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Special Education System Review for Reynoldsburg City Schools: Final Report Submitted by Greg Maloney June 2, 2008 “Greatness is not a function of circumstance. Greatness, it turns out, is largely a matter of conscious choice.”

- Jim Collins, Good to Great

As the above quote suggests, achieving greatness or excellence occurs when intentional effort is implemented, measured, and adjusted as necessary. This applies to individuals, private businesses, and school districts. The Reynoldsburg School District (RSD) is currently engaged in exerting this effort through having various components of its educational system reviewed. This report summarizes the findings and provides recommendations based on these findings concerning RSD’s special education support system. It is emphasized that this review focused on the structural components of the special education system, not on evaluating the performance of specific individuals. It is understood that an organizational review of RSD’s Central Office organization and functioning will also be occurring. Overview This specific review was initiated by RSD for several reasons. First, site-based management has historically been a key component of RSD’s approach to providing education. Superintendent Dackin and Assistant Superintendent Hoffman sought feedback on the effectiveness of this approach, primarily as it relates to providing services to students with disabilities (SWDs). Next, RSD was rated as an Effective school district, and in District Improvement Year 1 for 2007. SWDs did not meet Adequate Yearly Progress (AYP) in reading and math, while the performance of limited English proficiency (LEP) students did not meet proficiency in reading. Consequently, feedback and recommendations related to the performance of SWDs was included in the project scope. Given the changing requirements for providing special education services, including recent changes to state and federal requirements, the district leadership also sought feedback and recommendations related to RSD's compliance with these requirements. Moreover, RSD is experiencing significant change. Financial constraints have resulted in budget cutting, with additional cuts expected while at the same time new buildings are being added to the district. Student diversity is increasing with nearly 60 languages now represented. As a result, feedback and recommendations for how to make service delivery for SWDs more efficient and effective was requested. Consequently, the project scope included four components: • Relationship between RSD Central Office (CO) and the individual school buildings; • Performance of SWDs; • Compliance with special education requirements; and, • Efficiency of operations.


Methodology Initial discussions occurred with Greg Maloney, project consultant, Superintendent Dackin and Dr. Aron Ross of the Franklin County Education Service Center (FCESC). Once the project’s scope of work and timelines were decided, background information was reviewed including • RSD’s Organizational Chart • REACH Materials • Ohio Department of Education (ODE) Determinations Letter for RSD • ODE Self-Assessment Letter for RSD • Information on RSD Community School • RSD’s Excess Cost report • RSD’s AYP Workbook • RSD’s Comprehensive Continuous Improvement Plan (CCIP) • RSD Report Card • RSD Special Education Roster and other Special Education information • A sample of RSD SWD Files • RSD District Goals • State Support Team RtI Implementation Report for RSD • Discipline records for RSD and individual buildings • 1997 ODE Monitoring Report • Documents and correspondence with Office of Civil Rights • Primary Prevention Awareness, Attitude, & Use Report • RSD Special Education Documents including the Easy Guide to IEP Meetings and the Quick Reference Guide to Special Education Procedures • Individual Assistance Team Materials Perspectives from central office staff and school-based personnel were also solicited. Over seventy (70) individuals were interviewed, including central office staff, site administrators, special education and related services staff (intervention specialists, school psychologists, social workers, speech/language therapists), and regular education staff. All staff members were cooperative and pleasant. Attempts made by the consultant to contact parents were not successful. ODE personnel, ESCFC special education personnel, and administrators from other districts were consulted for reference and background information. Research was also conducted to identify districts in Ohio and nationally which have been successful in serving SWDs, including meeting AYP, and the practices they implemented to achieve their success. The results have been incorporated into this report. THEMES & RECOMMENDATIONS The next sections describe themes that emerged from the review, discuss their impact, and provide recommendations to address them. Positive perceptions or strengths regarding the district, especially the special education system, will be identified first. Next, themes related to the four focus areas are presented followed by recommendations for the district to consider. Although the primary focus of this review is on SWDs, many of the themes and

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recommendations also apply to the services provided to other subgroups, including students receiving support under Section 504 of the 1973 Vocational Rehabilitation Act and students demonstrating Limited English Proficiency (LEP). Please note that for this discussion, CO refers to the Central Office as a unit, unless otherwise specified.

Perceived Strengths Although the project focused on identifying opportunities for improvement, a number of positive attributes or strengths were identified including the following: High Quality of RSD Personnel. This was a near unanimous theme. Personnel at all sites were described as having high expectations for students, being willing to “go the extra mile”, and being flexible and creative. One respondent described the district as possessing “tremendous talent” which was echoed in the comments of others. The responses also indicated that staff members want to continue developing their professional skills to improve their capacity for meeting student needs. Site-Based Management. Many respondents appreciated that schools are able to make local decisions regarding their school’s operation. This allows schools to address issues in the most locally effective fashion, as opposed to a “one-size fits all” model. Site-based management also allows flexibility in regards to scheduling and structure. Special Education Compliance. Staff reported that overall RSD does well ensuring timely completion of student evaluations and IEP reviews. Administrative Support. Recognition and appreciation for the support offered by CO staff and building principals was expressed. Staff believed that the CO staff was responsive to questions and that principals generally allowed staff to think creatively and adapt as necessary. Respondents also appreciated that CO leadership was seeking their feedback through this project. Regular and Special Education Staff Collaboration. Respondents perceived a growing “ownership” by regular education personnel for supporting SWDs and at-risk students. Regular education and special education providers demonstrate considerable flexibility in meeting student needs and supporting student success. Intervention Efforts. Respondents described RSD personnel as striving to meet student needs through providing effective interventions. RSD was also described as having a number of alternative education options available for students. Parent Involvement. Most respondents described having positive or even very positive relationships with parents. Some sites have taken steps to encourage parental involvement, including providing transportation to meetings and holding meetings by telephone. Efficient Use of Resources. RSD schools were described as being very good at maximizing their resources to support student outcomes (i.e. “doing a lot with a little”).

