivers to fill the six unassigned school bus routes.
4. Cease documenting official in-service on state Training T-01 forms when the
ride checks or proficiencies are not performed by a state certified instructor.
5. Consider utilizing designated behind-the-wheel instructors.
School Bus and District Vehicles
The district has a significant shortage of vehicles available to meet its transportation needs.
Although the district has an inventory of 90 school buses, six buses are nonoperational and
beyond economical repair, resulting in 84 units available to operate 67 school bus routes daily.
Although the spare ratio is 20%, an analysis of the district’s daily school bus repair report for the
two weeks prior to fieldwork for this study showed an unusually high number of daily units as
out of service for both preventative maintenance and general repairs. Each day, the out of service
log lists 15 to 20 buses as non-operational. The high number of non-operational buses often
exceeds the 17 spare buses, resulting in the need to utilize other district vehicles to complete the
routes. A thorough analysis of the reasons for daily bus nonoperational status needs to be done to
determine if this issue relates to the age and needed repairs of the district’s school bus fleet or may
relate to the workflow in the vehicle maintenance program.
An assessment of the district’s annual school bus report and inventory list shows that the average
age of a district bus is 16 years based on the 90 units listed in the report. However, extrapolating
the four buses that have been nonoperational for the full year shows that the district fleet has
accumulated over 17,511,000 miles, with the average unit miles at 203,606.
The California Association of School Business Officials (CASBO) School Transportation
Performance Profile recommends criteria for creating a school bus fleet replacement program.
School buses are identified in one of four categories based on their chassis weight and design, and
replacement is suggested as follows:
Vista UniFied school district
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Trans PorTaTion
• Type II School Buses (Designed for carrying no more than 16 passengers plus the driver,
or manufactured on or after April 1, 1977 with a manufacturer’s gross vehicle weight
rating of 10,000 or less and designed for carrying not more than 20 passengers and the
driver): 7 years/100,000 miles
• Type I Conventional School Buses (designed for carrying more than 16 passengers and
the driver): 15 years/200,000 miles
• Type I Transit (non-integral construction) (designed for carrying more than 16
passengers and the driver): 15 years/250,000 miles
• Type I Transit (integral construction) (designed for carrying more than 16 passengers and
the driver): 20 years/300,000 miles
As a result of the shortage of school buses, the district utilizes other district vehicles to transport
students. Transportation programs often use a passenger van or SUV type of vehicle for efficiency
when there are fewer than nine students to transport and/or when one or two students attend
an isolated program site and the routing makes it more efficient than scheduling the student
on a bus route. However, during the course of FCMAT’s fieldwork, district staff reported that a
district truck was utilized twice to transport a student. General passenger vehicles do not meet
the same stringent body design and crash impact standards as a certified school bus. Furthermore,
placing a student in the front seat of a passenger vehicle or truck is not a prudent practice because
it places the student in close proximity to the driver and reduces the frontal impact shock that
can be absorbed by a passenger riding in a rear seat, with the back of the seat in front of them to
provide shock absorption in the event of a crash.
Recommendations
The district should:
1. Determine the causes for the excessively high number of nonoperational
buses that result in an insufficient number of available buses to meet the
district’s transportation needs.
2. Explore the replacement of aging school buses.
3. Reconsider the practice of utilizing district trucks to transport students when
vehicle shortages exist.
Intra- and Interdepartmental Communication
The administration of Special Education and Transportation do not hold regular meetings that
would potentially allow both programs to quickly resolve challenges and concerns and provide an
avenue for both effective and ongoing communication.
Formal communication among transportation leadership staff does not occur regularly. The
director does not schedule specific times for key staff meetings with an agenda to allow for staff
collaboration. Although informal discussions may occur in general work areas, often they are
not attended because they are not viewed as mandatory or essential. In some cases, informal
discussions may occur when key staff is not present or available. Staff desires devoted time by
the director and a more formalized process to address current issues affecting the transportation
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Trans PorTaTion
program, with research, follow-up and time for open discussion as a team regarding these issues
and the department’s future plans.
