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 The comments as well as that draft (no longer current) can be found here.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.