D89 PAEC Review

8/15/2019 D89 PAEC Review

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Maywood-Melrose Park-Broadview School District #89

Program Review and Proposal for Modification of Special Education Services Delivery

Program: Proviso Area for Exceptional Children (PAEC)

I. Program Description

School District 89 (D89) initiated a joint agreement for special education services with PAEC in1957. Other member districts are: Berkeley Sch. Dist. #87, Bellwood Sch. Dist. #88, BroadviewSch. Dist. #92, Hillside Sch. Dist. #93 and Proviso Twp. High Sch. Dist. #209.

PAEC’s Articles of Joint Agreement state that the cooperative’s purpose is, "a. [t]o determine incooperation with member school district personnel those children who may be in need of specialeducation and related services, [and] b. [t]o provide special education and related services to theeligible children who reside in its member school districts as may be defined and mandated bythe Illinois School Code.”

II. Current Program Data and Activities1

D89 utilizes PAEC specifically to provide direct educational programming to students whosedisabilities require more intensive service provision than the District presently is structured to provide in-district. The total cost to D89 of PAEC programming in FY '13 was approximately$5.7 million, inclusive of grants written over to PAEC and direct billing, discussed further below).

PAEC manages all IDEA grant funds, Medicaid, and the State of Illinois reimbursement fundsfor its member districts. The District's membership in PAEC results in nearly all of its IDEA

federal flow-thru grant dollars being dedicated to supporting PAEC programming. D89 utilizesits own personnel and funds to coordinate and implement the District's Child Find, EarlyChildhood, and proportionate share (parentally placed private student services) programming inaddition to providing direct services to eligible students whose needs can be met within theDistrict. D89 also provides its own supervisory support, training and direction to the specialeducation personnel employed by the District and does not utilize PAEC for these services.

In the 2012-2013 school year, enrollment of D89 students attending PAEC programs rangedfrom 107-117 students of 809 total D89 students with Individualized Educational Programs(IEPs). The students served at PAEC were served in the following programs and are anticipatedto be starting the 2013-14 school term at PAEC:

PAEC Alternative Program- is described as a therapeutic day school that supports students inkindergarten-eighth grade. These students have significant social-emotional challenges. D89 has placed 26 students in the Alternative Program, which has a total of 65 students. The students inthis program have no access to their general education peers during the regular school day.

1 Range based on the total number of students served at PAEC during the 2012-2013 school year.


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In order to support these students, the program has 5 teachers, 9 program assistants, a Principal,an Assistant Principal and a program secretary. The program maintains an overall student to staffratio in the classroom of 4.64:1. D89 students make up 40% of the program's attendance.

PAEC Academy- provides programming for students with mild to moderate cognitive

impairments. The program supports students in kindergarten - eighth grade. It has a curriculumdirected to functional academics, daily living, community awareness and prevocational skills.This program is housed at three schools; North Middle School (District #87) and Whittier School(District #87), both of which are public school buildings, and in St. Domitilla in Hillside, achurch building, which does not have access to students in general education programming. D89has 34 students placed in the program spread across all 3 program locations. The programmaintains a total of 91 students. The program staff is comprised of: 7 teachers, 14 programassistants, a Principal, an Assistant Principal and a program secretary. The PAEC Academy program maintains an overall classroom student to staff ratio of 4.33:1. D89 students make up37% of the program's attendance.

PAEC- Early Childhood Program- provides special education preschool classes to children agesthree through five who have developmental delays. This program is housed at PAECElementary. The program maintains a total of 36 students; D89 has no students placed in the program. The program has 2 teachers, 2 program assistants, a Principal, an Assistant Principaland a program secretary, while maintaining an overall student to staff ratio of 9:1 in theclassroom.

PAEC Center - is described as a program that addresses the needs of special education students

ranging in age from three years old to twenty one. The programs include a range of interventions

for students with Autism, Multiple Disabilities and Cognitive Disabilities. PAEC Center

programming includes prevocational/vocational training, functional academics,

receptive/expressive language intervention, large and small motor skills training, social skillstraining, community based education and daily living skills. Students in the program do not have

access to their general education peers. D89 has 46 students placed in the program, which has a

total of 252 students. D89 students make up 18% of program attendance. The program includes

27 teachers, 59 program assistants, a Principal, an Assistant Principal and a program secretary.

The program maintains an overall student to staff ratio of 2.93:1.