All transportation staff appears to work diligently, and may feel there isn’t time for open commu-
nication as a leadership team. The transportation operations supervisor, driver instructor, vehicle
maintenance supervisor and schedulers need to meet regularly with the director of transportation
to share challenges, planning and the impacts each have on the other from the various aspects
of transportation work. Additionally, there appears to be a communication challenge between
the vehicle maintenance shop and the operations staff that may affect the daily transportation
of students because the shop does not understand the number and types of vehicles needed to
accomplish the workload.
Although transportation staff works closely with the special education secretary to ensure student
transportation requests are communicated, the director and/or operations supervisor do not
appear to be included in student IEP meetings where transportation services may be an issue for
discussion.
Recommendations
The district should:
1. Schedule routine meetings between key leadership staff in the Special
Education Department and the director of transportation and transportation
operations supervisor to discuss common goals, challenges and needs.
2. Implement regularly scheduled transportation staff meetings between the
director of transportation, supervisors, and other personnel on the depart-
ment’s leadership team. Encourage informal discussions as needed among
department work groups.
Vista UniFied school district
Fiscal crisis & ManageMent assistance teaM
5577
Pro GraMa ePfPfeicnideincceys
Appendices
Appendix A - Example of Excess Costs Calculation
Appendix B - Size and Scope Requirements
Appendix C - Forms for Determining One-to-One or Special
Circumstances Aide
Appendix D - Forms and Guidelines for Specialized
Procedures
Appendix E - Information on Learning Centers
Appendix F - Study Agreement
Vista UniFied school district
5588
ParPoPeGnrdaiMc eesfficiency
Fiscal crisis & ManageMent assistance teaM
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hcae
fo noitacude
eht rof dneps tsum AEL
na tnuoma egareva
muminim
eht etupmoc
ot woh
swohs woleb elpmaxe
ehT
.tcA eht
fo B traP rednu
sdnuf esu yam ti erofeb
emit
lluf
detacifitrec
no
desab
tilps ot
si hcaorppa
enO
.sehcaorppa
fo
yteirav
a esu nac
sAEL
taht
detseggus
neeb
sah tI .tcirtsid deifinu
a rof loohcs hgih
morf
yratnemele
tuo kaerb
ot woh no
selur laiciffo on era erehT
ediw-tcirtsid
a ni
evres
ETF
fI
.yletanoitroporp
serutidnepxe
etar-orp
dna
yradnoceS
ni ETF
detacifitrec
fo rebmun
eht dna yratnemelE ni ETF
detacifitrec fo
rebmun
eht
tnuoc dluohs
AEL eht siht
od oT .)ETF( tnelaviuqe
.rennam
elbanosaer
a ni meht etar-orp ,yticapac
.1102
,51
rebmetpeS
erofeb
ro no
seengised
ro
sOBC
eht
fo
erutangis
eht
htiw )sAPLES(
aerA
nalP
lacoL noitacudE
laicepS rieht ot )woleb
ees( etalpmet
siht timbus
