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How the Provincial Auditor's
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You can view the Provincial Auditor's report online. |
Many of the recommendations arising from the Auditor's 1993 investigation have never been implemented. Children who were in kindergarten then are now in grade 8 - and can't afford to wait any longer. The Audit reminds us that we must not waste special education money and students' lives. (The Coalition's reactions and suggestions follow, in italics and brackets.)
This is the fourth school year since the law changed and Regulation 181/98 was initiated. The Ministry of Education must monitor and enforce the Standards it has set for:
- Individual Education Plans (IEP's), so that it is evident to the parents, and others, that students are learning and that they are getting the supports that they need to learn , and
- Annual Special Education Plans in order for taxpayers to evaluate the effectiveness of school board services.
Better IEP's!
The emphasis of the Auditor's report is exactly where the Coalition, supported by parents and educators, knows it should be: to encourage schools to commit resources in ways which promote measurable student progress. And the IEP is the tool to use to secure these commitments. (The Education Act defines "special education program" essentially as an IEP ; so it need not involve segregated placement or congregated grouping. The Coalition wants IEPs to do a better job of bringing that extra help to students within their regular classrooms of their neighbourhood schools. If students get the help they need to learn there, and teachers get the supports they need to teach them there, then we think parents will be satisfied and segregation will never be justified.)
The Auditor clearly states that IEPs must ensure support is carefully tailored to the needs of individual students. He said goals, expectations, strategies, etc. must be identified - specifically and measurably - or else there is no way to assess whether a student is successful. If goals are not met, then either the supports are insufficient or the goals must be adjusted; the planning cycle continues.
The Auditor says IEP's are "critical documents… to specify learning expectations for the student, as well as any accommodations necessary to enable the achievement of those expectations." He suggests the following ways IEPs could better "focus the efforts of the teacher, student and parent" [p. 128]:
- IEPs must be done on time to be effective especially since teacher turnover can mean inconsistency, delays and errors. The Auditor found that only 17% were done within the legal limit of 30 school days after the start of school or a change of placement. (The Coalition knows that these delays have often resulted in poor outcomes for students and even students being locked out of school.) This is unacceptable and must stop.
- The law requires parents and older students to be consulted in the process. The Auditor says "the extent of parental involvement and the quality of service generally depend heavily on the principal's approach to service delivery" Some parents told the auditor that parental advocacy is now "simply tolerated rather than encouraged" [p. 131]. (The Coalition wants this law enforced - to ecourage better collaboration everywhere.)
- Principals must ensure that IEPs specify "the amounts and types of supports/services to be provided to the student". The Audit noted that school boards are often reluctant to specify the supports/resources that are needed for the student to be successful, because they may not have the resources to fulfill such promises. (The Coalition has received legal opinion that IEPs are legally binding promises; schools must deliver the resources they say students need. According to the Ontario Human Rights Code, decisions about appropriate accommodations cannot be changed arbitrarily. But we know this makes school boards nervous. But we don't want students to be blamed if they fail because they didn't get the help they needed.) The Ministry says schools should know what resources they have to offer by the time IEPs are written each Fall. And now the Auditor has said it is wrong for schools to avoid promising help, just in case they can not deliver it. (The Toronto Catholic School Board was recently required by the Ministry to change its IEP format. A "waiver" had to be removed that was designed to avoid board responsibility for providing the supports school teams have recommended.)
- Principals are responsible by law for their professional judgment about "the relative need of each student with special needs" [p.132]. The Auditor is concerned that "the allocation of finite resources is influenced more by advocacy than by relative need" [p. 132]. All children have the right to the supports they need to succeed, regardless of the Principal's beliefs or whether their families are effective advocates. The Auditor asked the Ministry of Education to provide guidance about such decisions. The Ministry is in the midst of conducting a Program Standards Project to establish differing special education expectations for students, according to the different exceptionalities with which schools ''label'' them. (The Coalition thinks it would be very dangerous to decide how much help students need according to their exceptionality label. We wish it didn't take so much work to get what students really need, but we were relieved that the Ministry responded to the Auditor that the Program Standards they are developing "will not provide guidance to educators regarding how they should determine the level of service to be provided in individual cases''.)
