Comments on the Second Draft of Comprehensive Corrective Action Plan

Seattle Special Education PTSA and SEAAC collected comments from members on the second draft of the district’s Comprehensive Corrective Action Plan that was submitted to OSPI. The comments as well as that draft (no longer current) can be found here.

The following paragraphs are taken from our cover letter to Dr. Doug Gill, Director of Special Education at OSPI:

We are pleased that OSPI is exercising oversight and giving SPS guidance for serving students with disabilities. In particular, we hope that the district, with oversight from OSPI, will retain qualified leaders, dedicated to the administration of special education services. For a decade, special education service has been administered by a revolving door of administrators. We further hope that the superintendent will be compelled to empower these new special education administrators to actually deliver the services for which they have responsibility. We believe the decentralized administration has resulted in difficulties providing consistent, predictable, equitable, high-quality services to students.

We have included a number of suggestions to strengthen the CCAP. Student outcomes are our primary interest guiding these recommendations. First, we believe that non-compliance starts with the failure to recognize our students as first class citizens and as general education students first. This leads to non-compliance at the state and federal levels in many ways: failure to account for our students’ use of general education funding, failure to provide our students to access to the full range of educational, enrichment, and extracurricular opportunities afforded others as required by IDEA, and failure to receive education in the least restrictive setting, maximizing access to non-disabled peers. Further, it leads to a culture where the rights of and obligations to students with disabilities are easy to overlook. Secondly, we believe that non-transparency in the provision of district services leads to non-compliant and inequitable services and processes. Failure to disclose the nature and location of available services means that families are not given a range of alternate placements to consider as required by IDEA, based on the individual needs of students. Finally, we’d like to see improved responsiveness to families to correct known problems and instances of noncompliance. Our suggestions include specific actions to address these problems. We hope OSPI can help the district by requiring the implementation of solutions in the attachment which include:

  • Principals must be accountable for an “Inventory of Citizenship Status,” where the participation of students with disabilities in all facets of schools can be monitored centrally.
  • The district must provide adequate audits for funding levels due to students with disabilities. That funding should include all monies, including general education funding, levy funding, and any Title monies. Our students are general education students first, and all their general education money should be accounted for. Audits must ensure that special education funding does not go for other activities, such as educating non-special education eligible students.
  • The district must provide an accounting of the location of all programs and services serving students with disabilities at all times. The current SM “model” system only provides funding information, not services. It has been further degraded lately to provide only scattered information, often out of date.
  • The district must provide a known, predictable, and timely process for dispute escalation that includes all parties.
  • The district must create a system that incents the SPS legal department to resolve rather than escalate disputes.
  • The district must increase investment in special education. Students currently are not served with a scalable system. Lack of adequate accountability has meant that increased student population has not resulted in commensurate increase in the resources adequate to provide special education services.

While we are pleased with much of the work of the district and OSPI, we find room for improvement and streamlining. A number of improvement goals do not align with any student outcomes. In particular, training in IEP development software (IEP Online) does not address any issues the community has identified. We do not believe improved software usage will improve compliance in any way. Focusing on software training, while easy to check off a list, will not improve anything for our students. We are not convinced that all special education services should be centrally administered. Having central oversight is certainly important, but it isn’t clear that centralizing funding will lead to improved compliance, especially if the central staff continues to experience a very high turnover rate. We urge caution with making any changes. We do not believe that reducing by a small percentage, the number of citizen’s complaints to OSPI will result in more compliance. Complaint levels are not under the control of the district, so the district is unlikely to be successful in that effort. We do not believe it to be an accurate measure of compliance. And finally, we feel that pulling random IEPs to spot check for IDEA compliance is a very incomplete gauge. We would like to see OSPI monitor IEP implementation and school settings as well as IEP documents. In the end, we want to see improved outcomes and full citizenship for our students with disabilities and we hope OSPI and SPS will join families in making that a reality for our students.