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Discussion The positive aspects described above indicate that the desire and motivation for effectively serving SWDs is widely held by RSD staff. This suggests that improvement efforts designed to increase staff capacity for serving SWDs stand a strong chance of success.

Focus Area #1:

Relationship between Central Office & School Sites

For any school district, the central administrative office’s relationship with individual school sites is a key component and indicator of overall effectiveness. This relationship impacts all aspects of a district’s functioning, including its special education system. Not surprisingly, respondents provided consistent feedback on this topic, much of it focused on the balance between site-based management and centralized leadership.

Themes District Identity & Culture. Concerns with the district’s perceived identity and culture were frequently expressed. Many indicated that RSD does not seem to have a common identity, but appears composed of isolated schools operating relatively independently. They indicated this leads to inconsistent practices and results, as well as inefficiency, particularly regarding vertical alignment among programs and use of resources. A number of respondents described the culture as competitive and one in which sharing of resources, information, or ideas was not encouraged. The level of trust and communication between the CO and the schools was often rated low, as was accountability at the CO level. For example, respondents indicated that while the performances of SWDs and students with LEP are primary reasons why RSD is rated Effective instead of Excellent, no centralized effort to address these concerns have occurred, such as reviewing the data, analyzing district/school instructional practices, and designing professional development. Respondents also indicated they did not think the district’s annual goals or Comprehensive Continuous Improvement Plan (CCIP) were evaluated systemically. Schools were described as taking their CIPs seriously, but not the district. However, a number of respondents indicated they are hopeful that the new RSD leadership can help address these issues. District Policies. Respondents indicated that RSD has few core policies and procedures, although they believed these would help improve consistency and efficiency at the schools. Among the suggested centralized policy areas they suggested are • Curriculum • Special education policies and procedures; • Data collection and utilization for guiding and differentiating instruction; • Professional Development • Staffing (i.e. caseload management) • Individual Assistance Team (IAT) procedures; • Response to Intervention (RtI) procedures; • Mapping and pacing learning expectations; • Behavioral support systems; • Sharing of resources; RSD Final Report Maloney Consulting

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• • •

Development and review of CCIP goals, strategies, and action steps; Use of Technology; and, Student transitions into different buildings.

The desire for the CO to assume a more active leadership role for ensuring that district policies, once created, are implemented with fidelity and evaluated was also clearly expressed. Respondents believe this would further promote vertical alignment of RSD services, which would benefit both students and staff. Respondents do not want micro-management, but a core set of procedures and expectations that they can adapt to fit their local needs. Communication & Collaboration. Nearly all respondents indicated their desire for more systemic, structured opportunities for collaboration. They want to interact with their specific peers (i.e. intervention specialists, school psychologists, social workers, and administrators) in other buildings, to meet as a special education group with CO special education staff, and to meet with regular education staff to focus on improving student performance. They also want meetings to be well-structured and occur on a consistent basis. In addition, they desire more opportunities for team teaching among special education and regular education staff. Respondents want more professional development opportunities to supplement what is offered by their schools. Special education staff members want training on special education requirements and procedures, writing improved IEP goals and objectives, behavioral issues, etc. Having professional development to support regular education and special education collaboration was also cited. A strong preference to have this training provided jointly for staff from different buildings was also expressed. Relationship between CO & Schools. Respondents would like to see a collaborative partnership develop between the CO and schools. Respondents indicated their desire for the CO staff, including special education staff, to become more involved with identifying systemic solutions, developing long term planning, and helping promote accountability across sites. Several respondents described the past CO approach to schools as “just make it work”. Another expressed desire is for the CO staff to be more aware of what is happening at the schools. Respondents would like to have CO staff visit schools more frequently and become more aware of the challenges and success experienced there. At the same, school staff would like to become more aware of what is happening at the CO in terms of policies, procedures, and other information. Resources. Respondents indicated they want to become more knowledgeable about how resources are allocated in RSD, including federal special education funds which are apparently used to pay for alternative placement tuition, personnel, and assistive technology support. They also want support for sharing resources and grouping purchases across sites, as well as the opportunity for discussing “what’s working” at other buildings that they can utilize in their schools.

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Discussion RSD personnel demonstrate a deep commitment to student success as evidenced by RSD’s Effective school rating and the perceptions they have of each other. They also believe that the CO needs to demonstrate a stronger leadership role to propel RSD to higher levels of achievement. With its history of site-based management, RSD does not currently have a wellestablished framework through which to exercise this leadership. The recent changes in district leadership, support demonstrated for this role by respondents, and examples set by other successful districts, provides RSD with a great opportunity to create this framework. This includes defining expectations, in terms of process and outcomes, as well as clearly communicating and evaluating these expectations. This set of expectations or mission serves as the centralized organizing framework from which other activities flow and which these activities support. District policies are created in the context of whether they support this framework. Activities and personnel are evaluated in relation to this framework. Site administrators continue to operate as instructional leaders in their schools but within the framework established by RSD. As opposed to micromanagement, this framework provides the context within which site management may operate, and provides a balance between top-down and bottom-up leadership. As this process unfolds over time, a distinct district identity and culture will emerge, while preserving the unique characteristics of each building. A key factor to the ultimate success will be the level of commitment the CO demonstrates in establishing and maintaining this culture. Establishing a centralized organizational framework may seem far afield from the task of improving RSD’s special education system. If, however, RSD’s framework contains a central tenet that all students will receive the support services they need to be successful (“what they need when they need it”, as an administrator from another district described it), this will have a major impact on special education services in terms of staff roles, referrals, regular education and special education collaboration, professional development, technology and resources.