- Expectations must be clear and measurable, so that the "rationale for service decisions" can be provided. Student progress must be carefully evaluated in order to know if supports are adequate and whether a placement meets the student's needs. (You can only measure success if IEP objectives are specific; the same vague goals should not reappear year after year. If the goals are not met, then either they need to be adjusted, or else supports have to be improved. If you find out what works, ensure it continues. Be cautious - because when IEP goals are not at all related to the regular classroom curriculum, it is easier to justify segregation.)
- School board trustees need to know if learning is "stable, improving or deteriorating" [p. 134]. More and more students are being exempted from Education Quality Accountability Office (EQAO) provincial testing, and the Auditor wonders why. At present, we have no way to measure how those exempted are doing. Some boards and schools exclude more students than others; so EQAO should not pretend their tests are reliable and valid outcome measures, especially to compare schools. School Improvement Plans required by EQAO should improve "special education" too.
- The Auditor accepted a recommendation of the Coalition that the Ministry and school Boards need to learn from "outcome information on students' post school education and employment success"[p. 135]. (We have suggested schools should follow students after they leave school, and ensure that those deemed "exceptional" have the same rates of employment, for example, as others. Because students who are excluded from the grade 10 Literacy Test never graduate, the opportunity is there for schools to close the door on any sort of an academic education for these students. This is already happening in some school boards. The illiteracy rate is destined to escalate above the 30% that already exists. )
- Inter-Ministerial co-ordination of professional services needs to improve. Government direction has been unclear since 1984, so that inequities continue.
Better School Board SPECIAL EDUCATION PLANS!
The Auditor said the Standards the Ministry has set for reporting will not do enough to "ensure effective oversight and management accountability for service delivery" [p. 140] because:
- There need to be "measurable goals or targets for improving programs and services and, ultimately, achievement levels for students", and
- There should be a "discussion and analysis of trends" in order to assess "the adequacy and quality of service delivery" and to establish "future goals". Statistics should be collected about student numbers and placements, the caseloads of professionals, "training requirements and the availability of personnel", etc.
And unless accountability to individual students - and their parents - improves, through better IEPs, school systems won't know how successful they are. (Educational "inputs" should be changed in ways that can be shown to improve student "outcomes". The Coalition is disturbed that segregation is allowed to continue with no educational justification. When students are supported to learn in regular classrooms, research shows that the quality of the educational outcomes is superior - so why do we need to segregate students when we know what works and what doesn't ?)
Funding
The Auditor studied four school boards intensively. Board A appears to be Ottawa Carleton Public; Board B Peel Public; Board C Sudbury Catholic and Board D Waterloo Catholic. He found great variation among the four boards investigated in terms of grants and expenditures per student, and availability of resources, but the system doesn't provide ways to judge whether this was due to differences in students' needs, or in service delivery methods.
All four boards reported that they spend much more on special education than they receive from the province - but to varying degrees, from 5.8% to 19.3% more. Overall, boards across Ontario say they spend $95 million more than they are granted for special ed. The implications of these statistics were unclear to the Auditor: Are other programs being "robbed" of funds, and what disadvantages does that involve? Are Boards spending money unwisely? Is the Ministry really underfunding special ed? These questions are unanswerable because the Ministry "does not check if boards' financial information is accurate, complete and prepared in a consistent manner" [p.147].
The Auditor thinks management and effectiveness would improve if costs were broken down for such things such as assessments, staffing, and placements. (The Coalition would not want costs to be compared according to exceptionality category) But he also sees that costs outside the special education funding envelope must be considered - such as transportation to segregated classes and schools and provincial schools - when comparing service options.
The Auditor does not address the waste, harm and many problems of Intensive Support Amount (ISA) funding, other than to say that it is complex and under review, and that documentation is a burden to special education teachers. But there cannot be a thorough cost-benefit analysis unless more information is available - about outcomes for students - than boards collect currently. (The Coalition continues to provide evidence of ISA waste and harm and to show inclusive eductaion is better - for students, schools and taxpayers. We can now remind ourselves, school boards, politicians and the public that the Auditor wants us to be better able to prove we get value for the money.)
