Evaluating Special Education in Challenging Financial Times

1. Evaluating Special Educationin Challenging Financial Times January 2010 Ideas from Kent ISD and Local Special Education Administrators

2. PART 1:Kent ISD’s History of Special Education Cost Containment and Revenue Enhancement

3. Efforts Led By Superintendents and/or Business Officials

4. History of Special EdCost Containment in Kent ISD – 1 • Pre-1992 – Kent Intermediate Superintendents’ Association (KISA) established “caps” for special education administrators and ancillary staff allowed for Act 18 reimbursement. • 1992-93 – Special Education Task Force formed to study rising costs of special education.

5. History of Special EdCost Containment in Kent ISD – 2 • 1993 – KISA approved changes to distribution methodology for Act 18 and federal funds to ensure equity and discourage “overspending.”

6. History of Special EdCost Containment in Kent ISD – 3 • 1998-1999 – Special Education Finance committee studied new methods of distributing Act 18 funds that were equitable to districts and did not provide reimbursement based on costs (which could reward “overspending”). • 2000 – KISA adopted new Act 18 Reimbursement methodology based on total student population with a weighting factor for students who qualified for free/reduced lunch.

7. History of Special Ed Revenue Enhancement in Kent ISD – 4 • 2002-03 – Kent ISD began to contract for special education transportation for Region 3 which increased transportation reimbursement. • 2003-04 – Kent ISD began to provide special education transportation for Regions 1 and 2. • 2004-05 – Kent ISD began to contract for special education transportation for Region 4 (GRPS) and employed ancillary (itinerant) staff from locals.

8. History of Special EdCost Containment in Kent ISD – 5 • 2008-09 – Kent ISD and locals engaged in study of special education transportation costs to try to lower rates of increases in future years. • 2009-10 – Kent ISD hired temporary special education transportation consultant to work with Dean to increase efficiencies.

9. Efforts Led By Special Education Administrators

10. History of Special EdCost Containment in Kent ISD – 6 • 1996 – Kent ISD Special Ed Department worked with LEAs and PASE to apply for first waivers from special education rules (increased EMI, LD, and departmentalized caseloads, reduced unneeded evaluations). • 1996-2004 – More waivers sought and approved (including increased numbers in autism classrooms from 5 to average of 7 students and reducing SXI/SCI programs from 230 to 217 days).

11. History of Special EdCost Containment in Kent ISD – 7 • 1999– Kent ISD and locals developed LD Eligibility guidelines to ensure appropriate eligibility. (2001–6,082; 2009–5,087) 16% • 2003– Kent ISD and locals developed EI Eligibility guidelines to ensure appropriate eligibility. (2001–1,865; 2009–1,097) 41%

12. History of Special EdCost Containment in Kent ISD – 8 • 2004 – Kent ISD Special Ed Department worked with LEAs and PASE to incorporate waiver language and other new efficiencies into Special Education Plan (IEP Addendum, Home Community pro-ration). • 2009 – Additional waiver language incorporated into Special Education Plan (including pro-ration of ECSE hours and aligning SXI and SCI to 200-day minimum rule).

13. History of Special EdCost Containment in Kent ISD – 9 • 2005 – Kent ISD and locals developed ASD Eligibility guidelines to ensure appropriate eligibility. (2001–378; 2009–698) 85%Note: Kent ISD’s growth in ASD is considerably slower than neighboring ISDs and state: Allegan 128%; Genesee 289%; Ionia 184%; Macomb 241%; Oakland 162%; Ottawa 161%; State increase in ASD from 2001-09 was 160% • 2009 – Kent ISD and locals developed SLI Eligibility guidelines to ensure appropriate eligibility. 6% drop in past year. (2001–3,725; 2009–3,917) 5%

14. History of Special EdCost Containment in Kent ISD – 10 • 2001-2009– Districts within Kent ISD reduced percentage of students who qualified for special education in total population from 16.26% to 14.43%. • 2007-08 – Kent ISD began implementation of two RtI pilot projects aimed at reducing referrals to special education in areas of reading and behavior. 8 schools in the 95% Group pilot reduced referrals by 63% and identification of SWD by 59% in just 2 years.

15. History of Special EdCost Containment and Revenue Enhancement in Kent ISD – 11 • 2009-10 – Kent ISD implemented its own Medicaid billing system to reduce vendor costs and increase reimbursement to locals.

16. PART 2:Cost Containment Considerations from Special Education Administrators

17. How do we determine if we can make budget cuts in special education?

18. Steps to Evaluate Revenuesand Expenses – 1 • Review active caseloads (verified by attendance records) in all programs to see if staffing could be reduced. • Where applicable, review eligibility guidelines and recommended entrance criteria for various programs to avoid over-identification and ensure LRE. (Particular area of focus: OHI)

19. Steps to Evaluate Revenuesand Expenses – 2 • Review all non-mandated paraprofessional positions to see if a free appropriate public education (FAPE) can be provided if positions were eliminated. • Review all paraprofessional positions to see if hours and/or benefits could be reduced to save costs while still meeting mandates.