III. Program Progress toward Intended Outcomes

A. The June 27, 2013 special education audit commissioned by the District from Dr.

Sandi Cole of Indiana University is summarized in the following points with respectto PAEC programs:

1) The proportion of D89 students in separate school placements exceeds the Statetarget. Between 13% and 16% of the District's special education populationattends PAEC programming. The State target for out-of-district placements is3.9%.


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2) A portion of the D89 students placed at PAEC are already in classrooms housedin a public school setting, which suggests they readily could succeed in a comparableclassroom within the District.

3) PAEC provides a number of services to the District which come with

"administrative layers that seem unnecessary for District 89" and come with a cost.

Among other things, Dr. Cole recommended that most, if not all, of the students currently beingserved by PAEC be returned to the District.

B. An analysis of the ISAT and IAA testing data on students attending PAEC:

I A A

I S A T

M o v e d f r o m

I A A t o I S A T

M o v e d f r o m

I S A T t o I A A

T e s t i n g

o

u t c o m e s s h o w

r e g r e s s i o n i n

R e a d i n g

T e s t i n g

o


r e g r e s s i o n i n

M a t h

T e s t i n g

o


n o g r o w t h i n

R e a d i n g

T e s t i n g

o


n o g r o w t h i n

M a t h

T e s t i n g

o u t c o m e s s h o w +

g r o w t h i n

R e a d i n g

T e s t i n g

o u t c o m e s +

g

r o w t h i n M a t h

Total

number of

students at

PAEC in the

following

categories

54 24 2 13 8 10 41 47 29 21

IAA Assignments: Seventy eight (78) students attending PAEC facilities were required to

participate in State assessments in FY 2013 based on their grade levels. (The variance in thisnumber and the total D89 is accounted for by some grade levels not being required to test.)

Fifty-four (54) of these students took the Illinois Alternative Assessment (IAA) (69%), and 24

students took the ISAT (31%). Of the 54 students taking IAA, 27 have IQ’s in the range

suggested by the ISBE as being appropriate for IAA participation. The ISBE guidelines provide:

These students have intellectual functioning well below average (typically associatedwith an IQ below 55) that exists concurrently with impairments or deficits inadaptive functioning (i.e. communications, self-care, home living,social/interpersonal skills, use of community resources, self-directions, functionalacademic skills, work leisure, health and safety). The reference to "typically

associated with an IQ of below 55" is to help distinguish between students withcognitive disabilities and significant cognitive disabilities from students with themost significant cognitive disabilities. This means that many students with cognitivedisabilities will not qualify for the IAA.

These students may be identified under a variety of educational categories, includingCognitive Disabilities (Mental Retardation), Autism, Multiple Disabilities, andTraumatic Brain Injury.


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Analyzed IAA and ISAT scores of students at PAEC have concerning outcomes:

Of the 54 total students taking IAA, 13 of them were transitioned from ISAT to IAA uponmoving to PAEC. Of the 13 students transitioned to IAA, 10 of them moved categories to showgrowth in the following year (77%).

Reading: Overall, 10% of the students showed regression in their Reading scores while 53% of

students showed no growth (no movement shown from year to year- no movement from the level

of Exceeds, Meets, Below and Warning). Only 37% of students showed growth. Of the 29 total

students showing growth in Reading, 17 took the IAA (58%).

Math: Thirteen percent (13%) of students showed regression in Math (moving from Meets toBelow, Meets to Warning, or from Warning to Below), and 60% showed no growth in Mathscores. By comparison, 27% of students showed growth in Math. Of the 21 students that showedgrowth in Math, 16 took the IAA (76%).

C. Attendance:

A total of 117 students were considered enrolled in PAEC in the 2012-13 school year. (Thenumber of enrolled students fluctuates month to month due to students moving in and out of theDistrict or changes in a student's need for the level of services available at PAEC.) Studentsattending PAEC programs missed an average of 10 days per student. This compares to anaverage of 3.5 days absent per student attending programming within the D89.

The ISBE defines a chronic or habitual truant as, "a child who is subject to compulsory schoolattendance and who is absent without valid cause from such attendance for 5% or more of the

previous 180 regular attendance days." 105 ILCS 5/26-2a. Under these criteria, 100% of theD89 students attending PAEC would be considered chronic truants. When requested, PAEC

could not provide documentation reflecting interventions with these students or their families.

D. Individualized Educational Program (IEP) Form Compliance:

The electronic IEP records program, called Customized Relational Tec (CRT), utilized by D89 is provided through PAEC. PAEC provides all operational oversight in regard to CRT. A reviewof the IEP document CRT generates revealed several areas which could be improved to facilitateIEP Team compliance with the many procedural mandates associated with service delivery toeligible students with disabilities. The changes outlined below were requested from PAEC.