tsum stcirtsid
,1102,03
enuJ gnidne raey eht
roF
.noisiviD
noitacudE
laicepS
eht fo tseuqer
no elbaliava eb tsum
stroper eseht dna
,stroper
tsoc ssecxe
stcirtsid rieht
etadilosnoc tsum sAPLES
noitinifeD
lacoL
YLNO SLLEC
DETHGILHGIH
WOLLEY NI LLIF :ETON
LATOT
YRADNOCES
%
YRATNEMELE
%
SERUTIDNEPXE
%00.94
%00.15
s%
ETF ffats detacifitrec retnE
traP
gnidulcni(
laredeF
dna ,etatS
,lacol—sdnuf
GNITAREPO
lla morf stneduts
rof serutidnepxe
sti
fo tnuoma
latot eht
enimreted tsum
AEL eht tsriF .a noitceS
)YLNO 26-16
dna ,31
,90-10 SDNUF
esU( .raey
loohcs roirp eht ni—)B
804,753,97
$
584,695,28
$
398,359,161
$
9999-0006
dna 9992-0000
SR ;26 ,16 ,31 ,90-10
DF - serutidnepxE
lacoL
dna etatS1
metI
331,226,11
$
605,690,21
$
936,817,32
$
)5833
fo noitrop
etats
& 5533
gnidulcxe(
9995-0003 SR ;26 ,16
,31 ,90-10 DF -
serutidnepxE
laredeF2
metI
145,979,09
$
199,296,49
$
235,276,581
$
serutidnepxE
latoT3
metI
secruoser
gniwollof
eht rof
raey
roirp
ni
tneps stnuoma
lla evoba .a noitces
ni detaluclac serutidnepxe
latot
eht morf
tcartbus tsum
AEL eht ,txeN .b noitceS
MA
35:8
2102/5/7
detnir)YLNO
26-16
dna ,31 ,90-10
SDNUF esU( .ylno serutidnepxe
lautca
era
esehT
.)serutidnepxe
latnemelppus
deredisnoc era eseht(
145,979,09
$
199,296,49
$
235,276,581
$
serutidnepxE
latoT4
metI
967,951,3
$
937,882,3
$
805,844,6
$
6833 ,4043
,4333
,9233
,4233 ,2233
,9133 ,4133 ,3133 ,1133
,0133 SR - noitacolla
B
traP ,AEDI5
metI
442,182,3
$
371,514,3
$
714,696,6
$
5813 ,8713-5713
,3103 ,2103 ,1103
,0103 SR - noitacollA
A
traP ,I eltiT6
metI
877,462
$
585,572
$
363,045
$
4024-1024
SR - noitacollA
B & A traP
,III eltiT7
metI
751,241,51
$
502,067,51
$
263,209,03
$
xxx5
laoG - seitilibasiD htiW
nerdlihC rof tnepS
sdnuF
lacoL
& etatS8
metI
‐
$
‐
$
-
$
)snoitubirtnoc
FG( B
& A straP ,III eltiT & A traP
,I eltiT rof tnepS
sdnuF
lacoL
& etatS9
metI
295,131,96
$
092,359,17
$
288,480,141
$
serutidnepxe
latnemelppus ssel
serutidnepxE
latoT01
metI
5599
Pro GraMa ePfPfeicnideincceys
Appendix A
Vista UniFied school district
APLES
ESCCN
tcirtsiD
loohcS
deifinU atsiV
noitaluclaC
tsoC ssecxE
2102-1102
YF
)YLNO
26-16 ,31
,90-10
SDNUF( .evoba
.b noitces
ni detsil ton secruoser
rof ecivres
tbed
dna
yaltuo
latipac
tcuded ,txeN
.c noitceS
295,131,96
$
092,359,17
$
288,480,141
$
serutidnepxe
latnemelppus
ssel
serutidnepxE
latoT11
metI
864,345
$
056,565
$
811,901,1
$
0058
NOITCNUF
ro/&
,9347 JBO ro/&
,8347 JBO
ro/& ,xxx6 JBO
- tbeD
dna yaltuO
latipaC21
metI
421,885,86
$
936,783,17
$
467,579,931
$
tbeD
& yaltuO latipaC
ssel
serutidnepxE
latoT31
metI
eht
fo loohcs
eht
ni dellorne stneduts
fo rebmun
egareva eht
gnidivid erutidnepxe
tneduts
rep
launna egareva
eht
enimreted
tsum
AEL
eht ,txeN
.d noitceS
siht
hguorht
deniatbo
tnuoma
ehT .hpargarap
evoba eht rednu
detupmoc
tnuoma eht otni
)seitilibasid
htiw
nerdlihc
sti
gnidulcni(
raey
roirp eht gnirud
ycnega
eb
yam
sdnuf
B traP
"erofeb" seitilibasid
