Washington Unified School District Report

Washington Unified School District Special Education Review June 6, 2017 Joel D. Montero Chief Executive Officer Fiscal crisis & ManageMent assistance teaM June 6, 2017 Linda Luna, Superintendent Washington Unified School District 930 Westacre Road West Sacramento, CA 95691 Dear Superintendent Luna: In October 2016, the Washington Unified School District and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for a study to do the following: 1. Review the district’s implementation of student study team (SST), Response to Intervention (RtI) and multi-tiered system of supports (MTSS), including preidentification processes for preschool students, and make recommendations for improvement, if any. 2. Analyze whether the district provides a continuum of special education and related services, which includes student placements in the least restrictive environment, and make recommendations for improvement, if any. 3. Review special education teacher staffing ratios, class and caseload size using the statutory requirements for mandated services and statewide guidelines and make recommendations for improvement, if any. 4. Analyze staffing and caseloads for related service providers, such as: speech thera- pists, psychologists, occupational/physical therapists, behavior specialists, adaptive physical education teachers, credentialed nurses and others, and make recommen- dations for improvement, if any. 5. Review the efficiency of staffing allocations of special education paraeducators and make recommendations for improvement, if any. This will include reviewing the procedures used for identifying the need for paraeducators, the process for moni- toring the assignment of paraeducators and determining the ongoing need for continued support from year to year (including classroom and 1:1 paraeducators). 6. Review the organizational structure and staffing of the central office special educa- tion department and make recommendations for improvement, if any. FCMAT Joel D. Montero, Chief Executive Officer . . 1300 17th Street - CITY CENTRE, Bakersfield, CA . 93301-4533 Telephone 661 . -636-4611 Fax 661 . -636-4647 755 Baywood Drive, 2nd Floor, Petaluma, CA 94954 Telephone: 707-775-2850 Fax: 661-636-4647 www.fcmat.org Administrative Agent: Mary C. Barlow - Office of Kern County Superintendent of Schools 7. Review COE, NPS and NPA costs and placements and make recommenda- tions for improving the process for placement and cost efficiencies, if any. This report contains the study team’s findings and recommendations. FCMAT appreciates the opportunity to serve the Washington Unified School District and extends thanks to its staff for their cooperation and assistance during this review. Sincerely, Joel D. Montero Chief Executive Officer i TABLE OF CONTENTS Table of Contents About FCMAT ...................................................................iii Introduction ........................................................................1 Executive Summary ...........................................................3 Findings and Recommendations .....................................5 SST/RtI2/MTSS…………………………………………………………5 Continuum of Services ..............................................................................................11 Special Education Teacher Staffing and Caseloads ...........................................13 Paraeducator Staffing ................................................................................................19 Related Service Provider Staffing and Caseloads ...............................................23 Organizational Structure ..........................................................................................29 Contracted Services....................................................................................................33 Appendix ........................................................................... 37 Washington Unified school district ii Fiscal crisis & ManageMent assistance teaM iii ABOUT FCMAT About FCMAT FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify, prevent, and resolve financial, human resources and data management challenges. FCMAT provides fiscal and data management assistance, professional development training, product development and other related school business and data services. FCMAT’s fiscal and manage- ment assistance services are used not just to help avert fiscal crisis, but to promote sound financial practices, support the training and development of chief business officials and help to create efficient organizational operations. FCMAT’s data management services are used to help local educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and inform instructional program decisions. FCMAT may be requested to provide fiscal crisis or management assistance by a school district, charter school, community college, county office of education, the state Superintendent of Public Instruction, or the Legislature. When a request or assignment is received, FCMAT assembles a study team that works closely with the LEA to define the scope of work, conduct on-site fieldwork and provide a written report with findings and recommendations to help resolve issues, overcome challenges and plan for the future. FCMAT has continued to make adjustments in the types of support provided based on the changing dynamics of K-14 LEAs and the implementation of major educational reforms. Studies by Fiscal Year 90 80 70 60 50 40 30 20 10 0 92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15 Washington Unified school district seidutS fo rebmuN FCMAT also develops and provides numerous publications, software tools, workshops and professional development opportunities to help LEAs operate more effectively and fulfill their fiscal oversight and data management responsibilities. The California School Information Services (CSIS) division of FCMAT assists the California Department of Education with the implementation of the California Longitudinal Pupil Achievement Data System (CALPADS). CSIS also hosts and maintains the Ed-Data website (www.ed-data.org) and provides technical expertise to the Ed-Data partnership: the California Department of Education, EdSource and FCMAT. FCMAT was created by Assembly Bill (AB) 1200 in 1992 to assist LEAs to meet and sustain their financial obligations. AB 107 in 1997 charged FCMAT with responsibility for CSIS and its state- wide data management work. AB 1115 in 1999 codified CSIS’ mission. iv ABOUT FCMAT AB 1200 is also a statewide plan for county offices of education and school districts to work together locally to improve fiscal procedures and accountability standards. AB 2756 (2004) provides specific responsibilities to FCMAT with regard to districts that have received emergency state loans. In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to those types of LEAs. Since 1992, FCMAT has been engaged to perform more than 1,000 reviews for LEAs, including school districts, county offices of education, charter schools and community colleges. The Kern County Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D. Montero, Chief Executive Officer, with funding derived through appropriations in the state budget and a modest fee schedule for charges to requesting agencies. Fiscal crisis & ManageMent assistance teaM 1 INTRODUCTION Introduction Background Located in West Sacramento, the Washington Unified School District encompasses slightly more than 19 miles and serves approximately 7,735 students at eight elementary, one middle, one comprehensive high, one continuation high, and one alternative high school. The district has authorized one dependent charter school and two independent charter schools. The district is part of the Yolo County Special Education Local Plan Area (SELPA), and according to 2015-16 data from the California Department of Education, 791 students from birth to age 22 who live in the district are identified as having special needs. In October 2016, the district and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for management assistance to review the district’s special education program. Study and Report Guidelines FCMAT visited the district on January 17-20, 2017 to conduct interviews, collect data, and begin reviewing documents. This report is the result of those activities and is divided into the following sections: • Executive Summary • SST/RtI2/MTSS • Continuum of Services • Special Education Teacher Staffing and Caseloads • Paraeducator Staffing • Related Service Provider Staffing and Caseloads • Organizational Structure • Contracted Services • Appendix In writing its reports, FCMAT uses the Associated Press Stylebook, a comprehensive guide to usage and accepted style that emphasizes conciseness and clarity. In addition, this guide empha- sizes plain language, discourages the use of jargon and capitalizes relatively few terms. Washington Unified school district 2 INTRODUCTION Study Team The study team was composed of the following members: Shayleen Harte Jackie Kirk-Martinez, Ed.D. FCMAT Intervention Specialist FCMAT Consultant Bakersfield, CA Pismo Beach, CA JoAnn Murphy Don Dennison FCMAT Consultant FCMAT Consultant Santee, CA Arroyo Grande, CA Leonel Martínez FCMAT Technical Writer Bakersfield, CA Each team member reviewed the draft report to confirm its accuracy and to achieve consensus on the final recommendations. Fiscal crisis & ManageMent assistance teaM 3 EXECUTIVE SUMMARY Executive Summary The district does not have formalized systems for Response to Intervention (RtI2) and Multi- Tiered System of Supports (MTSS). These are necessary to build a comprehensive delivery system of interventions and supports for district students. Informal interventions occur throughout the district, but the level of support differs from school to school. The Student Success Team (SST) process focuses primarily on the need for assessment to determine eligibility for special education. The SST process should focus on designing a support system for struggling students. The district does not provide a continuum of special education services in the least restrictive environment. The district has various program options for students from preschool through age 22; however, it does not provide an inclusive program, blended learning or a co-teaching model in the least restrictive environment. Although the district provides general education preschools, special education preschool students are served in a special day class and do not access the general education preschool. The district maintains a traditional service model for students who require mild/moderate special education support by offering resource specialist services