Recommendations: It is recommended that: I. RSD develop a centralized organizing framework that outlines its mission, its global expectations for process and outcomes, and its focus on accountability. This will include developing a. a mission statement; b. a long-term (3-5 year) plan that includes current performance, future goals, and necessary steps to achieve these goals, including ongoing evaluation of RSD’s plan; and, c. annual goals related to the long term plan that include annual evaluation. II. In line with current research and identified effective practices, RSD include a prevention/intervention focus in which students have their needs identified, evidence-based interventions provided, and their progress systematically monitored. III. RSD develop a core set of policies that establish systemic expectations and procedures for the schools to implement and adapt as necessary. Some policy areas include RSD Final Report Maloney Consulting

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a. b. c. d. e. f. g. h. i. j.

Curriculum (materials, mapping, pacing, short cycle assessments) Special education policies and procedures, such as common eligibility guidelines; Data collection and utilization; Approaches to Prevention & Intervention (e.g. IAT, RtI)); Behavioral Support; Professional Development expectations; CCIP Development and Review; Resource Purchasing and Management; Student Transitions; and, Use of Technology.

This will help establish vertical alignment within RSD and allow school administrators and faculty to focus on implementing these policies effectively rather than on creating them at each school. IV. RSD include performance measures related to the implementation of these policies and procedures in performance evaluations as appropriate. V. RSD create an electronic newsletter to keep personnel apprised of district-level activities, progress, new policies, and successes experienced by schools and individuals. This type of tool is useful in helping build a sense of common identity and culture, and for demonstrating the district’s accountability to its staff. Note: Recommendations related to professional development, collaboration, and resource usage are contained in later sections.

Focus Area #2: Performance of Students with Disabilities As noted earlier, SWDs did not meet AYP in the areas reading and math, while students demonstrating LEP did not meet AYP in reading. In reviewing building level data, all but one of the elementary schools were rated as Excellent. However, the results of SWDs were not reported for these schools since the n size for SWDs was too low. The middle schools, junior high school, and the high school did not meet AYP for SWDs, primarily for reading. The gap between non-disabled students is striking; in 10th grade 97.1% of non-disabled students demonstrated reading proficiency while only 57.4% of SWD did. Significant gaps exist at all grade levels and in all subjects, and when the SWD results are compared across the racial/ethnic subgroups and economically disadvantaged subgroup. The comparison of SWDs with students demonstrating LEP students produces more comparable performances.

Themes Expectations for SWDs (and other subgroups). Some respondents raised the issue of reasonable academic expectations for SWDs. Some indicated that expectations for these students were not high enough and they were not being challenged appropriately. Others RSD Final Report Maloney Consulting

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indicated that expectations were too high and, at least for some SWDs, unreasonable. Some special education providers expressed confusion regarding whether they should be focusing on teaching SWDs the curriculum or focusing on IEP goals. Similar concerns regarding expectations were raised regarding students demonstrating LEP and students identified as Gifted Perception of Special Education as a Priority. Some respondents were concerned that although the performance of SWDs is said to be a priority in RSD, some actions taken in schools appear to conflict with this. In some buildings, according to respondents, intervention specialists are sometimes used as substitutes for regular education teachers if another substitute can not be found. Similarly, if an intervention specialist is out, a substitute is sometimes not hired to replace this person. In either case, respondents expressed concern that SWDs are not being served appropriately. Special education personnel were also described as being “spread thin” due to caseloads and multiple responsibilities. As mentioned earlier, concern that more district level analysis of the factors contributing to the lower AYP performance of SWDs and students with LEP has not occurred was expressed. Intervention Efforts. All schools have implemented an Individual Assistance Team process. However, considerable variability exists in how these processes are conducted including who participates on the teams, how the referral process to the teams works, the forms and data collected from the process, and how interventions are selected and implemented. Respondents in some buildings reported the IAT was an integral part of identifying and meeting the needs of students, and even reducing the need for referrals, while other respondents indicated that the IAT was simply a necessary step to getting a student referred for special education services. Concern with the lack of follow-up was frequently noted. The implementation of the Response to Intervention (RtI) model across schools demonstrates an even greater level variability. Some schools have developed and implemented a tiered intervention model, while other schools are still considering whether to implement it. According to the SST’s RtI Implementation Report produced by the Region 5 State Support Team (SST), 5 schools attended RtI training and are implementing, 2 schools attended but are not implementing, and 4 schools did not send staff to the training. The report also indicates that 6 schools are using universal screeners and tools to monitor student success. The process for choosing and evaluating evidence-based practices is also not clearly defined. Similarly, schools demonstrate a variety of methods for addressing behavioral issues. At least two schools have implemented a school-wide system of behavioral support, while some schools do not appear to have implemented any system, other than their discipline policy. Yet, staff in all schools report behavioral and disciplinary issues to be a primary concern and one of the objectives listed under RSD Goal #3 is to “develop positive behavior/discipline plans within each building. In reviewing the discipline records for SWDs, one elementary school reported no suspensions while another school reported 11 different SWDs were suspended at least once. Although other factors may contribute to this disparity, this raises the possibility that expectations differ across schools. Finally, schools utilize different special education service models, with some using resource rooms, some using an inclusive approach, and some using skill labs. Some schools also assign