htiw
nerdlihc
sti fo hcae
fo noitacude
eht rof )egareva
eht
no( dneps
tsum AEL
eht
tnuoma
muminim
eht si noitatupmoc
.desu
421,885,86
$
936,783,17
$
467,579,931
$
noitaluclac
egareva
rof tnuoma
latoT31
metI
108,6
416,51
514,22
) dE
laicepS dna
dE lareneG(
stneduts
LLA ,SDEBC
- raey
loohcs roirp ni dellorne
stneduts
fo
rebmuN41
metI
580,01
$
275,4
$
542,6
$
tneduts rep erutidnepxe
launna
egarevA51
metI
gnidulcni
ton(
AEL
eht
ni seitilibasid
htiw nerdlihc
sti fo noitacude
eht rof dneps
tsum AEL eht
sdnuf
fo tnuoma
muminim
latot
eht enimreted
ot ,txeN
.e noitceS
rep
launna
egareva
eht semit
AEL eht ni
seitilibasid
htiw nerdlihc
fo rebmun
s'raey lacsif
tnerruc
eht ylpitlum
tsum
AEL
eht
,)ecivres
tbed dna yaltuo
latipac
.muminim
siht evoba
dna revo stsoc
ssecxe rof desu
eb ylno nac
tcA eht fo B traP
rednu
sdnuF
.evoba
d hpargarap
ni deniatbo
erutidnepxe
tneduts
eht
seificeps
atad SIMESAC
.sessalc
de
laiceps ni yllautca
si tneduts
hcae emit fo tnuoma
eht etaluclac
ot uoy
seriuqer
woleb
71 metI :ETON
dehcatta
eeS
.hcae
no ETF
a teg ot tneduts
de laiceps hcae
rof noitamrofni
siht esU .noitacudE
lareneG
ni si tneduts
hcae
taht emit
fo egatnecrep
snoitcurtsni
noitaluclac
rof teehskrow
580,01
$
275,4
$
542,6
$
tneduts rep erutidnepxe
launna
egarevA61
metI
63.635
52.855
16.490,1
)sessalc
de laiceps
ni
tneps emit fo
ETF(
stnelaviuqe
tneduts de laiceps
emit-lluf
fo
rebmuN71
metI
381,904,5
$
933,255,2
$
155,538,6
$
)tsoC
ssecxE( SDNUF
B TRAP
GNISU
EROFEB
TNEPS EB
TSUM TAHT TNUOMA
MUMINIM
LATOT81
metI
tnuoma
eht
sdeecxe
ro ot lauqe
si tnuoma
siht
yfirev dna seitilibasid
htiw
nerdlihc tcirtsid no
raey
tnerruc
ni
tneps saw
hcum
woh enimreted
,yllaniF
.f noitceS
)YLNO
26-16
,31 ,90-10
SDNUF(
evoba
.e noitces ni
detaluclac
381,904,5
$
933,255,2
$
155,538,6
$
)tsoC ssecxE(
SDNUF
B TRAP
GNISU EROFEB
TNEPS
EB TSUM TAHT TNUOMA
MUMINIM
LATOT
91
metI
9999-0006
;9992-0000
SR
- seitilibasiD
htiW
nerdlihC rof tnepS
sdnuF lacoL
& etatS - serutidnepxe
RAEY
TNERRUC
014,808,61
$
764,494,71
$
778,203,43
$
XXX5
laoG dna*02
metI
722,993,11
$
821,249,41
$
623,764,72
$
*tnemeriuqer
fo ssecxe
ni seitilibasid
htiw nerdlihc
no tneps
tnuomA**12
metI
siht
ni
dedulcni
ton
si
FARCP
eht
morf
noitamrofnI
.)FARCP(
mrof
latnemelppus
SCAS
edulcni
ton
seoD ,raey
roirp si 9
enil ,RAEY TNERRUC
si sihT
.evoba
9
enil
sa
emas eht
ton si 02 metI
:etoN
*
.teehskrow
.sdnuf
B
traP
AEDI
laredefrieht
fo
yna
esu
ton
yam dna tnemeriuqer
tsoc
ssecxe eht
tem
ton sah
AEL eht neht evitagen
a si ti
fI
.tnuoma
evitisop
a eb
dluohs
12 metI
:etoN**
rekaB
asereT
eengiseD
laiciffO
slleW isaC
reciffO laicnaniF
feihC
tcirtsiD
loohcS deifinU
atsiV
6600
ParPoPeGnrdaiMc eesfficiency
Fiscal crisis & ManageMent assistance teaM
6611
Pro GraMa ePfPfeicnideincceys
Appendix B
Size And Scope
Of Special Education Local Plan Areas as approved by the State Board of Education at the November 17-18, 1983
meeting.