and mild/moderate special day class (SDC) services, which operate as separate entities. In providing special education support, the district should consider implementing models of specialized academic instruction that address the services provided by mild/moderate SDCs. Determining special education instructional staff levels and caseloads for this study was hindered by the lack of accurate and consistent data and conflicting information between the district departments responsible for tracking this information. The district should establish and clearly communicate to staff the standards for establishing staffing and caseload guidelines. The Special Services Department indicated it relies on the Yolo SELPA guidelines for staffing levels, but district documentation did not confirm this nor did interviews with staff indicate that anyone aside from the department director was aware of these guidelines. Position control documen- tation on certificated and classified special education instructional staff was inconsistent with the information from the Special Services Department. The district should conduct a rigorous internal audit to establish an accurate baseline of current staffing and caseloads. Reliable and consistent procedures for tracking and communicating staffing data should be established. These procedures should also serve as a foundation for a thorough and consistent review and justifica- tion for any mid-year special education staff addition that is submitted to cabinet as well as for annual budget planning. Student caseloads for special education teachers are mostly within Education Code requirements and industry standards. The K-8 resource specialists are understaffed by less than 1 FTE, and the high school resource specialists are overstaffed by less than 1 FTE. Adjustments could be made between grade levels if the district determined they were appropriate. The nonpublic agency (NPA) contract for 1 FTE resource specialist service costs the district $24,443 per year more than the expense for the average resource teacher salary including benefits. Contracting with an NPA for this type of service is highly unusual, and the district should make it a high priority to aggressively recruit and hire an employee to fill this assignment. The district does not consistently use the Yolo SELPA model to determine the necessity of providing 1-to-1 paraeducators. This procedure should be consistently applied. A comparison of several district-provided documents found that it has 7 FTE 1-to-1 paraeducators at a total cost of $174,277. Of additional concern is evidence that the district is overstaffed in paraeducators for Washington Unified school district 4 EXECUTIVE SUMMARY the resource specialist program and SDCs when compared to industry standards. The overstaffing of 14 paraeducators results in an average total cost of $340,430. The district should require the Business, Special Services and Human Resources departments to meet at least monthly to discuss personnel increases and decreases in addition to caseloads and other budgetary items in special education. Because of the inconsistent documents and lack of leadership in the Special Services Department, FCMAT cannot determine if speech and language pathologists are within Education Code caseload requirements. The district has sought additional speech and language pathologists; however, it has not used speech services available via telecom- munication. FCMAT recommends immediate research and implementation of this option to fill any vacancies. The Special Services Department’s organizational structure was compared with three districts of similar size, special education enrollment and identification rate for disabled students. The clerical support level was consistent except that the district is 0.5 FTE above the average of the other districts; however, additional duties in health services require the additional support. The district’s certificated staffing is technically comparable to other districts reviewed; however, it has transferred behavior specialists from their assignments to program specialist duties. This practice increases the administrative ratio and hinders services for behavior management. Communication from the department leadership is inconsistent with directives from the district level. The Special Services administration and other district administrative staff deliver conflicting messages, which causes confusion for staff implementing special education at the site level. Meetings are frequently cancelled, affecting overall efficiency and credibility. The district does not consistently provide the related services required by federal and state law. The administration should give this issue its immediate attention by developing a plan to correct this deficiency in programming. The annual costs of nonpublic schools have increased in the last three years despite decreases in the number of students attending. The Yolo County SELPA maintains a nonpublic school pool for district reimbursements for students that require placement in a nonpublic school. The funding for this pool comes “off the top” of the SELPA funding model, which means it is taken from the total SELPA allotment before any funds are distributed. NPA expenditures for each of the last three years are for staffing in speech and language therapy, occupational therapy and sign language services. This occurred because of the district’s inability to hire certified staff and can cost more than personnel hired by the district. This year’s NPA costs include one resource specialist teacher as well. Fiscal crisis & ManageMent assistance teaM SST/RTI2/MTSS (PRESCHOOL AND K-12) 5 Findings and Recommendations SST/RtI2/MTSS (Preschool and K-12) Serving a student with an individualized educational program (IEP) is more expensive than using general education intervention supports. Identifying a student for special education before attempting general education interventions is contrary to the purpose of the Individuals with Disabilities Education Act (IDEA) of 2004 and not in the student’s best interest. Special education should be the last option because of state and federal laws and district costs. These laws mandate that students be educated in a general education setting with their nondisabled peers, also known as the least restrictive environment (LRE) to the greatest extent possible. Response to Intervention – The reauthorization of the IDEA in 2004 provided support for models that include a response to scientific, researched-based interventions. The law stated that these methods may be used as an alternative to the discrepancy model when identifying students with learning disabilities. IDEA 2004 also shifted researched-based interventions from special education to general education, stressing that this method would no longer be limited to special education students, but would apply to all students. The law left each individual state to develop its own guidelines and regulations. RtI, which the California Department of Education (CDE) now refers to as Response to Instruction and Intervention (RtI2), provides districts with a method to drive educational decisions and measure academic growth. The CDE information states the following: RtI2 is meant to communicate the full spectrum of instruction, from general core, to supple- mental or intensive, to meet the academic and behavioral needs of students. RtI2 integrates resources from general education, categorical programs, and special education through a comprehensive system of core instruction and interventions to benefit every student. The CDE further states that RtI2 is used in the following three ways: 1. Prevention: All students are screened to determine their level of performance in relation to the grade-level benchmarks, standards, and potential indicators of academic and behavioral difficulties. Rather than wait for students to fail, schools provide research-based instruction within general education. 2. Intervention: Based on frequent progress monitoring, interventions are provided for general education students not progressing at a rate or level of achievement commen- surate with their peers. These students are selected to receive more intense interventions. 3. Component of SLD determination: The RtI2 approach can be one component of the SLD determination as addressed in the Individuals with Disabilities Education Act (IDEA) 2004 statute and regulations. The data from the RtI2 process may be used to demonstrate that a student has received researched-based instruction and interventions as part of the eligibility determination process. Washington Unified school district 6 SST/RTI2/MTSS (PRESCHOOL AND K-12) The CDE is in the process of further defining how RtI2 could be used in the eligibility process. Source: http://www.uesf.org/wp-content/uploads/RTII-Eligibility-CDE. pdf, Determining Specific Learning Disability Eligibility Using Response to Instruction and Intervention. FCMAT reviewed the RtI at both the preschool and K-12 levels. Special education district staff reported that RtI2 and the SST process is inconsistently used between sites, which results in varying levels of special education referrals for assessments. This may lead to underqualifying or over qualifying students for special education. Best practices suggest that districts should have a foundational level of expectations for RtI2 at all sites. This would ensure that there is a minimum level of service requirement. The district provides limited interventions in preschool for students who are screened and iden- tified for articulation disorders. Speech therapists serve 71 students who receive eight weeks of articulation therapy in speech improvement classes. Parents are asked to sign a permission slip to participate in the class. After eight weeks, students are reassessed and can continue for 10 more weeks of therapy if needed. Staff reported that this practice has no written procedures, and each therapist manages the process individually. The district should establish guidelines for speech therapists on providing intervention versus assessment requirements for the IDEA 34 C.F.R. Part 300.301 and Part 300.302 on using screening as an instructional tool in order to ensure compliance. During a presentation held at the National Association of School Psychologists Convention in 2006, George Batsche and W. David Tilly identified three phases in the implementation of RtI2: Consensus building (commitment from the staff), infrastructure and implementation. RtI2 implementation is best led by the Education Services Department with consultation from the Special Services Department. This would be crucial in the implementation process because