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intervention specialists by grade level which means that some may have larger caseloads than others. One building utilizes a cross-categorical program that includes students from two grade levels and four disability categories. Data Collection & Usage. A range of approaches to collecting data are being used across the district. Dr. Rogers, Director of Accountability, is working with the middle schools to implement a data tool which should significantly streamline the process. He indicated that the junior high schools will be next, followed by the elementary schools. The OASIS system is being used at the HAMS for the Gifted program and is apparently being considered for wider application. Progress Book is being used at the middle school through high school levels, but not at the elementary, although the elementary schools may adopt it soon. DASL is also being incorporated. Some schools and some staff have created their own data tools. As a result, although most staff realize the importance of data no consistent method for collecting and presenting the data has been articulated throughout the district. The use of short-cycle assessments and other types of progress monitoring is also somewhat inconsistent. This suggests that ongoing communication among the Director of Student Services, the Director of Accountability, the Director of Technology, and site administrators is critical. Analyzing and using the data to guide instruction is another issue. Wide variability for skill and comfort using data was reported among schools. Some described their schools as being skilled at using data and others reported their schools being uncomfortable using data. As one respondent stated, “we are data rich but information poor (DRIP).� Some administrators place strong emphasis on using data and have created processes and expectations to support this. As noted earlier, respondents indicated there is currently no systemic review of student performance data from a district wide perspective; instead, it is occurring primarily at the building level. Other concerns included the need for time to analyze the data and enhanced professional development. Assessment Issues. Two issues emerged related to statewide assessments. The first concerns the use of accommodations for SWDs on statewide assessments. A high degree of variability was reported among the schools. The need for greater consistency and standardization among sites was frequently expressed. The second concerns the Alternate Assessment (portfolio assessment for students with significant cognitive disabilities). Currently, only RSD students enrolled in the Franklin County MRDD program are apparently allowed to participate per district policy. A number of respondents believe this policy is too restrictive since they know students with cognitive disabilities for whom they believe taking the Ohio Assessment Tests (OAT) is inappropriate. However, other respondents expressed concern that having students participate in the Alternate Assessment could lead to lowered expectations for SWDs. This issue is closely aligned with the issue of what are appropriate expectations for SWDs. Vertical Alignment & Student Transitions. Respondents from all levels communicated their concerns that the RSD curriculum, expectations, procedures, and other programmatic functions were not vertically aligned, and sometimes not even horizontally aligned within buildings. They indicated that the connections among buildings and levels are not well-defined or articulated, and

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believe this has an impact on student performance. One person described vertical alignment as a “crying need”. A number of staff expressed their desire to learn more about the expectations and programs of schools above and below their level in order to better facilitate students transitioning from one school to another. Some schools have implemented a process in which staff members from the sending and receiving schools meet to discuss how to best serve the students making the transition. However, there is apparently not a formal, district-wide expectation for this to occur, although many staff expressed their desire for this to happen. Professional Development. A strong desire for increased professional development for regular education and special education staff was expressed. This is consistent with the desire noted earlier for more opportunities to collaborate with colleagues from other buildings. Targets for regular education staff included training on the basics of special education, differentiated instruction, and use of data. Targets for special education included increased understanding of academic standards, grade level indicators, along with aligning special education services with the general curriculum.

Discussion A common thread connecting the above issues concerns RSD’s commitment to promoting student achievement, particularly SWDs. Another common thread is the variability among schools for how they address these issues. With a centralized organizing framework, it is expected that mechanisms for addressing these issues will be established. For example, the question of whether improving the SWDs is a district priority would entail discussion of how special education staff are utilized, which would likely raise issues of budgeting, organization, and scheduling. It may also analysis of data describing the performance of SWDs to determine what specific issues need addressed. The IAT and RtI processes would be reviewed to determine if students, particularly at-risk students, are getting the support they require, whether data is being collected, and whether the IAT and RtI processes are effective. Professional development to address the identified issues would be identified and provided. Dr. Judy Elliott, formerly of Long Beach Unified School District in Long Beach, CA, is a nationally recognized expert and presenter on effective student support services. In a recent presentation, she highlighted 3 cultural aspects that need to evolve for school districts: • From Excuse to Accountability • From Compliance to Performance • From Uniformity to Differentiation Based on Talent & Need. The centralized organizational framework can help this evolution occur. Expectations regarding the academic achievement of SWDs obviously impact how they participate in statewide assessment. The issue of accommodations is relatively straightforward: test accommodations should be based on the IEP accommodations the student is currently receiving and which are allowable under ODE policy. Students do not necessarily perform better when they receive more accommodations and may actually find additional accommodations

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frustrating since it is a new task to learn. Using unnecessary accommodations is also inefficient since it requires additional staff time and planning. Similarly, the criteria for the Alternate Assessment (portfolio) are relatively objective. Under NCLB & IDEA 04, students must demonstrate a significant cognitive disability, have an educational program that is primarily functional in nature, and be unable to participate meaningfully in the traditional statewide assessments, even with accommodations. It is the role of the IEP team to make this determination; however, only up to 1% of students tested may have their results counted toward AYP via the Alternate Assessment, which provides an upper limit to the number of students participating in the Alternate Assessment. As with accommodations, it is based on the individual student’s needs as determined by the IEP team, taking into account appropriate expectations for the student. The intent of the Alternate Assessment is not to lower expectations, but to make the testing process fair and equitable for SWDs. Professional development for staff is a critical factor in helping assure that assessment processes are utilized appropriately. ODE has a number of training materials available focusing on the use of accommodations and the Alternate Assessment.