(Citations are to governing Federal regulations or the Illinois School Code.)

1) An addition of a form field for Parental Concerns. 34-CFR 300.324(a)(1)(ii).2) An opportunity to customize the CRT program's accommodation list for the

District to better support decision making by IEP Teams related to Student'sidentified needs. 34 CFR 300.324(a)(4) and 34 CFR 300.320(a)(4).

3) Inclusion of a form field to address “supports for school personnel”. 34-CFR300.324(a)(4).


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4) An addition of a check box under procedural safeguards, for notification tofamilies regarding behavior intervention policies and procedures. 105 ILCS5/14-8.05(c).

5) Form fields to guide the documentation specific to Specific Learning Disabilitiesrequired under IDEA, required as of the 2010-2011 School Year (SPECIFIC

LEARNING DISABILITY). 34 CFR 300.311.6) Space to note the location of service on the IEP. 34 CFR 300.324 (a) (4).7) An Autism eligibility form incorporating the seven areas required to be

considered under State law. 105 ILCS 5/14-8.02(b).

The above information will be mandatory to document regardless of whether or not PAEC

completed the changes requested in CRT; D89 must plan for changes if PAEC fails to act.

E. Financial Summary:

The cost to service students with IEP’s in-district for FY '13 was $6,650,062.78. In summary, itcost D89 $6.6 million to service 703 students, while 107-117 students cost $5.7 million at PAEC.

1) Audit Findings: During an ISBE audit conducted in March 28, 2013, State andFederal monitoring staff found the following reported concerns regarding fiscalreporting completed by PAEC for D89 resulting in a $89,408 loss to D89. Thesefunds are to be reduced from revenue in FY14.

i. Special Education- Private Facility Tuition- “The LEA did not report thedays enrolled of pupils correctly. The LEA overstated enrolled days for astudent at Joseph Academy- Melrose Park by 92 days. In addition,enrollment at Easter Seals Therapeutic- Rockford and Helping HandsSchool was overstated 19 days and 1 day respectively."

ii. Special Education – Personnel- “The LEA did not report the salaries of personnel claimed for Special Education Personnel reimbursementcorrectly. The LEA failed to report the full salaries paid for personnelcoded NHA (Health Aides) and NLP (Lunchroom/Playground Aides).”

2) IDEA Flow-Thru Grants: D89 is allocated funds from the Federal government to

specifically support students with disabilities. The grant funds are called IDEA

Flow-Thru funds. The funds are directly allocated to PAEC. In FY13 and

projected FY14, PAEC will have retained over 95% of the District's IDEA Flow-

thru dollars although it is providing services to only 13-14% of the District's

special education students.

IDEA Flow-Thru Grant Funds

D89 IDEA Grant Total IDEA Allocation to D89 from

PAEC

Amount Retained by PAEC

FY 13 $1,156,606 $8,554 $1,148,052 (99%)

FY 14

(estimated)

$1,091,621 $44,760 $1,046,861 (96%)


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When PAEC was asked to explain the differences in allocations given in FY13

and those projected for FY14, it was stated that the FY14 number is based on the

following formula:

Budget Allocations of IDEA FY '14District Child Count %’s Amount

87 386 15.02% $ 22,530

88353 13.74% $ 20,610

89 767 29.84% $ 44,760

92 62 2.41% $ 3,615

93 73 2.84% $ 4,260

209 929 36.15% $ 54,225

TOTAL 2,570 100% $150,000

It is unclear how the amount allocated to districts from year to year is determined.

PAEC was unable to provide a consistent year-to-year determination ofallocations. This inconsistent return of funds makes it difficult to plan and budget

for all students with disabilities.

3) IDEA Preschool Flow-Thru Grants: In addition to the IDEA Flow-Thru funds,

D89 is allocated additional funds from the Federal government in order to

specifically support D89 students with disabilities from ages 3-5. The grant funds

are called IDEA- Pre-School Flow-Thru funds. For the FY13, those funds totaled

$25,253.00. For FY14 the projected allocation to D89 is $25,256.00. No funds

were allocated to D89 from PAEC.

4) Allowable use of Allocated Funds: Federal grant expenditure restrictions are

minimal if spending is related to Special Services, allowing districts discretion on

funding usage. Fifteen Percent (15%) of IDEA grant funds are allowed for

preventative services, such as Response to Intervention (RtI) and Positive

Behavior Intervention System (PBIS.) PAEC restricts the usage of flow through

funds to instructional improvement only limiting allowable funds, thereby

necessitating the expenditure of local funds to support these preventative services.