RtI2 is a general education function and acceptance should be sought from the entire staff. The district should also consider hiring an expert to assist with the planning, training, and implementation phases of this model. Multi-tiered System of Supports – “The Special EDge,” Winter 2015, Volume 29, No. 1, describes Multi-Tiered System of Supports (MTSS) as “standards based instruction, interven- tions, mental health, and academic and behavioral supports aligned with accessible instruction and curriculum…” The Special EDge issue highlights that a MTSS approach can, “be used to develop and align resources, programs, supports, and services at all organizational levels to increase positive student outcomes.” The Report of California’s Statewide Task Force of Special Education, “One System: Reforming Education to Serve All Students”, March 2015, states, “A multi-tiered system of supports (MTSS) is a whole-school, data driven, prevention-based frame- work for improving learning outcomes for every student through a layered continuum (typically three tiers) of evidence-based practices that increases in intensity, focus, and target to a degree that is commensurate with the needs of the student.” The publication also states, “Operating at the student level, RTI is a part of MTSS and echoes the tenets of the MTSS structure.” The CDE provides information on the similarities and differences between MTSS and RtI2 as follows: MTSS incorporates many of the same components of RtI2, such as: Fiscal crisis & ManageMent assistance teaM SST/RTI2/MTSS (PRESCHOOL AND K-12) 7 • Supporting high-quality standards and research-based, culturally and linguistically relevant instruction with the belief that every student can learn including students of poverty, students with disabilities, English learners, and students from all ethnicities evident in the school and district cultures. • Integrating a data collection and assessment system, including universal screening, diagnostics and progress monitoring, to inform decisions appropriate for each tier of service delivery. • Relying on a problem-solving systems process and method to identify problems, develop interventions and, evaluate the effectiveness of the intervention in a multi-tiered system of service delivery. • Seeking and implementing appropriate research-based interventions for improving student learning. • Using school-wide and classroom research-based positive behavioral supports for achieving important social and learning outcomes. • Implementing a collaborative approach to analyze student data and working together in the intervention process. • MTSS has a broader scope than does RtI2. MTSS also includes: • Focusing on aligning the entire system of initiatives, supports, and resources. • Promoting district participation in identifying and supporting systems for alignment of resources, as well as site and grade level. • Systematically addressing support for all students, including gifted and high achievers. • Enabling a paradigm shift for providing support and setting higher expectations for all students through intentional design and redesign of integrated services and supports, rather than selection of a few components of RtI and intensive interventions. • Endorsing Universal Design for Learning instructional strategies so all students have opportunities for learning through differentiated content, processes, and product. • Integrating instructional and intervention support so that systemic changes are sustainable and based on common core state standards (CCSS) aligned classroom instruction. • Challenging all school staff to change the way in which they have traditionally worked across all school settings. • MTSS is not designed for consideration in special education placement decisions, such as specific learning disabilities. MTSS focuses on all students in education contexts. • The following figure displays similarities and differences between California’s MTSS and RtI2 processes. Both rely on RtI2’s data gathering through universal screening, data-driven decision making, problem-solving teams, and are focused on the CCSS. However, the MTSS process has a broader approach, addressing the needs of all students by aligning the entire system of initiatives, supports, and resources, and by implementing continuous improvement processes at all levels of the system. Washington Unified school district 8 SST/RTI2/MTSS (PRESCHOOL AND K-12) CA MTSS 2 RTI • Universal Screening • Addresses the needs of all students • Multiple tiers of intervention • Aligns the entire system • Data-driven decision-making of initiatives, supports and resources • Problem-solving teams • Implements continuous • Focus on CCSS improvement processes at all levels of the system Source: California Department of Education For more information and documents please refer to the California Department of Education website: http://www.cde.ca.gov/ci/cr/ri/mtsscomprti2.asp Both RtI2 and MTSS are necessary to build a comprehensive delivery system of interventions and supports for all district students. At Washington Unified, there is no formalized RtI2 or MTSS system districtwide. The SST process has board administrative procedures that were written in 1991, but do not operate consistently throughout the district. Staff report the SST process focuses primarily on the need for assessment to determine eligibility for special educa- tion. The SST process should focus on designing a support system for struggling students. The district provided a document titled, “Adopted Curriculum Interventions,” but it is not dated or identified as board-approved. It identifies interventions that could be used including Read 180, Kindergarten Intervention Kit, 1st Grade Intervention Kit, Transition and Review Guide, Level C Multisyllabic Guide, and Magic Math Stick. The team found indications of RtI in the Riverbank School and an outline of a system of Positive Behavioral Intervention Systems (PBIS) at Stonegate Elementary. The staff reported that RtI2 and MTSS are not used as formal systems, but interventions occur and are supported by the district. During the 2016-17 school year, the district made changes to the base funding for all schools, which added positions for interventions and student support based on enrollment ranges. Those positions are shown in the chart below. Schools had the discretion to create their own programs with these resources. Teachers reported that most interventions consisted of after-school tutoring Base Program Enrollment Range Positions Added FTE Intervention Specialist 1.0 Elementary 1-449 Counselor 0.5 Social Worker 0.4 Intervention Specialist 2.0 K-8 Combined Elementary and Middle Schools 1-749 Social Worker 0.4 Home School Liaison, Spanish 1.0 Home School Liaison, Russian 1.0 9-12 Comprehensive High School 1-2149 Social Worker 0.4 Certificated Librarian 1.0 Source: District document titled “Supplemental Support with Restricted Dollars” Fiscal crisis & ManageMent assistance teaM SST/RTI2/MTSS (PRESCHOOL AND K-12) 9 The district does not have consistent intervention options accessible to all students. It should consider prioritizing RtI2 and MTSS through a districtwide committee and provide intensive RtI2 and MTSS training for all staff with the training phase outlined in a strategic plan. Identification Rate The district’s 2015-16 special education identification rate of 10.2% is slightly below the 10.7% statewide average based on the March 2015 California Taskforce Report on Special Education. School Year Total Enrollment Students with IEPs Percentage 2014-15 7648 748 9.8% 2015-16 7735 791 10.2% Source: Data Quest, CALPADS During the 2016-17 school year, school psychologists assessed 53 students and only four were ineligible as disabled under IDEA. Based on this data, the referrals for special education evalua- tion are appropriate. Recommendations The district should: 1. Develop board policies and administrative regulations for preintervention supports. 2. Annually review SST procedures and update as necessary. 3. Implement SST across all sites with the Education Services Department leading and monitoring the process and procedures. 4. Provide additional SST professional development to assist with implementa- tion. Consider implementing annual refresher trainings. 5. Develop procedural guidance for preschool speech therapists providing inter- ventions before evaluating students for eligibility for special education. 6. Ensure district compliance with federal law on the need for assessment in all areas of disability when a speech and language disability is suspected. Reevaluate the practice of having 10 additional sessions of therapy in the intervention phase of speech and language services. 7. Implement and establish baseline expectations for RtI2 at all sites with the Education Services Department leading and monitoring the processes and procedures. 8. Provide intensive RtI2 training for all district staff. Consider using a vendor with expertise in RtI2 for the planning, training, and implementation phases of this model. 9. Implement MTSS at all sites with the Education Services Department leading the processes and procedures. 