Recommendations It is recommended that: I. RSD identify the performance of SWDs (and other subgroups) as a district priority and consider taking the following actions: a. Prior to the beginning of the school year, present RSD administrators and staff with data demonstrating overall trends in SWD performance, as well as trends within individual buildings; b. Facilitate analytical discussion of these data, including appropriate expectations for SWDs and students in other subgroups. Part of the discussion may focus on the relationship between RSD’s goal of students realizing one year’s growth in reading and math (value-added) versus achieving proficiency on statewide assessments; c. Facilitate discussion on how building practices support or impede the progress of these students; d. Create goals, action steps, and evaluation strategies as part of the CCIP at both the district and school levels to improve the performance of these students. II. RSD promote effective communication among the Directors of Accountability, Gifted Services, Student Services, special education supervisors, and standards coordinators for aligning the expectations of and services provided to SWDs and students in other subgroups. RSD should consider creating regularly scheduled meetings for these individuals to discuss current performance data, trends observed in schools, effective practices and how to incorporate them, and professional development needs. Action steps should be developed and measured.

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III. The group mentioned in the item above meet with CO and building administrators on a regular basis. Currently, it appears that 3 regular meetings with building administrators occur at the CO: a. One to review the Board agenda facilitated by the Superintendent; b. One to discuss leadership development topics facilitated by Assistant Superintendent; c. One composed of Local Professional Development Committee to research and discuss current educational practices. Perhaps one of the latter two meetings could be designated as the forum in which the recommended discussions occur. This would further demonstrate alignment between district priorities and district actions. IV. RSD create a data scaffold model that describes the purpose of each data tool and how it fits with other data tools. This model will illustrate the relationship among DASL, Progress Book, Dr. Roger’s data analysis tool, OASIS, and other tools. Creating clear expectations for how personnel interact with these data tools is also recommended. Again, collaboration among the Student Services, Accountability, and Technology should occur in designing the scaffold. V. RSD develop consistent expectations and guidelines for implementing the IAT and especially RtI processes. VI. RSD develop guidelines and expectations for the use of test accommodations and the Alternate Assessment. Collaboration among the departments of Student Services, Accountability, and Technology to develop these guidelines should occur. Actual decision making responsibility belongs to the IEP team, but guidelines supporting effective decisions will be beneficial. VII. RSD develop a process through which appropriate staff members at different building levels (i.e. elementary, middle school, junior high, and high school) meet prior to the beginning of the school year to exchange information and promote effective student transitions between buildings. VIII. RSD provide ongoing professional development related to the above recommendations. Regular education staff will benefit from training on • Data collection and analysis; • Differentiating instruction; • RtI; • Effective Team Teaching; and, • Understanding purpose and components of special education. Special education staff and other service personnel will benefit from training on topics such as

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• • • • •

Data collection and analysis; Content standards and grade level indicators; Developing and aligning IEP goals/objectives with the general curriculum; Effective Team Teaching; and, Statewide assessments, accommodations, and the Alternate Assessment.

A number of respondents expressed interest in team teaching but concern over whether time for planning would be available. Examples of strategies used by some districts to create planning time include • Flexible scheduling with a delayed start time for students every other week; • Holding grade-level classes, such as gym, art, and music, at the same time thus freeing up staff; • Creating a common lunch time built into the schedule to allow daily collaboration.

Focus Area #3: Compliance Compliance refers to whether special education requirements and procedures are being followed. Minimum compliance reflects that timelines are met, appropriate paperwork is completed, procedural safeguards are provided, and other similar requirements. From a broader qualitative standpoint, compliance focuses on whether a student’s program matches the student’s needs, the quality of the IEP goals and objectives, the connection to the general curriculum, and overall student progress. ODE’s Office for Exceptional Children, in compliance with the Individuals with Disabilities Education Act of 2004 (IDEA 04), has recently implemented processes to help monitor district compliance. The first, called Determinations, annually rates a school district (using the ranks Meets Requirements, Needs Assistance, Needs Intervention, and Needs Substantial Intervention) on factors including least restrictive environment, childfind, early childhood transition, secondary transition, and AYP for SWDs. RSD, like the majority of Ohio districts, received a determination of Needs Assistance, primarily due to the early childhood transition data from 2005-06 and SWDs not meeting AYP. The RSD Preschool Coordinator indicated that the early childhood transition issues have been successfully addressed. Second, RSD was asked to complete a self-assessment of its compliance with completing initial evaluations within 60 days from obtaining parental consent, and providing secondary transition planning in a student’s IEP. Based on the 2006-07 data that RSD submitted, it was determined that both areas did not meet the 90% compliance threshold, although completing initial evaluations within 60 days was very close (89.1%). Action plans for addressing these two issues have been submitted to ODE. Another ODE tool compares suspension and expulsion rates for students with and without disabilities in a district. According to a January 2008 memorandum from the ODE Office for Exceptional Children, the discipline data reported by RSD for 2006-07 indicated a significant discrepancy on this measure. As a result, the district reviewed its policies according to a rubric provided by ODE and provided this review to ODE. In addition, according to ODE, five (5) due process hearing requests from RSD have been received since 2000. All of them were resolved prior to going to hearing. Overall indications

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are that RSD generally meets its basic compliance requirements. Reminders are sent out by the CO special education administrative assistant to facilitate compliance.