The county superintendent of schools shall submit to the Superintendent of Public Instruction a description of how
districts within the county intend to develop special education local plans (Education Code 56140).
The following standards are to be used by the county and districts to determine if they are of sufficient size and scope
to qualify as a Special Education Local Plan Area (SELPA) (Education Code 56195.1). 1
In addition to being of sufficient size and scope to qualify as a SELPA, the SELPA shall cooperate with the Office of
the County Superintendent of Schools and other school districts in the geographic area in order to assure that the
SELPA is compatible with other SELPAs in the county, as required by Education Code (EC) Section 56195.3. 2
A region may not become a SELPA without approval of the SELPA by the county superintendent or a decision of the
Superintendent of Public Instruction to overrule the disapproval of the county superintendent of schools, pursuant to
EC Section 56140.
Metropolitan Areas
A metropolitan area is defined as an area that has a pupil population density of 200 pupils or more per square mile.
Population density is computed by dividing total number of K-12 pupils in the SELPA by the square miles to
determine number of pupils per square mile. All SELPAs in metropolitan areas shall have comprehensive special
education programs. A county superintendent of schools may allow a minimum of contract services for low-incidence
programs with justification, in addition to utilizing State Special School programs for low-incidence sensory-
handicapped pupils.
Single-District SELPAs
A single district must have kindergarten through 12 grades and 30,000 or more pupils
Multi-District or District-County SELPAs
Method One:
Kindergarten through 12th grade
30,000 or more pupils
No more than 15 miles from border to border of the SELPA at the longest distance
Method Two:
Kindergarten through 12th grade
25,000 to 30,000 pupils
No more than 20 miles from border to border of the SELPA at the longest distance
Method Three:
Kindergarten through 12th grade
20,000 to 25,000 pupils
No more than 30 miles from border to border of the SELPA at the longest distance
Non-Metropolitan Areas
Vista UniFied school district
6622
ParPoPeGnrdaiMc eesfficiency
Population density of less than 200 pupils per square mile
Single-District (Non-Metropolitan Area) SELPAs
In a non-metropolitan area, a single-district plan shall have:
15,000 or more pupils
A comprehensive special education program
Contracting may be allowed, with justification, for low-incidence programs
Multi-District, District-County, Multi-County SELPAs (Non-Metropolitan Areas)
Must have a comprehensive special education program
Contracting is allowed, with justification, for low-incidence programs in addition to utilizing State Special
School programs for sensory-handicapped pupils
Contracting
All contracts for low-incidence programs shall contain the clause that neither party may cancel the contract without a
12-month notice or upon mutual agreement of all parties to the contract.
Note: While the State Board of Education-adopted standards specifically address kindergarten through twelve
grades, it is important to note that SELPAs are responsible for planning and coordinating services for all children with
disabilities birth to twenty-two years of age.