10. Provide intensive MTSS training for all district staff. Washington Unified school district 10 SST/RTI2/MTSS (PRESCHOOL AND K-12) Fiscal crisis & ManageMent assistance teaM 11 CONTINUUM OF SERVICES Continuum of Services The district needs to develop and then articulate a full continuum of special education services in the least restrictive environment. It does not have a written description of the available services and program options for the students it serves who require special education services. District administration reported that the district uses the Yolo County SELPA class size and staffing ratios for SELPA-wide programs document, “Procedures 6151.” This document lists the various programs offered through the SELPA and includes two to three sentences describing primarily class sizes. The programs listed are RSPs, SDCs for students ages three to 22 (with mild to moderate, moderate to severe and severe disabilities), preschool SDC for students ages three to five and an inclusion program. The district provides SDCs for preschool students and speech-only services for preschool students ages three to five, RSPs for grades K-12, SDCs for the K-12 levels, SDCs for autistic students, and a transition program for 18- to 22-year-olds. The district contracts for services when a student requires a program for emotional disturbance in a more restrictive or therapeutic environment such as through the county office or a nonpublic school. District staff expressed concern that the district lacks a program for emotionally disturbed students. The district should provide a written narrative to parents and staff describing program options. The district does not show evidence of providing co-teaching opportunities, blended learning opportunities or inclusion options. Before a blended learning model or a co-teaching model can be considered, the district should provide multiple opportunities for general educa- tion staff to develop skills through modifications and differentiation of instruction. District and SELPA staff interviewed by FCMAT expressed their opinion that the district overuses SDCs instead of utilizing a less restrictive option allowing students to learn more in the general education classes. Some students are provided with specialized academic instruction in a pullout model. Additional evidence of the measure for least restrictive environment is the “CDE Special Education Annual Performance Report Measure.” According to the 2013-14 report, students ages six through 22 receive their special education or services inside the regular education classroom for more than 80% of the school day an average 43% of the time compared to the 49.2% target expected by the state. Additionally, the 2014-15 report shows this decreased to 42.7%, although the target remained the same. The 2015-16 report was not available as of the writing of this report. Preschools operated by the state, district and the Head Start program are located on district school sites. The Special Services Department does not work in partnership with any of the other preschools to include students with special needs. As students approach the age of five, they need kindergarten readiness skills and opportunities to mainstream into regular education classrooms. The prekindergarten students do not have opportunities for exposure to typical learning environ- ments. A task force should be created to research and develop a cooperative program to support all students ages three to five in the least restrictive environment. The district should examine alternative learning environments known as co-teaching, learning centers, inclusion or collaborative models. These learning environments include special needs students in the general education environments. The district should implement these models in a systematic and informed manner to ensure they meet student needs. Some of the district’s special education students do not graduate with a diploma. Staff reports that students who receive services through RSP graduate with a diploma, but not those in SDCs. These determinations are made as early as ninth grade. A student’s graduation determination should be individualized and designed to help the student meet graduation requirements through alternative class options. The district should design alternative options for graduation. According Washington Unified school district 12 CONTINUUM OF SERVICES to the “Special Education Annual Performance Report Measure,” the graduation rate for special education students in 2014-15 was 54.72% and did not meet the state target of 69.25%. The 2015-16 report was not available as of the writing of this report; however, the district indicated it was beginning to address the graduation rate through collaborative special education and general education meetings. Staff reported that the district does not include all special education teachers when ordering curriculum and teacher resources. All teachers should be provided with equal access to district curriculum and included when considering any curriculum for students. Recommendations The district should: 1. Consider alternative learning environments such as co-teaching, learning centers, inclusion, collaborative models or a blended learning approach to increase the least restrictive environments. 2. Consider the benefits of developing a district program for emotionally disturbed students. 3. Provide a written narrative to parents and staff describing program options. 4. Offer multiple opportunities for general education staff to develop skills for modifications and differentiation of instruction. 5. Create a task force to research and develop a cooperative program to support all students who are ages three to five in the least restrictive environment. 6. Design alternative options for graduation. 7. Include all teachers equally when considering any curriculum for students. Fiscal crisis & ManageMent assistance teaM 13 SPECIAL EDUCATION TEACHER STAFFING AND CASELOADS Special Education Teacher Staffing and Caseloads The district maintains a traditional special education service model consisting of RSPs and SDCs composed of mild/moderate special day classes and moderate/severe special day classes. The district schools are designated as K-8 elementary campuses, a middle school, a comprehensive high school and a continuation high school. In addition to the K-12 system, the district operates two preschool SDCs with morning and afternoon sessions and two adult (18 to 22 years of age) transition day classes for moderate/severe services titled Transition to Adult Living. In the K-8 system, the district operates two moderate/severe classes specifically for students with autism spectrum disorder. The district also serves students with autism spectrum disorder, emotional disturbance and low-incidence disabilities such as vision impairment and deafness/hardness of hearing through services and classes provided by the county office. Students may additionally receive services from NPAs and placement in NPSs. Class size caseloads and staffing ratios for district-operated RSPs and SDCS are based on guidelines developed by the SELPA, and resource caseloads are based on the Education Code guidelines of 28 students per teacher full-time equivalent (FTE). Additionally, Article 16 of the district certificated bargaining agreement for 2015-2018 specifies that resource specialists’ caseloads will remain at or below 28 students. SDC guidelines are based on a combination of adult to student ratios and total number of students per teacher FTE. Interviews with employees and a review of district-provided records indicate district staff, including senior administration, are generally unaware of the SELPA staffing guidelines. Interviews with staff indicate resource services at the K-8 schools are provided in a generally traditional manner largely consisting of pullout and push-in services for younger students in the morning and mostly pullout “study skills” support for older students in the afternoon. In grades 9-12, resource services are primarily provided through study skills pullout classes and some push-in support in the general class setting. Services in the high school setting are further complicated by the high school operating on a block schedule, but the high school special education staff and high school administration indicate that those obstacles have been overcome, and resource services operate effectively. Interviews with K-12 instructional staff expressed their desire to add more special education services by adding more SDCs. The expressed need for more SDCs runs contrary to the current statewide emphasis on extending services for mild/moderate students in the general education setting, or least restrictive environment, commonly referred to as specialized academic instruction (SAI). Interviews with staff indicate that tracking and sharing data on special education staffing and caseloads is inconsistently documented and inconsistently shared between departments. FCMAT reviewed multiple documents maintained by the Special Services Department on staffing and caseloads as well as documents generated by district position control. All documents examined had inconsistencies with the others such as the following: • The individual names of staff members appeared in one document but not the other. • The same staff member was reported at different levels of FTE in one document compared to another. • A teacher assigned to an RSP or SDC varied between documents. Staff interviews indicated frustration with the inconsistent documentation and information at all levels of district operation. If it is necessary to add a certificated or classified staff position mid-year, the district has a process of submitting a personnel action form. However, staff inter- Washington Unified school district 14 SPECIAL EDUCATION TEACHER STAFFING AND CASELOADS views indicated that the Special Services Department typically submits a form with insufficient information for district approval. Administrative staff considering the request is unclear on the staffing guidelines or the unique circumstances that made the request necessary. It is also uncertain what steps the Special Services Department took to thoroughly consider the necessity of adding new staff. Additional information and written justification are consistently required for such requests before administrative action can be taken. The study team made a thorough effort to resolve inconsistencies using the available data, but absolute accuracy in establishing staff assignments and student caseloads was not possible. The district should perform its own internal audit to reconcile the accuracy of position control and the process for providing consistently accurate updates to all departments throughout the school year. For the information contained in this report, FCMAT utilized data provided by the district from four primary sources: Special Services Department documents, position control, the Special Education Information System (SEIS) and staff interviews. RSP caseloads are calculated on a maximum of 28 students as required by Education Code (EC) 56362(c). In the K-8 setting, the district employs 7.5 certificated FTE with one notable anomaly. It hires resource specialist services through an NPA at a cost that is $24,443 more than the average cost of a district-employed resource teacher. The individual in this role serves one district elementary school and two charter schools. One district-provided document shows this position as 1.50 FTE, reflecting a .50 FTE assignment at each of the three sites served; however, this assignment is missing from other district documents. Based on staff interviews and caseload information from SEIS, this study includes .50 FTE assignment for this position and the student caseloads that are reflected in service to the district K-8 school site. This anomaly is therefore included in the K-8 resource specialist FTE. District documents and SEIS indicate 223 K-8 students received resource services at the time of the study. This reflects an average caseload of 1-to-29.73, which is above an average maximum caseload of 28 students. The district would require an additional .46 FTE resource specialist services to staff