Special Education Department Audit
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Special Education Department Audit

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Special Education Department Audit For School District U-46 Prepared by Rebecca K. Fries, Ed.D Education Consultant February 2005 1 Introduction School District U46 is the second largest school district in the State of Illinois with an enrollment for the 2004-2005 school year of close to 40,000 students and over 4500 of them requiring some type of special education services. This consultant was asked to review the special education programming and services and provide information regarding good practices and procedures as well as make recommendations for future practices which may improve service or provide some cost reduction for the programming and services. It is important to realize that prior to the 2003-2004 school year the Special Education department was asked to reduce its budget by 6 Million dollars. Budget reductions were asked of every department and program at this time to help reduce a serious budget deficit. The department complied, by making its recommendations for these cuts including some significant reduction in personnel in the social work, nursing, speech and supervisory areas. Some of the data used in this report regarding personnel levels precedes these cuts and will be noted as the discussion proceeds. I would like to thank the Superintendent, Dr. Neale, the assistant superintendents, chief financial officer, principals and deans and the many members of the Special Education ...

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     Special Education Department Audit   For   School District U-46        Prepared by  Rebecca K. Fries, Ed.D Education Consultant  February 2005
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Introduction  School District U46 is the second largest school district in the State of Illinois with an enrollment for the 2004-2005 school year of close to 40,000 students and over 4500 of them requiring some type of special education services. This consultant was asked to review the special education programming and services and provide information regarding good practices and procedures as well as make recommendations for future practices which may improve service or provide some cost reduction for the programming and services.  It is important to realize that prior to the 2003-2004 school year the Special Education department was asked to reduce its budget by 6 Million dollars. Budget reductions were asked of every department and program at this time to help reduce a serious budget deficit. The department complied, by making its recommendations for these cuts including some significant reduction in personnel in the social work, nursing, speech and supervisory areas. Some of the data used in this report regarding personnel levels precedes these cuts and will be noted as the discussion proceeds.  I would like to thank the Superintendent, Dr. Neale, the assistant superintendents, chief financial officer, principals and deans and the many members of the Special Education department who were so cooperative in working with me and scheduling appointments and meetings, including the director, assistant director, secretarial staff, supervisors, psychologists, social workers, and instructional staff.     
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Report Format  The narrative of this report will present the information separated into sections aligning with the original “deliverables” presented to the Superintendent in the contract proposal. As each section is addressed a data analysis of the various pieces of pertinent information, a discussion of the relevance of the data, and the impressions and opinions of this analyst in relation to that information will be presented. In addition, commendations on good practices and concerns will be covered, followed up by a section on recommendations. An additional section will follow the original ones planned to cover information acquired which did not fit into any of the previously identified categories. The various recommendations scattered throughout the presentation will be summarized at the end. That will be followed by a set of Appendices, which will contain the data charts referred to in the various sections. The sections are as follows: • Analysis of the percent of students eligible for special education in comparison to State figures and similar sized districts, in total and by each special education category.  • Analysis and comparison of spending for special education services compared to other similar districts.  • Analysis of class or caseload size compared to state guidelines.  • Analysis of provision of level of service as it relates to state and federal recommendations regarding least restrictive requirements.  • Analysis of staffing ratios as compared to state and selected comparative districts.  • Analysis of school and district level staffs’ perceptions of service delivery and support including information about positive areas and areas of concern.  • Overall summary of positive aspect of present programming and services offered as well as recommendations for improvement of services or changes in service delivery to be more cost effective.  • Other information learned which did not fit in any previous category.  
Data Collection Procedures
The following procedures were utilized to acquire data to be used in the special education program review. 1. Initially, interviews were held initially with the Superintendent and part of her cabinet. This included the Assistant Superintendent of Secondary Education, the Assistant Superintendent of Elementary Education and the Chief Financial Officer.
 