1ECSection changed pursuant to AB1115, Chapter 78, Statute of 1999
2EC Section changed pursuant to AB602, Chapter 854, Statute of 1997
Fiscal crisis & ManageMent assistance teaM
6633
Pro GraMa ePfPfeicnideincceys
Appendix C
Vista UniFied school district
6644
ParPoPeGnrdaiMc eesfficiency
Fiscal crisis & ManageMent assistance teaM
6655
Pro GraMa ePfPfeicnideincceys
Vista UniFied school district
6666
ParPoPeGnrdaiMc eesfficiency
Appendix D
Fiscal crisis & ManageMent assistance teaM
6677
Pro GraMa ePfPfeicnideincceys
Transportation Requirements Assessment
(Adapted from Beaumont USD)
IMPORTANT: ALL INFORMATION CONTAINED ON THIS FORM IS STRICTLY
CONFIDENTIAL. DISCLOSING THIS INFORMATION TO ANY PARTY NOT
DIRECTLY RESPONSIBLE FOR THE SAFETY AND WELFARE OF THE CHILD
IS A VIOLATION OF STATE AND FEDERAL LAW.
Child’s Name:___________________________________ Student
ID:____________________
School:_____________________________________ Grade:_______
Date:_____________________ 1. Disability
1. 1a. What is the child’s
disability?___________________________________________________
__
2. 1b. Yes No Are there specific IEP goals for the child’s bus ride?
3. 1c. If yes, what are they?
___________________________________________________________
2. Behavior and Supervision on the Bus Ride
1. 2a. Yes No Can the child be safely included on a bus with typical
children?
2. 2b. Yes No Does child exhibit behavior aggressive or potentially
dangerous to self/others?
3. 2c. Yes No Are there specific “triggers” or situations known to provide the
child?
1. 2d. If yes, what are
they?_______________________________________________________
____
___________________________________________________________
_________________
Vista UniFied school district
6688
ParPoPeGnrdaiMc eesfficiency
2. 2e. Yes No Is there a behavioral intervention plan in place for the child?
(attach copy if yes)
3. 2f. Yes No Does the child require additional adult supervision on the bus
besides the driver?
4. 2g. If an attendant is required, is specialized training needed? (circle any
topics that apply)
Violence prevention training Epi-Pen training CPR certification
Other specialized training (describe):
______________________________________________
___________________________________________________________
_________________
5. 2h. Yes No Does the child require an individualized, one-on-one attendant
during bus rides?
3. Vehicle and Equipment Needs
1. 3a. Yes No Can the child use the vehicle stairs to enter and exit the bus?
2. 3b. Does child use braces, a walker, manual wheelchair, or power
wheelchair? (If yes, circle which)
3. 3c. If child uses a wheelchair, indicate dimensions and any special
features (e.g., tilt-in-space, etc.):
Width: _____(in inches) Length: _____ (in inches) Special features:
____________________
4. 3d. Yes No If child’s wheelchair has a lap tray, may it be safely removed
during the bus ride?
5. 3e. Yes No Can the child be safely transported to a school bus seat for the
bus ride?
If yes, are special restraints
required?______________________________________________ If yes, what
assistance is
required?________________________________________________ How much
does the child weigh?
_________________________________________________
4. Medical Concerns
Fiscal crisis & ManageMent assistance teaM
6699
Pro GraMa ePfPfeicnideincceys
1. 4a. Yes No Does the child have a potentially life threatening condition or
illness that requires monitoring, evaluation, and possible intervention by a
nurse or other medical professional during the bus ride? If yes, what is the
condition or illness? _____________________________________
2. 4b. Yes No Does the child use assistive devices or medical technology
such as tracheotomy or feeding tubes, ventilator, oxygen, suctioning
devices, or wear a helmet or other protective gear? If yes, describe the
device or technology required:
____________________________________
___________________________________________________________
__________________
3. 4c. Yes No Does the child experience uncontrolled seizures, severe
hypotonia resulting in constricted airway, or apnea? If yes, circle which and
attach medical assessment.