resource services at the maximum caseload average of 28 students per EC. District-provided records indicate 5.5 FTE resource specialists serve 132 students in grades nine to 12, representing a caseload average of 1-to-24. If 9-12 caseloads were at the maximum of 28 students per FTE, the district would be overstaffed by .79 FTE at this level. The district could consider adjusting resource specialist assignments between K-8 schools and the 9-12 schools to remain within the caseload maximum throughout the K-12 system. Resource Specialist Caseloads Total Staffing FTE above Grade Span No. of FTE District Caseload Average Education Code Caseload (+) or below (-) EC K-8 7.5 223 1:29.73 1:28 (-) .46 FTE 9-12 5.5 132 1:24.00 1.28 (+).79 FTE Source: District data and Education Code Section 56362(c) The two preschool special day classes operate in tandem, offering morning and afternoon sessions daily. Staff interviews indicate the two classes operate cooperatively to offer both a mild/moderate service setting and a moderate/severe service in both morning and afternoon sessions. One class will provide moderate/severe services in the morning with a smaller class size while the other class provides mild/moderate services with a larger class size. The classes switch in the afternoon, Fiscal crisis & ManageMent assistance teaM 15 SPECIAL EDUCATION TEACHER STAFFING AND CASELOADS with the morning moderate/severe class providing mild/moderate services and the other class moderate/severe services. The design ensures that one class does not become identified as solely mild/moderate or moderate/severe. Caseloads for preschool special day classes are typically calculated on a ratio of adult per student rather than a teacher per student, allowing the FTE of teachers and paraeducators to be used in the calculation. The division into morning and after- noon sessions is also typically regarded as separate classes when calculating caseload ratio. Given the structure described above, the two special day classes have two sessions each with two teachers and 4.0 FTE paraeducators. Preschool mild/moderate services and moderate/severe services have a difference in caseload ratios. Also, when staffing preschool programs, a district will usually take into account the fact that preschool programs promote half of its students at the end of each year and begin a new year with low caseloads that will grow. At the mid-year point of this study, the table below reflects that the two preschool special day classes operate at an adult to student ratio that is below the industry standard for mild/moderate services and moderate/severe services. Preschool Special Day Class Caseloads (Mild/Moderate and Moderate/Severe combined) Total Teacher Total Industry Standard adult/ District Ratio adult/student Paraeducator FTE FTE Caseload student per session per session 1:7/session m/m 2.0 46 4.0 1:3.83/session 1:5/session m/s Source: District data and industry standards Industry standards for mild/moderate special day classes in the K-12 system are based on teacher to student ratios. The table below reflects that the K-8 mild/moderate special day classes are within the industry standard. The 9-12 mild/moderate special day classes operate with an average caseload that is slightly above industry standard. Mild/Moderate Special Day Class Caseloads Total District Caseload Staffing FTE above (+) or Grade Span No. of FTE Industry Standard Caseload Average below (-) Industry Standard K-8 7.0 91 1:13.00 1:12-15 Within Standard 9-12 3.0 50 1:16.66 1:12-15 -0.33 FTE Source: District data and industry standards Similar to the mild/moderate SDC ratio, the industry standard for moderate/severe special day classes is also based on teacher FTE compared to enrolled students. The K-8 caseload for moderate/severe SDC is within the industry standard, and the 9-12 average caseload ratio for moderate/severe SDC operates at slightly below the industry standard. Washington Unified school district 16 SPECIAL EDUCATION TEACHER STAFFING AND CASELOADS Moderate/Severe Special Day Class Caseloads Staffing FTE above (+) or below (-) Grade Span No. of FTE Total Caseload District Caseload Average Industry Standard Industry Standard K-8 3.0 32 1:10.66 1:10-12 Within Standard 9-12 1.0 13 1:13.00 1:10-12 -0.08 FTE Source: District data and industry standards Autism Spectrum Disorder Moderate/Severe Special Day Class Caseloads Total District Caseload Staffing FTE above (+) or Grade Span No. of FTE Industry Standard Caseload Average below (-) Industry Standard K-8 2.0 22 1:11.00 1:8-10 -0.20 FTE Source: District data and industry standards Recommendations The district should: 1. Immediately conduct an internal audit of certificated and classified special education service providers that can be reconciled with position control to establish an accurate staffing baseline that can be used to develop new staff tracking and planning procedures. 2. Develop consistent standards for staffing levels based on student caseloads, and ensure staffing and caseload standards are effectively communicated to district departments and appropriate staff. 3. Develop an effective, accurate and consistent tracking system for special education teacher assignments and caseload monitoring that is updated monthly by the Special Services Department. 4. Ensure that special education teacher assignment information is effectively shared and reconciled with the Human Resources and Business departments on a mutually-agreed-upon schedule. 5. Develop an administrative cabinet procedure for determining the need for all mid-year special education staff additions including certificated and classified personnel. The procedure should ensure that steps such as a comprehensive review of existing staff assignments have been conducted. It should also include direct communication between the cabinet and the director of special services that eliminates nonessential procedural steps. 6. Determine what level of staffing is required for the resource specialist position that is provided through a NPA contract, and aggressively recruit and fill that position by hiring or reassigning a district employee. Fiscal crisis & ManageMent assistance teaM 17 SPECIAL EDUCATION TEACHER STAFFING AND CASELOADS 7. Consider adjusting resource specialist assignments between K-8 schools and the 9-12 schools to remain within the resource specialist caseload maximum throughout the K-12 system. 8. Review and consider the available information on the specialized academic instruction model to provide mild/moderate special education as contained in sources such as, “One System: Reforming Education to Serve ALL Students” the Report of California’s Statewide Task Force on Special Education. The goal should be to make a determination on the possible revision of the district’s model of service to students with mild/moderate special education needs to a less restrictive environment. 9. Provide consistent effective professional development to certificated special education and general education staff to promote best practices in service delivery especially in the area of differentiated instruction and least restrictive environment. Washington Unified school district 18 SPECIAL EDUCATION TEACHER STAFFING AND CASELOADS Fiscal crisis & ManageMent assistance teaM 19 PARAEDUCATOR STAFFING Paraeducator Staffing Based on staff interviews and document reviews, the district employs instructional assistants in three categories: paraeducator II-special ED, paraeducator specialist SH and paraeducator specialist TAL. The paraeducator II is assigned to both the RSP and mild/moderate SDCs, and the paraeducator specialist SH is assigned to mild/moderate special day classes and moderate/ severe special day classes. The paraeducator TAL is assigned only to the Transition to Adult Living SDCs. All paraeducators who are hired for 1-to-1 assignments are hired as paraeducator SH, which has bathroom assistance included in its job description. All paraeducators in the district except for the TAL position are hired at .75 FTE. To simplify the table below all paraeducators hired at the .75 FTE are reflected as one FTE. The district provided the FCMAT team with an average cost including salary and benefits for all three paraeducator positions. • Paraeducator II - $24,316.40 • Paraeducator SH - $24,896.71 • Paraeducator TAL - $37,065.84 A review of district-provided records found that the tracking documents maintained by the Special Services Department and the position control documents maintained by the district are inconsistent. During staff interviews, it became apparent that some paraeducators do not perform the assignments identified in district-provided documents. Staff interviews indicate that the district lacks an effective system to consistently share current Special Services Department information with other departments. As mentioned previously, it also lacks procedures and docu- mentation to verify a midyear request to the cabinet for additional classified paraeducator staff. Paraeducators also do not receive any formal job orientation at the point of hire and ongoing professional development, according to staff interviews. Many staff members are concerned about the shortage of substitute paraeducators that occurs when a paraeducator is absent from his or her regular assignment. Interviews indicated the options in such cases are limited primarily because of an ongoing shortage of paraeducators on the substitute list. This shortage is exacerbated by the tendency of the district to hire from the depleted substitute pool when a paraeducator vacancy must be filled. If no substitute is available, one of the following occurs: • The school site staff where the paraeducator is assigned operates without a replacement. • If the absence is for a critical support position, an existing paraeducator in another assignment is redirected to fill in. Based on staff interviews and review of district-provided documents, the table below shows that the district is staffing both mild/moderate services and moderate/severe with a level of paraeducator support that is well above the industry standard. Excluding 1-to-1 paraeducators, the district employs a paraeducator support staff of 49 employees in all three categories. Using industry standards for resource services, mild/moderate SDC and moderate/severe SDC, 14 of the 49 paraeducators are above-average staffing level for those services. Conservatively calcu- lating the additional cost of the 14 paraeducators at the average salary for paraeducator II of $24,316.40, the excess cost is $340,429.60. Washington Unified school district 20 PARAEDUCATOR STAFFING Paraeducators (excluding 1-to-1 paraeducator support) Para. FTE