Themes Percentage of Students identified with Disabilities. RSD has 1,187 SWDs, including 82 preschool students, enrolled as of May 2008. Using a total student population of 6,662 for comparison, RSD demonstrates an identification rate of 17.8%, which is higher than both the state (approximately 14%) and national averages (approximately 12%). Excluding preschool students, the percentage is still 16.6%. Among the elementary buildings, the number of students identified varies widely. One school has 108 SWDs, another has 92, and the remaining schools have fewer than 70. Again, many factors may contribute to this disparity, but it does suggest some variability in how students are identified. This has a number of ramifications including staff caseloads, time spent testing for eligibility, number of required meetings, and impact on expectations for students. Some suggested that a contributing factor to the number of students identified is the number of SWDs moving into the district. Respondents also suggested that lack of consistent guidelines for how students are determined eligible may be a factor. Continuum of Services for SWDs Demonstrating Behavioral/Intensive Needs. Respondents expressed strong concern regarding RSD’s approach to serving SWDs demonstrating significant behavioral issues, as well as other intensive needs. Previously, behavioral units were created in the district to serve students with behavioral issues, but they have been largely discontinued in favor of serving students in their local schools and regular classrooms, possibly with paraprofessional support. If a student is unsuccessful in this placement, the next option is an out of district placement such as Excel Academy. Wagner Road Junior High School maintains a cross-categorical program which includes students in 7th and 8th grades demonstrating a range of disabilities and intensive needs. Of the 16 students reported to be in the program at the beginning of the year, 9 remain. Some transferred but some were apparently expelled. Many staff are concerned that schools are not prepared to serve these students which impacts not only students but also special education and regular education staff. It may also be impacting the number of SWD suspended and expelled. Many respondents expressed their desire for more intensive programming provided in the districts, or at least more intensive support. This concern was shared at all levels and sites. From a broader perspective, the most recent Primary Prevention Awareness Attitude & Use Report (PPAUS) indicated that 16% of middle school students reported being called names, disrespected, physically threatened or made to feel afraid online at least twice. At the high school level, 15% reported fearing for their physical safety more than once in the previous year. Clearly, behavior management is an important issue for RSD. Special Education Quality Control. A sample of special education documents (i.e. Evaluation Team Reports (ETRs), IEPs) from each school was reviewed. General themes that emerged included •

Unclear guidelines for special education eligibility, particularly for the category of learning disability;

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IEP Present Levels of Performances (PLEPS) did not connect the student’s disability with its impact on the student’s performance on the general curriculum;

IEP goals were very general, sometimes immeasurable, and not aligned to the standards;

Special education services were not specified in terms of frequency and duration;

Testing accommodations did not match student’s IEP accommodations;

Secondary Transition planning was limited.

These issues are not unique to RSD. However, given the current structure and information management process, it is not clear how such issues would be identified and addressed. Currently, cumulative special education files are maintained at the schools, which then send the ETRs and IEPs to the CO, which then contracts with a company to scan them into an online database. The student services administrative assistant maintains a special education roster that lists due dates for IEP reviews and re-evaluations, and sends reminders to staff as the due dates approach. It does not appear that at the local or district level a qualitative review of special education programming and documentation is occurring. Some districts utilize a process in which these processes and documentation are reviewed by qualified staff and the results used to guide professional development activities. RSD does provide two special education support publications: The Easy Guide to IEP Meetings and The Quick Reference Guide to Special Education Procedures. However, respondents expressed the desire for consistent training for improving their performance in this area. In related fashion, three different systems for completing IEPs and other special education documentation are apparently being utilized. Some sites are using the ODE forms downloaded from the ODE website. Some are using the IEP component of the Progress Book data system, which seems to have the required information but in a different format from the ODE forms. Some are using the Practical Solutions IEP tool which has forms that are consistent with the ODE forms except for the EMIS form. Along with potentially impacting compliance and data reporting, this variability could also impact SWDs transitioning to different buildings. FERPA. Maintaining confidentiality of student records, as defined by the Family Educational Rights and Privacy Act (FERPA), is an important compliance component. Given that FERPA applies to all educational records, not just special education, it is important that all staff are familiar with FERPA requirements. In one building, for example, a paper was seen in the general trash that listed student names and whether they had IEPs. Special education records should also be locked and only accessible to appropriate staff. Transfer Students with IEPs. Two issues arose regarding SWDs transferring to RSD. First, it appears that RSD generally accepts student IEPs from the previous district. As long as RSD implements the IEP as written, no concern exists. However, if the program being provided does not match the student’s IEP, the district is out of compliance. The district has the right to review the student’s IEP and reconvene an IEP meeting to rewrite the IEP, although the resulting services have to be based on the student’s individual needs.

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A second issue concerns the student enrollment process. Some respondents indicated that since students now enroll at the CO as opposed to the schools, staff are not always aware of whether a student has an IEP until school begins. This impacts scheduling, caseloads, and other planning that occurs prior to school starting. They expressed a desire that more effort be made to determine if a student transferring to RSD has an IEP during the enrollment process. Professional Development. A number of respondents indicated their desire for increased professional development and collaboration opportunities, particularly focusing on special education requirements and effective practices. Parent Involvement. Most staff reported positive relationships with parents of SWDs. The primary issue reported was concern over how to increase parental involvement with the schools.