Why continue to debate "PLACEMENT"?
The Auditor refers to the law - Regulation 181/98 - that "first choice should be integration in a regular classroom with accommodation and supports" [p. 137] (but we are alarmed that his report perpetuates misunderstandings about inclusive education. The Auditor is misinformed when he states that teachers in "integrated classes… must prepare and deliver separate lessons for each student". He says teachers are concerned about class size and about "interruptions by students with behavioural problems". We don't think he should imply that these problems are due to placement of exceptional students in regular classes, rather than the lack of adequate supports - as if there are not many sources of discipline problems! To support his statements, the Auditor cites a 1996 survey of British Columbia teachers. He fails to note a critical 1997 nation-wide research study involving the Faculties of Education at York, Acadia and Calgary, which showed that teachers do want exceptional students in their regular classrooms along with the specific necessary supports.)
He also states that the law says, "the Ministry requires that boards maintain a range of placements". (This is incorrect; there is nowhere in the legislation where this is stated.
It would have been helpful if the Auditor had examined the great variation in placement statistics among the 4 boards studied. And we know that students with developmental disabilities have fewer opportunities for inclusive placement all over Ontario)
Helping Students Means Helping Teachers
The Auditor recommends that "all teachers need a strong foundation in special education service delivery", through both pre-service and mandatory professional development [p. 141]. (We may have different ideas about what this means, but the Coalition's ALL Teachers - ALL Students Project has the same rationale - that all teachers should be better prepared to teach the students of all abilities who have the right to learn as members of their regular classrooms. We have been discussing changes needed to teacher pre-service and in-service training with the College of Teachers and many of Ontario's Faculties of Education - when teachers should learn that effective pedagogy applies to all students.)
The Auditor also heard that there are not enough experienced special education teachers and educational assistants. (We think it is important to determine how best to utilize those ''human resources'' that the Ministry IEP Standards say should be specified in student IEPs. For example, if all team members should participate in planning, they should be paid to attend meetings.)
The Auditor recommended that the Ministry make more resource materials available to school boards centrally. (The Coalition agrees that teachers and support staff need information. Finding out about students' needs, categorized according to labels such as developmental disability, autism, etc., does not help identify teaching strategies or tell you anything about the student. Parents are the best source of information, and will be able to help identify strategies that have been effective in past, but more importantly they will describe their son or daughter as an individual with strengths and capacities. No two students with an exceptionality are the same. We advocate for greater respect for individuals.)
(Coalition members hate to see time wasted on computer-generated IEPs developed for students having the same label. At best, these are not helpful and are filed awayand forgotten; at worst, they destroy educational opportunities. Research supports that it is not exceptionality-specific material but curriculum adaptation help that teachers really want - to avoid preparing separate lessons, and to ensure students learn together.)
It is imperative that the Auditor's recommendations are met, not forgotten like those from the report of 1993. The Coalition can provide those models of good practice the Auditor calls for. Our Building for Inclusion Project helps school teams avoid costly confrontation and become more collaborative. Our training shows teachers and families how to capitalize on the student's strengths; work together to prioritize related objectives; support the teacher with the curriculum challenges - and commit to the supports the student needs for success.
It is not the role of the Auditor to change public policy, but to hold the civil service accountable to do what the government says it will do. The Coalition can keep reminding schools, boards and the Ministry about the Auditor's recommendations, to improve educational opportunities across Ontario. The Coalition's projects with schools and communities unprecedented examples of good practice and enhanced collaboration. We know that inclusive education is both better for students and cost-effective; so we welcome closer examination of special education costs and practices. As the Auditor reported, the law and the Ministry of Education's Standards must be better monitored and enforced. Reality should match rhetoric. Policies must translate into practices that truly help each and every student.
For more information, CONTACT: mdolmage@inclusive-education.ca
Phone 416 531 8553 Fax 416 531 8102
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