Total Teacher Total District Para. Industry Standard Program (+) Over/(-) Under FTE (K-12) FTE (FTE = 0.75) Total Para. FTE Industry Standard Resource Specialist 13.0 FTE 17.0 FTE 13.0 FTE + 4.0 FTE Mild/Moderate Special Day 10.0 FTE 18.0 FTE 10.0 FTE + 8.0 FTE Class Moderate/Severe Special Day 6.0 FTE 14.0 FTE 12.0 FTE + 2.0 FTE Class Total Para. FTE 49.0 FTE 35.0 FTE + 14.0 FTE Source: District data and industry standards A review of district-provided documents indicate that 1-to-1 paraeducator staffing also affects district spending for paraeducators as a whole. The industry has no standard for 1-to-1 paraedu- cator staffing because all 1-to-1 assistants are considered over and above traditional paraeducator staffing. Virtually all districts have some 1-to-1 paraeducators, but the numbers vary so widely from district to district, there is little basis for establishing an average or standard. Based on district-provided records, it has a total of 7 FTE 1-to-1 paraeducators for a cost of $174,276.97 calculated at the paraeducator SH rate of $24,896.71. Interviews with the Special Services Department administration indicated that the district inconsistently utilizes the SELPA special circumstances instructional assistant (SCIA) assessment process. In fact, staff provided various opinions on which staff should be responsible for completing a SCIA assessment. The district lacks clear procedures for using the SCIA process. Further, once it determines that a student requires 1-to-1 assistance, a fade plan or goals for reaching independence from the additional assistance are not developed in the IEP or reviewed and revised annually. Staff interviews indicate that when the possible need arises for adding a 1-to-1 paraeducator through the SCIA and IEP process, the Special Services Department considers adding paraedu- cator support to the classroom staff instead of creating a 1-to-1 assignment for a specific student. In this instance, the additional staff support is included in a student’s IEP as an accommodation. This practice is not uncommon among districts and has the advantage of providing the district with more flexibility in meeting student needs. However, the district still bears the additional cost of adding the position, and an internal procedure for evaluating the need and justification of the staff addition similar to the SCIA process must be implemented (see recommendation #5 in previous section on Teacher Staffing). The overall cost of special education paraeducator support above the industry standards in mild/moderate services, moderate/severe services and assigned 1-to-1 paraeducator support in the district is estimated at $514,706.57. Recommendations The district should: 1. Develop an effective, accurate and consistent tracking system for special education paraeducator assignments that is updated monthly. 2. Ensure that special education paraeducator assignment information is effectively shared and reconciled with the Human Resources and Business departments on a mutually-agreed-upon schedule. Fiscal crisis & ManageMent assistance teaM 21 PARAEDUCATOR STAFFING 3. Provide special education paraeducators with consistent effective professional development to promote best practices in service delivery. 4. Develop procedures to consistently implement SELPA SCIA support when determining the need for the assignment of a 1-to-1 paraeducator. This process should ensure that a formal assessment is conducted and clearly estab- lish which staff position is responsible for implementing the procedure. 5. Develop a policy on including goals for independence, or fade plan, in the IEP of every student who receives 1-to-1 instructional support as a related service. These goals must be reviewed and revised annually until the IEP team determines the related service is no longer required. 6. Evaluate current paraeducator levels of support and consider reducing staff if applicable. Washington Unified school district 22 PARAEDUCATOR STAFFING Fiscal crisis & ManageMent assistance teaM 23 RELATED SERVICE PROVIDER STAFFING AND CASELOADS Related Service Provider Staffing and Caseloads Related services are the developmental, corrective and other supportive services required to allow a disabled child to benefit from special education (34 CFR 300.34). These services are written in the IEP and include but are not limited to speech pathology, psychological services, physical and occupational therapy, counseling, school health and nursing services. As mentioned earlier in the report, the district relies on the Special Services Department to help determine staffing needs for the various special education programs it operates. The department informs the Human Resources Department of staffing needs for the next year, provides justifi- cation and increases are provided. The Special Services Department has no regularly scheduled meetings with the other departments. Communication between the Special Services, Business and Human Resources departments is critical throughout the school year to help make informed decisions on staffing. The staff interviewed indicated there are many obstacles in tracking staff and their service locations throughout the district. The Special Services Department provided several documents with information such as staffing names, locations, caseloads, positions and numbers, but they included a number of inconsistencies. The findings reported in this study for related services and student caseloads should be regarded as tentative. The data provided must be subject to a rigorous analysis directly involving the Special Services, Business and Human Resources departments. The study team made a thorough effort to resolve inconsistencies using the available data, but absolute accuracy in establishing related service provider staffing and student caseloads was not possible. The report will reflect calculations based on the various docu- ments provided. Psychologists The district employs seven FTE psychologists, three credentialed and hired by the district and two district-hired interns placed on the psychologist’s salary schedule. However, the other two are hired through a contracting agency at a cost that exceeds the salary of a district-hired psychol- ogist. Most psychologists are assigned to school sites and support the students and programs located there. They perform the duties common to school psychologists, consisting primarily of performing initial assessments for special education eligibility, writing reports, participating in IEP team meetings and completing triennial evaluations. The district has one FTE psychologist assigned to the preschool program. The comparison for psychologist staffing is based on the K-12 assignments. Because the state has no comparison for school psychology staffing in the preschool setting, the 1.0 FTE preschool psychologist is removed from the K-12 comparison. The district also chooses to use some psychologists in assignments outside of the duties common to the position such as counseling. Although a district Marriage and Family Therapist (MFT) provides services for educationally related mental health services (ERMHS) , some psychologists also support students with guidance and counseling. Using the statewide caseload average for K-12 school psychologists of 1,321 provided by KidsData.org, the district is appropriately staffed in psychologists through the use of interns and independent contractors. A review of the district document, which is untitled but has a revision date of 1/19/2017 9:18 p.m. and marked with the letters “L/B,” indicates district psychologists earn an average of $78,675. If the intern salaries are removed, the psychologist’s average salary is $94,636 including salaries and benefits. The NPA charges $130,000 $152,800 per psychologist for 180 days of service. The district should consider ways to attract school psychologists or more interns to the district to reduce the number of private contractors. Washington Unified school district 24 RELATED SERVICE PROVIDER STAFFING AND CASELOADS Psychologist Caseloads Program No. of FTE Enrollment Industry Standard District Caseload Average Psychologist 6 7,735 1:1,321 1:1,289 Source: District data and kidsdata.org Staff reported the district lacks a consistent process and procedure for referring a struggling student for special education assessment. They also report an increase in special education assessments because of the number of parents who are concerned about their child’s grades and progress. Some principals indicated they have instructed the psychologists to immediately begin the assessment process when this happens. However, the best practice is for the district to hold an SST meeting at the school site that involves general education teachers, the principal, psychol- ogist, parent and any other members who are knowledgeable of the student to discuss interven- tions provided within the general education environment. Before eligibility for special education can be considered, the district should first determine if there is data to determine it meets 5 CCR §3030 Eligibility Criteria, which states the following: To ensure that underachievement in a pupil suspected of having a specific learning disability is not due to lack of appropriate instruction in reading or math, the group making the decision must consider: (i) Data that demonstrate that prior to, or as a part of, the referral process, the pupil was provided appropriate instruction in regular education settings, delivered by qualified personnel; and (ii) Data-based documentation of repeated assessments of achievement at reasonable intervals, reflecting formal assess- ment of student progress during instruction, which was provided to the pupil’s parents. The district should consider a consistent process and procedure for formalizing the parent request for assessments. Speech and Language Pathologists To help determine the number of speech and language pathologists (SLP) FTE and caseloads, the study team reviewed documents provided such as caseloads reported in SEIS, NPA listing, staffing list and interviews of district personnel and NPAs. It found inconsistencies in the reporting of speech and language personnel and caseloads. FCMAT reached a conclusion that best describes assignments and caseloads, although these numbers should be viewed with caution. EC 56441.7(a) establishes a maximum caseload of 40 students for preschool. District-provided documents indicate 1.9 FTE SLPs provide preschool support and services to 73 students. The district’s preschool caseload for SLP is 1-to-38 per FTE. The preschool SLPs do not provide Response to Intervention (RtI) supports to preschoolers, and no preschool students are in