Article and Editorial about OSPI report on Special Education Compliance

The Seattle Times recently reported on OSPI’s recent report on Special Education. OSPI is ordering Seattle Public Schools to fix these compliance problems within the next 18 months or lose funding.
Here are some links:

Q and A with our new Executive Director of Special Education, Zakiyyah McWilliams

The following are some questions and answers from the PTSA meeting of May 15, 2013 with Zakiyyah McWilliams, our new Executive Director of Special Education.

–          Ms. McWilliams started work on 5/13, two days before the meeting.

–          She has 30 years of experience, most recently with the Compton Unified School District in California.

–          She’s excited about the new service model being presented by the SPED Taskforce, (ABCD) and wants to be a partner.

The following is a summary of questions and responses.

Q: How do you hold people accountable?

A: Ms. McWilliams has worked in systems where teacher behavior caused due process motions, costing the district a lot of money. She presented data about the problem to the board, and more accountable was enforced, with repercussions for teachers if the proscribed processes were not followed. The flip side was to protect the rights of teachers as well. She put policies in place to hold teachers accountable, which will be ensured by principals and lead teachers.

Q: Will you give education to the district’s legal department?

A: Yes, she has worked closely with legal departments in other districts and understands the need for this.

Q: What’s on your “to do” list?

A: Drop-in hours for parents, staff, teachers. Visit all schools.

Q: How will you deal with professional development, especially since there doesn’t seem to be any time or money for this?

A: The District has agreed internally on intensive education during summer 2013. Not sure why teachers (in the audience) had not heard of this plan yet, could be due to need to finance the development work, which was still in formation.

Q: What’s the strategy to ensure money for SPED students sent to each school is actually spent on the students instead of being treated as a discretionary fund?

A: Will investigate this allegation.

Q: Will there be changes to specialized testing? IEP doesn’t transfer to MSP.

A: Is IEP accommodation against the rules of MSP? Is it in the OSPI as an accommodation? There was discussion about this from the audience, and questions about state law and practice. Investigation of this situation is now on Ms. McWilliams’ to-do list.

Q: What models of support have you seen work? We’ve seen that teachers are left to “twist in the wind” without support. New teachers need training.

A. In the past Ms. McWillams has seen programs where Special education teachers get assigned to a “star mentor” status, moving to 2-year “induction program.” IEP responsible teachers make sure each student gets appropriate services. Teachers are responsible for accommodation of students. Informal support groups among teachers can help, but teacher retention is a problem.

Q. How do you get to know strengths and weaknesses of students and district?

A. Visit all of the schools! Stay healthy in order to have lots of energy. Ms. McWilliams wants to know all of the principals; she wants to empower them and get to know their philosophy of special education. The best way to find that out is to engage them in conversation.

Q. What should parents do if teacher doesn’t follow IEP?

A. Start with special education teacher.

Q. Why can’t the Special Education direction look at the budget?

A. That is not clear. It is one of Ms. McWilliams’ top priorities to get a look at the budget!

Q. Have you worked with unionized principals before?

A. No. McWilliams has worked extensively with unionized teachers and staff. In fact she used to be a teacher’s union representative. However this is the first time she’s worked with a principal’s union and she feels she has much to learn.

Q. Questioner noted that there is not enough attention to assistive technology or transition services.

A. If it’s in the IEP it needs to be addressed.

Q. Transition plans/changes have not been communicated to teachers. When will that be done?

A. It’s believed this may be due to funding issues and job descriptions being re-written. Things are in flux.

Q. What is your line of reporting to the Superintendent office?

A. Ms. McWilliams reports to the Asst. Superintendent for Teaching and Learning, which means sitting at the table with the general education folks. She’s also part of the Superintendent’s cabinet, which is new this year.

Q. Do you have experience with outside organizations luch as Special Olympics, etc?

A. Yes, Ms. McWilliams worked with special programs in Compton such as non-public schools and recreation centers. She feels it’s possible to shift funds from one program to another in order to obtain the best possible services for students.