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Working for Inclusion:
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Community Living
Canadian Association
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Association of Ontario
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Network of Ontario
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Ontario
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Lakehead Association
for Community Living
Ontario Association
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People First
Ontario
Youth Involvement
Ontario
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ISA funding harms Ontario Students.
STOP IT! The Ministry of Education is planning its third
"consultation" regarding parts its three year old special education funding
formula - Intensive Support Amount (Levels 2 and 3).
There are better ways to fund special education - already in use in Ontario.
- block funding based on total enrolments: Ontario pays Boards a Special Education Per
Pupil Amount (SEPPA), adjusted annually.
- reimbursing particular special costs: Level 1 ISA costs across Ontario have been
well-managed, but they reimburse School Boards for only that part of the cost of
individualized personal equipment that is over $800. Level 4 ISA somehow pays the costs of
certain segregated classes. But ISA Levels 2 and 3 have been plagued with problems .
It is to these Levels of the ISA funding that we will refer in this analysis.
ISA has meant worse outcomes for students:
- ISA documentation is less negative, more objective and more closely tied to
resource-delivery for students with sensory impairments.
- But the more students who face other challenges are shown not to be learning, not
safe, not independent nor relating to others, the more money School
Boards get.
- More and more students are thus being described in extremely negative ways. What a
terrible "outcome measure" this is - suck an indictment of Ontario's schools!
- ISA documentation does not improve instruction, and thus contravenes Ontario's new
Ontario Student Record Guidelines.
- The Ministry says ISA is justified because certain students are said to be "high
cost". That would make sense if those costs were examined, but they are not.
- The additional provincial money need not - ever - be spent to support those needy
students. In fact, if this money does help such students, their Board might lose it.
- At first, Boards were required to show they "attached" educational assistants
to ISA-eligible students. While providing extra staff is just one of many ways to provide
additional support in regular class, some students do require this. We caution that
EA's
should not be "joined at the hip with velchro" to students, but it was
irrational that the Ministry decided to "de-link" ISA funding too.
- People were misled, thinking ISA focused on the educational needs of individual
students. The Ministry backtracked, now telling parents that the ISA process is no longer
related to the determination of individual students' programs and services. The Ministry
says it is "inappropriate" for parents to have information about the ISA funding
applications made and approved in their children's names, as it may give parents
"unrealistic expectations" about resources available to their children.
- We know some Boards defy Regulation 181's requirement that regular class placement must
be considered for all exceptional students. Boards complained to the Ministry that ISA
"drove programming decisions", but really meant they wanted to control
"placement" decisions. Parents are still told there is no money for support in
regular class.
- Time and money are wasted on assessments and documentation that are, at best,
unnecessary for educational programming and, at worst, invalid and discriminatory. ISA
takes precious educational resources away from helping students - as Boards prepare for
validation process now all year.
- The ISA 2 profile for students with developmental disabilities contravenes Regulation
181, because students placed in regular classrooms will not have their "program"
delivered by a special education teacher.
- ISA documentation poisons Individual Educational Planning, and wastes the efforts made
by the Ministry and School Boards to improve IEPs.
ISA funding is neither stable nor predictable:
- The Ministry tells us that 60 of Ontario's 72 School Boards are now getting more ISA
money than they are entitled to. Political pressure has prevented the special education
cuts the provincial funding formula calls for. If the Ministry does actually begin
applying its own ISA formula, most Ontario School Boards will certainly lose money - a lot
of it. The Ministry has told us that Toronto District Public School Board gets money as if
it has almost 5500 high needs students, when last year it could show only about 2000.
- The Ministry has changed its ISA criteria every year - attempting to curb Board's
ever-increasing, seemingly insatiable appetite for more money.
- The number of ISA claims is increasing while the number of students
deemed eligible is decreasing; so the validity of claims becomes ever more questionable.
- ISA money is more and more eaten up by the costly means Boards use to
obtain it - superfluous documentation, duplicated files, internal audits, misuse of
professional consultation, etc.
- Boards might lose a lot more money in legal action over inappropriate IQ
testing, negative documentation, lack of constant, and failure to meet IEP commitments.
Boards provide the support students need regardless of funding.
- Although ISA depends on individual student documentation, the Ministry insists it funds
boards, not schools or students. What sense does that make?
- We know there are students whose documentation has brought $27,000, but who are not even
attending school - perhaps because they do not get the communication and learning supports
they need due to autism; perhaps the Board has decided to spend the ISA money on other
exceptional students instead. It should not a surprise if 10 unsupported students seek
better education by moving away, or even changing religion. How will the Board cope when
more then one quarter million dollars of ISA money moves with them?
- Since last year, ISA validation rates students for
labelled with
developmental or multiple disabilities have dropped the most. Most other groups -
with fewer affected students - have seen an increase in their validation rates. Who knows
why?
ISA funding increases the administrative burden:
- Professional support is being misused to produce negative documentation and to focus all
year on the generation of ISA funding.
- Some schools are writing duplicate report cards, or even falsifying students records.
- Boards are hiring psychologists just "to communicate diagnoses".
- They have established "SWAT teams" to conduct internal audits.
- Ministry validation costs are increasing: this year, more time was spent training
validators, and 33% of ISA claims were checked, up from 25% last year.
- Staff Support Worksheets and timetable have no relevance in determination ISA.