consul- tation only, therefore the data reflect direct-service provisions. The K-12 speech pathologists provide some early intervention supports known as RtI, for students in addition to their special education caseloads. Staff indicated that the special services director considers this general education support when SLPs are assigned, but there is no formal process for determining assignments. The district has 353 students receiving K-12 speech and language services, but FCMAT was unable to determine the number of SLPs serving this popu- lation. EC 56363.3 establishes a maximum caseload of 55 students for K-12. If the district were to consider only EC caseload requirements and not the SLPs’ other duties assigned such as RtI, it would require 6.4 FTE. The district should use this information to determine the FTEs needed through the NPAs and contract for up to 6.4 FTE. Fiscal crisis & ManageMent assistance teaM 25 RELATED SERVICE PROVIDER STAFFING AND CASELOADS Documents and interviews indicate the district hires speech and language pathologist assistants (SLPAs) through an NPA for 30 hours per week. SLPAs cannot relieve SLPs from caseload assignments, but can assist with direct and consultative services to students. The private contracted SLPA annual rate is $83,520.00. The district reportedly has open speech and language pathology positions that it has been unable to fill, even through NPAs. However, the SELPA reported some NPAs have SLPs that can provide these services. FCMAT inquired about virtual learning with specialized speech and language companies certified by CDE. The district has briefly tried this method. FCMAT and the SELPA encouraged the district to work with agencies to systematically develop telecommuni- cation services for a specific group of students who can access learning through an online source. This effort should be well planned, and meetings conducted to educate parents as well as staff on the multiple benefits of this approach. Students are assessed by district speech pathologists as well as the contracted service providers. It may be considered a conflict of interest for the contracted agency to assess students it could serve. The district should consider assigning a district employee to assess all speech-referred students. Speech and Language Pathologist Caseloads District Caseload Program No. of FTE Caseload Education Code Average Speech and Language Pathologist – 1.9 73 1:38 1:40 preschool Speech and Language Pathologist undetermined 353 undetermined 1:55 – K-22 Source: District data and Education Code Sections 56441.7(a) and 56363.3 Occupational Therapy For many years, the district has contracted for occupational therapy (OT) services at a cost of $200,000 per year. These services are performed by a 1.6 FTE OT and 1.0 FTE certified occu- pational therapy assistant (COTA). A COTA can provide direct services to students according to the IEP, but is not allowed to assume caseload management, IEP implementation or progress reporting. The COTA works under the direction of the OT. Because the full-time OT was on leave for some time, the .6 FTE OT and a substitute OT assisted with her caseload within the same NPA. The COTA serves approximately 42 students directly, and an additional 10 students are on consultation. The OTs reported serving an additional 81 students, including 15-16 students who are on consultation. The OTs also provide preschool assessments and observation of a student upon request. The occupational therapists report that the caseloads are manageable. As a comparison, the industry standards are 1-to-45-55 students for OTs without the use of a COTA. Because the district utilizes a COTA to support direct services, it operates within industry standard. Contracts are reportedly rolled over from year to year. However, in some instances, the NPA requested to increase OT services before the end of the year through a request to the special services director that was quickly approved. Interviews with district staff indicated the district has no formal process to approve or increase contracts for related services. Those outside of the Special Services Department were unaware of increases throughout the year. Washington Unified school district 26 RELATED SERVICE PROVIDER STAFFING AND CASELOADS Although OTs bill for Medi-Cal, they only bill for assessments and not direct therapy. The district could increase its revenue if they billed for the latter service as well. Occupational Therapist Caseloads District Caseload Industry Program No. of FTE Caseload Average Standards Occupational Therapist 2.6 (including COTA) 133 1:51 1:45-55 Source: District data and industry standards Nurses and Health Aides The district provides three credentialed school nurses, eight health aides and one health clerk. The health aides are new to the district and support all students at each school site. The district provides health aides at school sites to assist with everyday injuries and monitor allergies and diabetes. Some districts have developed protocols to train and implement site staff to provide specialized health care. Some districts have moved to providing a lead credentialed nurse(s) to oversee health aides, providing services while remaining cost effective. According to Kidsdata. org, the industry standard is 1-to-2,784 students. The district employs 3 FTE credentialed school nurses, which is within the industry standards. Nurse Caseloads District Caseload Program No. of FTE Enrollment Industry Standard Average Credentialed School Nurses 3 7,735 1:2,578 1:2,784 Source: District data and kidsdata.org Other Related Services The county office provides related services to the district through an agreed-upon allocation plan set within the SELPA. These include adapted physical education, vision, orientation and mobility services, assistive technology, and services for the deaf/hard of hearing. The district should ensure it reviews the cost of these related services and determine if it can provide them more cost effi- ciently. The district also contracts with an NPA for physical therapy services as needed. There is no process or procedure to determine how to access this provider for assessment or when this type of service might be needed as a result of an assessment. The district should consider developing such a procedure. Fiscal crisis & ManageMent assistance teaM 27 RELATED SERVICE PROVIDER STAFFING AND CASELOADS Recommendations The district should: 1. Review and discuss all staffing allocations and caseloads monthly with the Special Services Business and Human Resources departments. At these meet- ings, discuss any need for increasing or decreasing staff to meet the needs of special education students. 2. Develop and utilize one consistent document between all departments for tracking personnel positions, locations, FTE and caseloads including a consis- tent related services NPA spreadsheet. 3. Consider the options for recruiting positions, such as a school psychologist or intern, to reduce reliance on contracted services at a higher rate. 4. Develop a consistent process and procedure for formalizing the parent request for assessments. 5. Determine the number of FTE speech and language pathologists, both district-hired and contracted through NPAs, and staff up to the EC require- ments. 6. Consider assigning a district speech pathologist to assess all speech referred students. 7. Consider developing a written guideline for determination of assignments for SLPs. 8. Research, contract and implement a telecommunications practice for speech and language services. 9. Implement a formal approval process when determining the need for an increase or decrease in staffing or NPA related services contracts. 10. Review the cost of county provided related services and determine if the district can provide these services more cost efficiently. 11. Research and consider billing Medi-Cal LEA for OT direct services. Washington Unified school district 28 RELATED SERVICE PROVIDER STAFFING AND CASELOADS Fiscal crisis & ManageMent assistance teaM 29 ORGANIZATIONAL STRUCTURE Organizational Structure FCMAT compared the Special Services Department’s administrative and clerical support staffing with that of three unified school districts chosen because of comparable size: Azusa, Davis Joint and Snowline Joint. Comparable size was determined by similar enrollment and demographics as well as the number of disabled students by district of residence. Data for the comparison was taken from CALPADS completed enrollment figures for 2015-16 and Dataquest special educa- tion enrollment figures for 2015-16, which is the most recent and available posting. The total number of special education students from birth to age 22 was reported by district of residence. Although comparative information is useful, it should not be considered the only measure of appropriate staffing levels. School districts are complex and vary widely in demographics and resources. Careful evaluation is recommended because generalizations can be misleading if unique district circumstances are not taken into account. Special Education Identification Rate for District Enrollment Enrollment Special Education Azusa Unified 8900 1206 13.5% Davis Joint Unified 8562 928 10.8% Snowline Joint Unified 7798 1061 13.6% Washington Unified 7735 791 10.2% Source: CALPADS enrollment 2015-16; Data Quest Special Education Enrollment 2015-16 The districts provided information on both administrative and clerical support staffing. Each district identifies positions differently. FCMAT reviewed available job descriptions for adminis- trative and clerical positions and combined some categories into similar groups for purposes of this study. Administrative Position Azusa Davis Joint Snowline Joint Washington Director 1 FTE 1 FTE 1 FTE 1 FTE Coordinators 2 FTE Program Specialist 1 FTE 1 FTE 1 FTE 1 FTE Behavior Specialist/ 1.6 FTE Program Specialist Total 4.0 FTE 2.0 FTE 2.0 FTE 3.6 FTE Source: District documents and interviews. The average number of administrators in comparable size districts is 2.7 FTE, and the district has 3.6 FTE; however, the district’s behavior specialists divide their time between program specialist and behavior specialist duties. If the behavior specialist time is removed, the district is similar to the comparable-size districts. The behavior specialists and program specialists are both teachers on special assignment. Staff reported that the cabinet approved 1.6 FTE behavior specialists a few years ago, because of the needs for a behavioral support to meet the students’ social emotional needs. A job description was created but not board-approved because of a change in district procedure. The Washington Unified