 
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2. During the summer of 2004 letters were sent to six unit school districts requesting their Annual Financial Report for the 2002 – 2003 school year and a copy of the Special Education Data Profiles for the 2002-2003 school year provided to each district or special education cooperative by ISBE. That information was utilized to make comparisons of total and disability category special education eligibilities between the districts and financial comparisons of special education revenues and expenditures. This information is presented in table form in the attached appendices and will be referred to in the data discussion section of this report.
3. During the fall interviews were scheduled with the Director of Special Education, the Assistant Director of Special Education, all of the Special Education Supervisors, the administrator in charge of all early childhood programs, the school psychologists as a group, the school social workers as a group, four representative elementary building principals, four representative middle school principals, the four high school special education deans, the Assistant Superintendent of Secondary Programs, the Assistant
 
                
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Superintendent of Elementary Programs, the Superintendent, Chief Financial Officer, union representatives and some of the teaching staff.
4. Many documents from the district were also reviewed, including school enrollments for 2003-2004 and 2004-2005, special education class lists for all schools and some related services as of November 2004, Section 504 procedures, ISBE’s Compliance Review response dated July 2004, Local Alternate Assessment process, Social Work Handbook, Early Childhood and LD eligibility criteria, various internal forms used to refer students to service teams, to determine eligibility for one-on-one aides and to determine eligibility for Extended School Year services, the 2003 and 2004 Special Education Needs Assessment results, the FY 2005 IDEA Grants, the District and some individual school report cards for 2003 and 2004 and some information provided by special education supervisors regarding various programs used in some schools and the results of research they and their staff conducted.
Discussion Section
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Data Analysis Introduction  Through FOIA requests I was able to acquire Special Education Data Forms from the 2002 – 2003 school year. At the time of the requests this was the most recent year of data available. Since U46 is such a large district, there are not really any other school districts in Illinois, which are exactly comparable in size and ethnic similarity. The school districts chosen are large unit districts that fall into two categories. One set has a higher proportion of minority students and the other set are large districts that have been growing rapidly in the last few years. The districts included in the comparisons are:   Rockford, District 205  Peoria, District 150  Valley View, District 365U  Indian Prairie, District 204  Plainfield, District 202  Data from the entire State of Illinois was also utilized in the student and staff data comparison.     
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Students Appendix A provides a comparison of the ethnic make-up and low-income percentages of the 6 school districts and the State of Illinois. You will note that U46 has the highest percentage of Hispanic population of all those to which it is compared. In fact is has a higher percentage of Hispanic students than the State average, approximately 35% as compared to 17% for the State.  U46 does however, have a low-income percentage more in line with the State average, 34% as compared to 39% for the State. The other comparative districts either have much higher or much lower low-income percentages. The closest other low-income district is Valley View, 365U with a low-income percentage of 25.6%.  Appendices B and C compare the number of students by disability category from U 46 to the State of Illinois and the five other districts chosen. Appendix B provides this percentage by comparison to each entity’s total student population, while Appendix C provides the percentage comparison to the special education population in each entity.  When looking at the percentage of students eligible for special education compared to the total student population, U46 has a lower percentage of total eligible students than the State average, 11.51% for U46, and 14.96% for the State of Illinois. The total percentage for U46 more closely aligns with Valley View and Indian Prairie averages. Rockford aligns most closely with the State average with Plainfield a close second and Peoria has the highest percentage of students eligible for special education services in this reference group. That was also the district within this group with the highest percentage of low-income students.
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This low incidence of special education eligibility for U46 is an indication that there is no general over identification of students for special education services, which is a positive statement for the district. However, the fact that two other districts chosen for this comparison also have equally low eligibility percentages indicates that this is not an anomaly.  The primary area of discrepancy between U46 and the State of Illinois is in the percentage of students eligible for special education services under the category of learning disabilities. The state average is 6.73% while the U46 percentage is 3.52%. The current definition of eligibility criteria for this disability area is the most variable in interpretation from district to district and state to state. In discussion with the school psychologists in the district their feeling is that this low rate is due to a strict adherence to the state and district current eligibility criteria. However, this analyst has a concern some students are not being identified at the early ages since only 8% of the identified U46 LD population is below the age of 9 while the state number for this group is 11%.  When looking at Appendix C, which shows a percentage of students eligible for each disability category compared to the special education population, some interesting differences emerge. Even though the overall percentage of students eligible for special education in U46 was lower than the State average you could still expect that the distribution of students in each category would mirror the State percentages. However, this is not the case in looking at the data. Most notable is the higher percentage of students eligible in the speech/language impairment and emotional disturbance categories for U46 as compared to the State. In the case of speech/language impairment the U46 percentage is about 10 percentage points higher that the
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State of Illinois, and under emotional disturbance about 4 and a half percentage points higher. The area of learning disability for U46 is about 15 percentage points lower than the State of Illinois, which parallels the noted lower percentage when compared to the total student population.    The other two districts with similar low, overall percent of students eligible for special education also show some interesting variations on Appendix C. Valley View has a speech and language eligible population close to the state overage while its LD population is also below the state average and its mentally impaired population is higher than the state. The other district with a low eligibility percentage, Indian Prairie, has a higher incidence of students eligible under the speech and language, other health impaired and autistic categories and a lower percentage in the LD and mentally impaired areas. What these variances would indicate to this analyst is that there is seems to be great variability within districts and between them and the state averages and each district needs to look within itself to see some of the reasons behind these variations and what might be done to counter those trends, especially if they tend to over identification or extensive under identification in a specific category.  Recommendations: The special education staff needs to review procedures, eligibility criteria and actual practice in three disability category areas and try and determine if some manipulable factors are contributing to the over identification of students in the speech and language and emotional disabilities categories and under identification in the area of learning disabilities and make adjustments in the process as is appropriate.
Financial Comparisons
Annual Financial Reports  A second set of comparisons promised in the initial proposal of this report was a comparison of
special education costs between U46 and three other districts. It was hoped that a comparison
could be made with the five districts used above. However, although the Annual Financial
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Report (AFR) for the 2002-2003 school year was requested from all five districts, only three provided the specific sections required to make these comparisons. They were Rockford, Peoria, and Plainfield. The AFR’s from Valley View and Indian Prairie were not complete and did not
include comparative data. Additional attempts to acquire this information were unsuccessful.
 
