The Coalition of Inclusive Education
13 Birchcliffe Crescent, RR#4 Orillia, Ontario L3V 6H4
Phone 705-329-3316  Fax 705-329-0479 <inclusion@encode.com>
  

 

 

 

Working for Inclusion:

Brampton Caledon
Community Living

Canadian Association
for Community Living

Down Syndrome
Association of Ontario

Early Childhood
Resource Teachers
Network of Ontario

Family Alliance
Ontario

Integration Action
Group

Lakehead Association
for Community Living

Ontario Association
for Community Living

People First
Ontario

Youth Involvement
Ontario

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.