5) Orphanage Reimbursement: Funding for students determined as “Orphans” is

reimbursable at 100%, dependent upon State allocations and funding availability.

No individual aide salaries, transportation or supply costs were entered into the

state reimbursement system by PAEC for these students for FY12 or 13, resulting

in an undetermined loss of funds for D89. There were 10 “Orphans” with IEP’s in

D89 in FY 13, Minimally, D89 is expending the average cost per student for these


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students of approximately $9,600 and these costs were lost due to PAEC’s billing

methods.

6) Parentally Placed Private School Student Services: Students with Individualized

Support Plans (ISP) whose parents voluntarily enroll them in private facilities in

our District boundaries are allocated 2% of IDEA grant funds by the ISBE.

During FY'13, those funds were collected by PAEC. PAEC requested that D89

staff (Speech Pathologists and Special Education Teachers) perform the services

outlined in the ISPs, which they did. PAEC ultimately provided D89

reimbursement for the services provided under these funds, but it took two

inquiries and until May for reimbursement to occur. Additionally, we could not

verify how PAEC monitored delivery of these services to assure provision

occurred, and no formula for how funding was determined could be described by

PAEC.

7) Transportation: Transportation payments to PAEC, by D89, totaled $464,508.00

for FY13 for students with disabilities. These payments account for students

transported to PAEC facilities and students who are transported within the district

boundaries. Daily management of concerns from families regarding pick up and

drop off is first managed by the bus company, then PAEC and then forwarded to

D89 if further resolution is necessary. This transfer of concerns often leaves

families frustrated and confused. PAEC files and receives the reimbursement for

Specialized Transportation in FY 13, this totaled: $1,347,600.

8) PAEC program costs are projected to increase 8.8% for FY14.

F. Financial Implications of District Management of Services:

The District is projected to save over $1.2 million in costs associated with delivery of services to

students with disabilities if it were to resume full responsibility for management and

implementation of all special education programming. (See below table.) This would entail

opening approximately 10 new classrooms within the district to service approximately 80

students currently attending PAEC programs.

In order to assure a full continuum of service options are available for students with disabilities,more significant placement options may still be needed. Initially it is anticipated that these more

intense needs may need to be maintained for approximately 20 students.


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District 89 FY13 Payments to PAEC: including tuition, operations and maintenance and

transportation. The below only represents payments to PAEC, not offsetting IDEA grants and

reimbursements.

$2,993,259.00

Description of Program Costs and Return of offsetting Revenue: Estimated Cost of 10 classrooms to supportapproximately 80 students appropriate for return from PAEC.

Expenditures* Revenue

Claims Coordinator of Student Services - Oversees Transportation, filesSPED Reimbursement and manages Medicaid claims $90,000.00

10 teachers for programs (Base salary of $67,000 + Maximum benefitsallotment+ Retirement- $9000 Personnel Reimbursement) $780,000.00

Speech Path (1.5) , School Certified Nurse, OT, PT, Adaptive PE,Music Therapist and Social Worker (Base salary of $67,000 +Maximum benefits allotment+ Retirement- $9000 Personnel

Reimbursement) $585,000.00

3 Behavior Specialists (Base salary of $67,000 + Maximum benefitsallotment+ Retirement- $9000 Personnel Reimbursement) $234,000.00

15 Program Aides- State Personnel Reimbursement ($4500) $399,000.00

Workers Compensation and Property Casualty Insurance Increases$18,275.00

Professional Development $25,000.00

Additional Supply, Curriculum and Material $100,000.00

Administrator of Special Programs (LEA IEP meetings and support programs instructionally.) $103,250.00

Transportation Cost for all students with Specialized Transportation-Estimated cost of 6 vans and bus aids+ 5 trips $1,347,600.00

Estimated Cost of average legal cost associated with joint agreement $15,000.00

Tuition for 20 students who are recommended to continue outside placement $800,000.00

Return of Offsetting Revenue- FY14 IDEA Pre-School $25,256.00

Return of Offsetting Revenue-FY14 IDEA Flow-Thru $1,091,621.00

Return of Offsetting Revenue- State Transportation Claim $1,347,000.00

Medicaid Administrative Claim- current claim potential per IllinoisDepartment of Healthcare $275,000.00

Cost of Programs $4,497,125.00 $2,738,877.00

Total Cost of Programs in D89 ($1,758,248.00)

Cost Savings over Cost of PAEC $1,235,011.00

*Salaries Include cost of benefits

D89 PAEC Review

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