The information taken for Appendices D and E were utilizing the same line items from the AFRs
to make the financial comparisons. It is felt by this analyst that there are probably some special
education costs not included in the line items compared which should have been. These are probably listed under other lines items on the AFR’s that could not be specifically aligned with
special education costs. One primary example is that although Plainfield listed 27.6 speech pathologists on their 2002-2003 special education data form there is no money on their 2002-
2003 AFR on the speech pathology/audiology expense line item. There total cost is unusually low in comparison with Rockford and U 46 so it is theorized that costs related to the provision of
special education services, especially speech and language costs, are listed under other line
items, which probably include both special and regular education expenses. This is also true for
the total listed for the Peoria expenses for that year. They had an unusually large expenditure under line item 1250, which is designated as “Educationally Deprived/Remedial Programs.” It is
hypothesized that these expenses were also used for both special and regular education programs.
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This is especially true since Peoria had the largest percentage of students eligible for special education services of the six districts compared and the lowest expenditure for the special education line items used for this comparison.  Appendix D was developed to indicate various specific special education revenues as noted on the 2002-2003 AFR. In reviewing that sheet and its information it is interesting that Rockford had received almost as much special education revenue even though it is a district with almost 10,000 less regular education students and 300 less special education students.  There are some very interesting comparisons with revenues and under which category each district is receiving high and low amounts. But it is noted that all three districts used in this comparison received more extraordinary reimbursement than U46 did during the 2002-2003 school year. It is hypothesized that at this time period, and perhaps the years before and after, that the district under claimed its extraordinary reimbursement. The good news is that for the 2004-2005 school year the amount of extraordinary reimbursement has been redefined by HB 4225 and was projected to be $3,184,171.27 for U46 which should be a significant increase over the 2.4 million received last year and more than twice the amounts received for FY 02 and FY 03. There is a provision in HB 4225 which allows districts to claim reimbursement for students who fall under the now 14.02b category of the school code, whose expenses are four times the district’s per capita. It may be that some of the students in the EN II classes or the NIA hearing impaired or visually impaired classes, self-contained preschool, or other students placed in public school programs out of the district might qualify for this level of reimbursement.