school district 30 ORGANIZATIONAL STRUCTURE job description outlines the specific duties of behavior specialists, but there are no specific school assignments or schedules for this position for either behavior specialist. The average clerical support positions in Azusa and Davis Joint were 1.5 FTE. Snowline Joint did not respond with this information. The district has 2 FTE which is overstaffed by 0.5 FTE; however, the department could have unique health-services responsibilities that the district should review. Clerical Positions Azusa Davis Joint Snowline Joint Washington Administrative Secretary 1 FTE 1 FTE No response 1 FTE Secretary 1 FTE No response Health Clerk 1 FTE Total 1 FTE 2 FTE No response 2 FTE Source: District documents and interviews Functionality of the Department Interviews with staff indicated that the department is perceived to be reactive rather than proac- tive. School site staff reported that communication from the administration is inconsistent, with mixed directives from agreements made at the district level. One example is classes that were reassigned to a new school site without contacting the principal until two days before the start of school. Interviewees consistently reported a lack of responsiveness to emails and phone calls from the special services administration. Meetings for administrative special services staff are often cancelled, which affects overall effi- ciency. The director is involved in a high percentage of IEP meetings, impeding this position’s ability to provide department leadership and effectively communicate with all school sites and department staff. At the time of the study, the district was behind in providing speech therapy for 69 students at Riverbank. IEPs are overdue and services were not provided for most of the year. The administra- tion has an obligation to ensure that all services required under federal law are provided and all IEPs are current. Upon learning of this issue during the study, district administration immedi- ately began working with the SELPA to address the lack of services. Recommendations The district should: 1. Clarify the function of the behavior specialists who are used as program specialists, and establish clear job responsibilities and assignments. 2. Set standards of practice for effective communication with the Special Services Department that are implemented and monitored to ensure that the administration delivers the same message and is consistent with directives. Fiscal crisis & ManageMent assistance teaM 31 ORGANIZATIONAL STRUCTURE 3. Establish operating guidelines that require responses to all calls and email within one business day. If an answer is not immediately available, ensure that the Special Services Department staff informs the person about when he or she will receive a response and provide ongoing updates until the issue is resolved. 4. Ensure that Special Services Department meetings occur as scheduled. 5. Provide training and support to principals and program specialists to ensure that IEP meeting leadership is available and authorized to make decisions at the IEP meeting, reducing the need for the director’s presence in these meetings. 6. Assign special education leadership to build solid relationships with principals through attendance at district principal meetings and school site visitations, addressing the concerns of principals in a collaborative manner. 7. Increase communication by initiating a plan to consider principals first in any planning having direct impact on a school site. 8. Ensure that compensatory services in speech and language are provided for students at Riverbank who were not served for a portion of the 2016-17 school year. Washington Unified school district 32 ORGANIZATIONAL STRUCTURE Fiscal crisis & ManageMent assistance teaM 33 CONTRACTED SERVICES Contracted Services The district uses three types of placement options/services to meet the unique needs of students with disabilities when district programs and services are not available: NPSs, NPAs and the county office. However, it has no written process to guide IEP teams in making placement deci- sions involving the use of these entities. Instead, the practice is to contact a program specialist or the director for assistance. The district would realize greater efficiencies with a written process to guide IEP teams and training for all applicable staff in using and accessing these services. The county office provides intensive services for 661 students with severe disabilities (infants through adult) throughout the Yolo County SELPA. These include SDCs, itinerant services for the visually impaired including orientation and mobility, services for the deaf/hard of hearing and assistive technology. The total cost is estimated at $4,854,292 which is taken from the total amount of the SELPA allotment before any SELPA distribution of funds, known as an “off the top” allocation. There is an additional fee for service of $134,158 for the county to serve 65 infants. The district has 38 students in an SDC and 17 students with low-incidence disabilities receiving services through the county office. In addition, 27 students receive mental health services through the county office. The students in these classes and/or related services require intensive services not available in the district. The costs of intensive services should be reviewed annually to ensure efficiency inside and outside the district. Nonpublic Schools EC 56034 defines a nonpublic school (NPS) as follows: …a private, nonsectarian school that enrolls individuals with exceptional needs pursuant to an individualized education program and is certified by the department. It does not include an organization or agency that operates as a public agency, … an affiliate of a state or local agency, including a private, nonprofit corporation established or operated by a state or local agency, or a public university or college. A nonpublic, nonsectarian school also shall meet standards as prescribed by the Superintendent and board. An NPS is an option in the continuum of service for disabled students. Students are placed in an NPS when their unique needs outlined in an IEP require specialized programs that are unavailable in the district. The district negotiates NPS contracts and develops individual service agreements for the students served. The district has not established firm proce- dures for referrals to nonpublic schools. District Nonpublic Schools Costs Total School Year Annual Costs Number of Students 2014-15 $522,205.94 30 2015-16 $620,976.68 27 2016-17 $648,672.00 21 Washington Unified school district 34 CONTRACTED SERVICES The Yolo SELPA maintains a pool for district reimbursements for students who require placement in an NPS. For example, in 2015-16 the district’s annual cost was $620,976.68 and it received an allotment to cover these costs. Nonpublic Agency NPA Education Code requirements are the same as for NPS. Education Code 56365(a) requires an NPA to be the following: …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. The district uses independent contractors when specific expertise is needed but not available. WUSD Nonpublic Agencies Costs School Year Annual Costs 2014-15 $1,148,913 2015-16 $1,580,707 2016-17 $1,455,787 Source: Special Education documents 2014-2017 The NPA cost is a significant expenditure for special education and has remained relatively constant throughout the last three years. The three main expenditures for each of the three years are for staffing speech and language services, occupational therapy and sign language services. This is because of the district’s difficulty in hiring certified staff in these areas. The district is actively recruiting staff in these areas. Because of the national shortage of speech therapists, many districts have had to offer stipends and incentives to encourage applicants for district positions or rely on alternative ways to provide those services, such as telecommunication. Educationally Related Mental Health On June 30, 2011 Assembly Bill 114, Chapter 43, Statutes of 2011 was signed into law. Under AB 114, several sections of Chapter 26.5 of the California Government Code were amended or rendered inoperative, ending the state mandate on county mental health agencies to provide educationally related mental health services to disabled students. The law indicates that local education agencies are solely responsible for ensuring disabled students receive mental health and related services. The Yolo County SELPA has policy #5050 outlining how ERMH services are provided. The district provides these services, and the SELPA reimburses for them. During the 2015-16 school year, the district received $100,000 for a psychologist and $230,188 for the remaining mental health services. For a costly residential placement student, the district can request support through the SELPA’s NPS pool reimbursement system. Fiscal crisis & ManageMent assistance teaM 35 CONTRACTED SERVICES Recommendations The district should: 1. Develop a written process to provide guidance to the IEP team in making decisions for placement in an outside program such as NPA, NPS or county office services. 2. Evaluate the efficiency of all programs provided outside the district and build capacity to provide in the district when it is feasible. Explore all options such as the availability of facilities in the district and the feasibility of hiring certified staff. 3. Continue to utilize nonpublic schools as an option on the continuum of service for disabled students and access the NPS pool at the SELPA for reim- bursement. 4. Recruit speech therapists to staff open unfilled positions and consider incen- tives to encourage employment in the district. Consider alternative service delivery, such as telecommunication, when appropriate. 5. Consider creating a district occupational therapy position to decrease depen- dence on costly nonpublic agency services. 6. Analyze the need for sign language interpreters and create options for employ- ment within the district, if possible. This is a costly NPA service that can be provided in the district with the appropriate staff. Washington Unified school district 36 CONTRACTED SERVICES Fiscal crisis & ManageMent assistance teaM 3377 APPENDDRICAEFST Appendix A: Study Agreement Washington Unified school district 3388 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 3399 APPENDDRICAEFST Appendix A – Study Agreement Washington Unified school district 4400 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4411 APPENDDRICAEFST Washington Unified school district 4422 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 4433 APPENDDRICAEFST Washington Unified school district