- Transferring ISA when students move to another board, would be very cumbersome.
- The Minister has said it is not necessary for students to have had an IPRC
to access ISA - documentation, even though there are other better, less wasteful and
harmful ways to identify needs.
ISA funding is not accountable to students:
- ISA's original premise was that "some students more expensive to educate". Now
it says: "you will get extra money but need not spend it on such students"
- ISA is based on the premise that some boards have more "high cost students"
than others. (Many Boards consider themselves to be "magnets" for students with
disabilities.) The Ministry concludes that "boards have varying costs for special ed.
programs that are not strictly proportional to total enrolment", even though ISA in
no way considers Board costs.
- If the Ministry still considers ISA data "good" and "objective", why
does it rationalize its problems by renaming it a "surrogate statistic" from
which it merely infers the distribution of "high cost students" among
Boards. Can we really trust ISA data?
- The Ministry says that Boards that had the highest rates
of valid claims the first year have fewer now, perhaps because eligibility criteria are
being applied more consistently now. Does this mean some Boards should never have such ISA
rates?
- The Ministry says Toronto District may not have tried as
hard to document ISA, since its rates were so high the first year. Should some Boards have
had even higher rates>
- We know that some educators are less willing than others
to generate negative documentation to claim ISA.
- Could there be a difference in validation rates depending on
whether all or just a "random" sample of Boards' ISA files are checked?
- The Ministry says that 2/3 of boards have more money than last year and none have less,
but the Ontario's Principals' Council has found that 20% of Ontario's schools are seeing
considerably less special education staffing support than last year.
- The Simcoe County District School Board decided to keep $1.9 million of its ISA
grant in the bank, anticipating a cut next year - while it fails to support some of its
neediest students. Must parents sue, or will Ministry intervene?
- Principals feel pressure to limit the commitments they make to students in IEP's fearing
that they won't get resources.
- ISA money is only "attached" to eligible students when they make to students
when they move to another Board.
- We wonder if more students are being labelled "multi-handicapped" because this
makes it easier to satisfy ISA criteria.
- Staff Support Worksheets done in the Spring cannot indicate how money is sent come the
Fall, when the students documented may not even be attending school.
- The Ministry knows that more younger students have valid ISA claims, especially for ISA
3. This money cannot be obtained for kindergarten students, even though it is paid for
students known to be graduating or quitting school.
- Staff Support Worksheets misled people to expect that ISA has something to do with
provision of incremental staffing - available to students in the classroom.
- The Ministry originally based ISA amounts on an "incremental cost of
staffing", but we observe a great variation and within Boards in the rate of pay for
educational assistants. (One Board cut the working hours of EA's 5 hours a week since the
province took over funding) Now we hear that ISA has absolutely nothing to do with
additional staffing anyway.
Ontario's most vulnerable students need the Provincial Auditor to look at the
harmful effects of ISA funding:
- More and more ISA money is being pad to boards. The Ministry spent $127 million more
than anticipated the first year, $30 million more the second, and now almost another $43
million more. ISA spending totals almost $600 million - almost half of Ontario's special
education spending and more than was ever anticipated.
- The Ministry does not know how this money is being spent.
- This seems like a bottomless pit. Boards keep demanding more money and keep telling
parents there is not enough. Who knows? When Boards say they are spending more on special
education than the Ministry provides, proper have concluded that "regular"
education is being "cannibalized". Such a backlash causes further harm to
exceptional students.
- Most School Boards are receiving more money than their valid ISA claims permit. Why then
keep this formula? This is a dishonest way to distribute provincial money.
- The situation will worsen. Ministry staff wonder if they need more restrictive criteria
next year - to find only the very very (very very?) high need students. Will everyone stop
caring about educating many of the students whose negative documentation justifies this
funding?
- What is the cost of the repeated "consultation" and redesign of this ISA
funding formula? It cannot be made to work, no matter what the vested interests if
Ministry staff and School Board consultants. Previous Expert Panels have been designed to
limit student and parent input.
It is difficult to describe such a complex problem simply and coherently:
- A lot of money being spent - but not in Ontario's classrooms.
- School Boards and the Ministry are locked in endless struggles that harm students.
- The Ministry expects 1% of students to be eligible for ISA, but in each of the last 3
years Boards have made claim for about 1.5% if their students.
- The variation among Boards is less than expected and may be unreliable.
- The international Organization for Economic Co-operation and Development, the U.S.
National Association of State Boards of Education, the American Institutes for Research -
all recommend that special education funding not be based on the documentation of
students' disabilities.
- We cannot continue pretending to use this funding formula, and then do not do so!
- In August 2000, Education Minister Janet Ecker said that ISA funding is "dedicated
to high needs students"; it is not. She said her Ministry id "doing a better job
ensuring that their children will get the supports they need"; ISA hinders this.
- Ontario must stop this horrible ISA Level 2 and 3 mess!
- Reimburse Boards for the full costs of personalized equipment, and not just
costs that exceed $88 as is now done with ISA Level 1 funding.
- Increase the Special Education Per Pupil Amount (SEPPA). Calculate predictable
"block funding" through research and consultation
- Ensure greater accountability - to students as well as taxpayers - by means of
honest Individual Educational Planning.
- Provide financial incentives for professional development to improve
inclusion, curriculum modification and individual support.
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