20. Steps to Evaluate Revenuesand Expenses – 3 • Gather data from similar districts (or programs) on special education pupil expenditures (by type of program). • Gather data on number of ancillary staff of various types. • Review schedules and assignments of special education ancillary staff to maximize efficiency and minimize mileage costs.

21. Steps to Evaluate Revenuesand Expenses – 4 • List all functions of staff then determine whether each function is essential or nonessential. • Review whether each “nonessential” function reduces special education referrals and eligibility, which reduces costs for long term. • Evaluate whether nonessential functions could be reduced to allow administrative, related service, or other positions to be shared between districts.

22. Steps to Evaluate Revenuesand Expenses – 5 • Study MI-CIS local special education data portrait and compare to similar districts for potential places to reduce. • Solicit ideas and input from staff. • Solicit ideas and input from parents.

23. Short-Term Possibilities

24. How Could WeReduce Costs Next Year? – 1 • Reduce teaching staff where classroom numbers are considerably lower than comparable programs or districts (within caseload and IEP limits). • Reduce ancillary staff positions where staff numbers are considerably higher than found in comparable programs or districts. • Consider contracting for services instead of hiring employees, as allowed by bargaining agreements.

25. How Could WeReduce Costs Next Year? – 2 • Consider more centralization of staff – Could some positions be shared in regions or throughout ISD? Example: Could we have fewer special education directors if all were employed at ISD and assigned to local districts? • Use set aside funds to replace lights at center program facilities to attain high efficiency and auto-turn off when staff leave rooms.

26. How Could WeReduce Costs Next Year? – 3 • Review different categories of paraprofessional positions to see if new hires could be classified at lower level to reduce costs. • As an alternative to special education classroom placement or one-to-one paraprofessional support, cluster small groups of special education students in general education classrooms with one para who is shared for support. • Consider contracting for services instead of hiring employees, as allowed by bargaining agreements.

27. How Could WeReduce Costs Next Year? – 4 • Increase general education on-line options for special education students that could help reduce need for special education. • Search for savings in special education transportation. • Continue to invest in Response to Intervention approaches since data confirms RtI reduces both referrals and placements into special education.

28. Long-Term Possibilities

29. Potential Long-Term Cost Savings – 1 • Prevent students from requiring special education (whenever possible) since this saves districts the most money in the long-run. • Continue to invest in early childhood programming since both general and special education early childhood programs reduce the number of children who require special education later.

30. Potential Long-Term Cost Savings – 2 • When ARRA funds run out, seriously consider using 15% of federal funds for early intervening services as a way to reduce special education rates on the long-term. • Consider changing Part 6 of Michigan’s Special Education rules to allow Act 18 funds to be spent on early intervening services. • Evaluate all Michigan rules that go beyond federal mandates and consider their elimination.

31. Potential Long-Term Cost Savings – 3 • Require principals to go through IEP and special education policy training to prevent costly complaint and due process proceedings and to ensure decisions are made in a cost-effective manner. • Work with state/federal legislators to scale back mandates, especially those that require staff time and paperwork without direct benefit to students.

32. Potential Long-Term Cost Savings – 4 • Support state legislation to shift responsibility (and funding) from Department of Education to Department of Community Health (DCH) for young adults with disabilities ages 22 through 26. DCH can’t do this on current funding, but could serve population for less cost than schools.

33. Decision Points

34. Ensuring Prudent Decisions – 1 • Before making reductions, ensure compliance with federal regulations, state rules, ISD Plan, and individual provisions in students’ IEPs. • Instead of reducing or eliminating a “nonessential” special education position, consider whether position might assist overall building or district by helping to reduce referrals and placements into special education. It is permissive for general education students to receive “incidental benefit” from special education staff.

35. Ensuring Prudent Decisions – 2 • Ask whether a change in funding source for a position might be preferable to a reduction: For example, paying for a speech pathologist partly out of general education (or IDEA early intervening) funds could allow them to serve an overall higher number of students than 60, which could reduce overall need for more speech pathologists in the future.

36. Ensuring Prudent Decisions – 3 • Before making reductions in special education, make sure district calculates whether proposed cuts will negatively impact revenue sources: • Calculate Maintenance of Effortto ensure district does not have to pay back federal IDEA funds. • Consider impact of potential reductions on Act 18 reimbursement.

37. Ensuring Prudent Decisions – 4 • Strong special education leadershiphas been demonstrated to be a key ingredient in cost containment. Cost containment is achieved by: • Monitoring local caseloads, policies, procedures, finances, and IEPs to ensure compliance and maximize efficiency; • Generating creative solutions to service delivery;

38. Ensuring Prudent Decisions – 5 Strong special education leaders cost contain by: • Providing training to staff about IEP processes and appropriate responses to parent requests; and • Responding promptly to potential disputes before they escalate into due process hearings or formal complaints likely to result in costly proceedings.

39. Discussion/Next Steps

40. Guiding Questions for Groups • What information presented today is most pertinent to your current decision-making on special education budget issues? • What area(s) do you need to evaluate most carefully to ensure prudent decisions related to special education cost containment? • Are there short or long-term solutions you’d like help with from Kent ISD?