4. 4d. Yes No Will the bus staff be expected to perform any medical
procedure or operate any medical equipment during the bus ride? If yes,
what procedures or equipment? _______________
___________________________________________________________
___________________
5. 4e. Yes No Does the child experience severe allergic reactions? If yes,
allergic to what?
___________________________________________________________
___________________
6. 4f1. Yes No Does the child carry an “Epi-Pen?”
7. 4f2. Yes No If yes, is the child trained in how to self-administer the Epi-
Pen?
8. 4g1. Yes No Does the child require medication to be transported on the
bus? If yes, specify type(s) of medication and the amount(s) to be
transported: ______________________________
___________________________________________________________
__________________
9. 4g2. If yes, must the medication be available for the child to use during the
bus ride, or is the medication only to be transported between home and
school? ___________________________
10. 4g3. If yes, must the medication be available for the child to use during
other activities/field trips requiring
Vista UniFied school district
7700
ParPoPeGnrdaiMc eesfficiency
transportation?_______________________________________________
__________
11. 4h. Yes No In an emergency, could the child safely be lifted and carried
off the bus?
12. 4i. Yes No Is an Out-of-Hospital “Do Not Resuscitate” Order in effect for
the child?
13. 4j. Yes No Does the child’s medical condition require any other special
adaptations or restrictions to the bus environment? (e.g., temperature,
light, noise, duration of ride, etc.) If yes, what adaptations or restrictions?
__________________________________________________
___________________________________________________________
__________________
5. Special Transportation Concerns
1. 5a. Yes No Can the child be safely picked up and dropped off at a group
bus stop?
2. 5b. Yes No Must a designated adult be present to accept custody of the
child when dropped
off at the bus stop and/or home?
3. 5c. Yes No Does the child require any special seating arrangements (e.g.,
position on the bus ride)? If yes, what are they?
____________________________________________________
4. 5d. Yes No Does the child need a child safety restraint system (e.g., car
seat, safety vest, etc.) on the bus ride? If yes, what?
__________________________________________________
5. 5e. Yes No Does the child require an assistance animal during the bus
ride?
6. 5f. Yes No Does the child require any special communication techniques
(e.g., sign language, sign board, facilitative communication board, etc.)? If
yes, what are they?
___________________________________________________________
_________________
Fiscal crisis & ManageMent assistance teaM
7711
Pro GraMa ePfPfeicnideincceys
7. 5g. Yes No Are there any other special concerns that the bus driver,
attendant or other transportation staff should know to ensure the safety
and welfare of the child during the bus ride? If yes, what are they?
___________________________________________________________
___________________________________________________________
__________________
6. Emergency Contacts.
List the names, relationship (i.e., parent, neighbor, physician, etc.) and phone
numbers of all emergency
contacts for the child.
________________________________________________________________
_____________________
________________________________________________________________
_____________________
________________________________________________________________
_____________________
________________________________________________________________
_____________________
________________________________________________________________
_____________________
Information provided by:
Print name: _______________________________ Signature:
_________________________________ Date:
____________________________________
Information received by:
Print name: __________________________ Signature:
___________________________ Date: _______________________________
Vista UniFied school district
7722
ParPoPeGnrdaiMc eesfficiency
Appendix E
Fiscal crisis & ManageMent assistance teaM
7733
Pro GraMa ePfPfeicnideincceys
Vista UniFied school district
7744
ParPoPeGnrdaiMc eesfficiency
Fiscal crisis & ManageMent assistance teaM
7755
Pro GraMa ePfPfeicnideincceys
Appendix F
Vista UniFied school district
7766
ParPoPeGnrdaiMc eesfficiency
Fiscal crisis & ManageMent assistance teaM
7777
Pro GraMa ePfPfeicnideincceys
Vista UniFied school district
7788
ParPoPeGnrdaiMc eesfficiency
Fiscal crisis & ManageMent assistance teaM
7799
Pro GraMa ePfPfeicnideincceys
Vista UniFied school district