Discussion In previous years, special education compliance focused on whether rules were followed in identifying and serving SWDs. Under the No Child Left Behind Act (NCLB) and IDEA 04, this focus has changed significantly to one that now emphasizes whether SWDs are experiencing academic success. SWDs are expected to receive evidence-based interventions prior to referral and identification, IEP components are o be aligned with the general curriculum, and schools/districts are held accountable for the academic progress of these students. This is a major shift for many special education providers, regular education staff, and parents. The centralized organizing framework will help facilitate the transition to this paradigm across the district. The issue of providing appropriate services for SWDs demonstrating significant behavioral issues is critical. One option is to provide a wider range of more restrictive settings for students, including self-contained support. Although some indicated their desire for this approach, others expressed concerns over whether students would receive appropriate instructional support or simply be maintained in these classrooms. Another option is to continue providing services in regular classrooms with intervention specialist or paraprofessional support. Many respondents indicated this approach is not meeting the needs of students, results in disruptions in the classroom that affects other students, and when students are unsuccessful in this setting the next option seems to be an out of district alternative placement. Not only is this an expensive step, it is also more restrictive than a self-contained classroom since it is out of the district. A review of the most recent Schools of Distinction Cross-Case Analysis indicates that these schools serve most SWDs in the regular classroom, but with significant supports provided. Some also indicated that students with more intensive needs are educated in pull-out or other settings. The key for RSD is to determine the model the district can support that will provide students the individualized services they require. It may be that a transition process utilizing pull-out or selfcontained services would be useful until the regular education environment with support model becomes more viable.

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Recommendations It is recommended that: I. RSD develop eligibility guidelines for teams to consider for assessing and determining eligibility for special education. a. A particular focus should be on developing guidelines for determining if a student has a learning disability, given the recent changes in federal and state requirements that no longer mandate certain types of assessments, but do require data from evidence-based interventions to be considered. b. If RSD requires comprehensive speech and language assessments for each initial evaluation, it may want to consider whether a screening process to determine whether a more comprehensive assessment is required would be beneficial. II. RSD develop a process for reviewing eligibility and IEP processes and documentation. Some options include a. Having CO special education staff review files as they are sent to the CO; b. Having a team composed of school staff and CO staff review sample files; c. Having building level teams review files from that building. It will be beneficial for a CO special education staff member to participate so the issues that are identified throughout the district can be included in professional development activities. III. RSD develop guidelines and expectations for promoting positive behaviors among its students, which aligns with District Goal 3 of ensuring the safety and climate of each school environment. Although it may not be feasible to use a single behavioral support model in all buildings, one option may be to require schools to submit a plan outlining the steps being taken and the measurement/evaluation of these steps to support positive behavior development. Aligning these efforts with anti-bullying and other initiatives of the Safe and Drug-Free Schools program would also seem beneficial. IV. RSD evaluate its current approach for serving SWDs with significant behavioral issues (or other intensive needs). Whether the current approach is maintained or additional pullout/self-contained services are developed, resources to support schools in providing these services must be considered. One possibility may be to provide more traditional pullout/self-contained services as a transition towards supporting students in the regular classroom V. RSD provide staff training on FERPA requirements for handling confidential educational records. VI. RSD consider establishing a district-wide SWD parent advisory group which could help increase the involvement of parents of SWDs in school activities. This group will communicate ideas and concerns to the district as well as help disseminate information to other parents of SWDs.

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VII. RSD provide ongoing professional development on eligibility and IEP processes, changes in special education operating standards, behavioral support, FERPA, and other related topics to appropriate staff, including related services staff. To help build the district’s corporate identity, to promote collegiality, and for efficiency, it would be beneficial to train special education and related service staff jointly, rather than building by building. ODE is developing an online guidance document for providing special education services that should be available prior to the beginning of the next school year that could be incorporated into the trainings. One aspect of this training could focus on the options and requirements RSD has when SWDs transfer to RSD with an IEP. VIII. RSD review its student enrollment process at the CO to determine more effective methods for determining if a new student has an IEP.

Focus Area #4: Efficiency of Operations This section focuses on identifying themes and opportunities for utilizing resources, including human and material, more efficiently. The intent is not to reduce services but, through the prism of the centralized organizational framework, identify opportunities for increasing efficiency.

Themes Staff Roles. As described earlier, the current roles of the CO special education staff should be analyzed in light of the types of tasks and processes deemed necessary to support special education services. The functions of intervention teachers, intervention specialists, school psychologists, social workers, and other related services providers should also be reviewed. For example, school psychologists in some districts take on a more consultative administrative role focusing on prevention/intervention, such as collaborating with Response to Intervention initiatives. The same is true for other providers. Currently, most providers in RSD report that the majority of their time is spent on assessments. Speech and Language Pathologists indicated that a full speech language evaluation is required for every new referral, regardless of the referral question. This can require 2-3 hours of staff time per evaluation. Use of Funds. This year, RSD received approximately $1.3 million in federal special education funds (VI-B), along with an additional $19,000 (approximate) for early childhood special education. Currently, it costs approximately $17,000 annually for a student to attend Excel Academy. Using an average enrollment of 25 RSD students, that constitutes a total cost of $425,000 not including transportation. This does not take into account the number of additional students schools believe should attend a program like Excel but are not approved. Similarly, it was estimated that between $160,000 and $170,000 per year is spent on the Frontier program. It should be noted that under IDEA 04, up to 15% of federal special education funds can be used to support early intervention programs, such as IAT and RtI. Sharing of Resources. A number of individuals suggested that resources could be more effectively utilized if buildings shared resources or joined together to purchase materials. Others suggested that the CO could take more leadership in helping identify and purchase appropriate materials.

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Technology. It is reported that within RSD there are over 900 unique pieces of software in use. Some of this is educational support software that varies from school to school. Each piece of software has additional cost factors, such as maintenance, which add to the total cost of ownership (TCO) or operation. Purchasing product subscriptions or in quantity can likely reduce costs as well as help make support services more consistent and available. Ensuring that software being considered for purchase is compatible with RSD’s network would also seem beneficial. Equity among school sites was also raised. It is reported that RSD currently has 529 student computers using Windows 98 as the operating system. HAMS has 154 of these machines while RHS has none but is reported to have 529 machines using MS XP. Budgeting. To achieve equity among buildings, some respondents indicated that the CO may need to consider allocating site budgets using additional factors besides numbers of students. Different buildings may have similar numbers of students but very different needs. The current budget allocation process does not take these factors, such as poverty, transiency, and other identified factors into account which may contribute to inequity among the buildings. CO staff did indicate that discussions regarding this issue have begun. Resource Support. Currently, much of the training and support provided to RSD staff is provided at individual schools. As discussed above, this approach reduces consistency and negates the opportunity for staff to meet as a group to improve district-wide practices. It also is labor intensive, potentially requiring 11 separate trainings to be provided as opposed to one or several if done by building level. This approach also impacts the services delivered by other providers. An SST representative indicated that having fewer but more comprehensive training activities could potentially result in a wider range of service being offered since more time would be available. Special Education Information Management. Collecting, storing and accurately reporting data related to special education is becoming increasingly important. As noted earlier, the Student Services Administrative Assistant maintains the special education roster, including due dates for re-evaluations and IEP reviews. She also enters data into EMIS based on information provided by the schools on EMIS forms completed for each SWD. This appears to be a significant task requirement for this position, which also provides support for 5 other programs at the CO. EMIS staff also report manually entering some information, but indicated that it is possible that school staff could take on more responsibility for directly entering data into EMIS.

Discussion A range of potential opportunities for increasing efficiency have emerged. The first relates to staff responsibilities, both at the CO and in the schools. Under the central organizing framework, it is expected that CO special education personnel would focus more on creating core policies and procedures, identifying professional development needs and opportunities, supervising quality control, developing district eligibility and service guidelines, and other similar types of services. Additional staff, such as school psychologists, could begin to focus more on prevention

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and intervention, rather than conducting traditional assessments. Efforts could also be made to identify appropriate materials for instructional or behavioral support that schools at various levels could use, and then purchase those materials jointly rather than by individual schools. School budget allocations would also be reviewed to ensure equity among sites based on a formula that recognizes additional factors aside from number of students. Information management could potentially become more efficient by eliminating unnecessary, time consuming steps.

Recommendations It is recommended that: I. RSD review current special education staffing assignments. If the CO assumes a larger role for special education services, consistent with the central organizing framework, then specific roles or duties to consider would be: • Overall special education policy development, rollout, and evaluation; • Collaboration with other CO staff, including the Directors of Accountability, Technology, and Gifted Services to ensure policies and activities are aligned; • Managing budgets, including Medicaid; • Additional duties related to other program responsibilities. • Professional Development; • Quality Control; • RtI Support and Development; • Positive Behavior Initiatives; • Assessment; • Caseloads and Licensure; • Resource Allocation and Sharing; • Parental issues, including participating in the RSD SWD Parent Advisory Group recommended earlier; • Alternative Placements; and, • Assignment of Paraprofessionals. a. Group leaders among staff cohorts (i.e. intervention specialists, school psychologists, speech and language pathologists, and others as appropriate) could serve as liaisons for their cohorts and meet regularly with CO special education personnel to share issues arising from the field and obtain relevant information. These team leaders would then meet regularly with their respective cohorts to share information, discuss professional practices, and identify issues related to student and staff needs. This may result in CO staff needing to meet with each group only quarterly as opposed to current efforts to meet monthly. b. Under the centralized organizational framework that includes a prevention/intervention focus, school psychologists, speech and language

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therapists, social workers, and intervention specialists may develop new, less traditional roles. These individuals may increasingly serve as resource individuals supporting the prevention/intervention approach and focus less on providing traditional assessments and services if, as other districts have experienced, the number of referrals is reduced. In this scenario, more time is spent on building the capacity of teachers and buildings to meet the needs of students and less time is spent on conducting individual assessments and writing reports. II. RSD explore the possibility of recruiting student teachers and related service provider interns to RSD to complete their internships. Along with supplementing available staff time, these individuals would share the professional practices they have learned in their pre-service training programs. III. RSD develop a more centralized procurement process, particularly for academic support materials, that takes into account whether the materials are consistent with RSD’s curriculum and Ohio’s state standards, are compatible with RSD’s technology network (as appropriate), and could be used at other schools which could significantly lessen the purchase price. Collaboration among the Student Services, Accountability, and Technology departments to develop this process would be beneficial. IV. RSD consider having school personnel enter student information directly into the EMIS data base. This could eliminate the duplicative effort of school personnel completing the EMIS form and CO personnel transferring the data into the EMIS system. Similarly, it may be more efficient to have school special education staff input the data into the district’s special education roster spreadsheet as opposed to the Student Services Administrative Assistant. Collaboration among the Student Services, Accountability, and Technology departments would be required to develop this policy and to provide the necessary training. CONCLUSION As a result of this comprehensive review, a number of themes and recommendations have been generated. The majority of them focus on the role of the CO in providing leadership to the schools, as well as the relationship between the CO and the schools. RSD personnel look forward to participating in the process of helping define the role of the CO and creating an effective district identity and culture. Although many of the recommendations provided can be implemented without creating a centralized organizational structure, their impact on SWDs performance and success will be much greater if this structure is created.

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Special Education Report (June 2008)