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Analysis and Recommendations for the
Education Equality Task Force

From The Ontario Coalition for Inclusive Education

September 2002

It is imperative that the Task Force recommends fundamental change in Ontario’s funding formula concerning special education. Unlike others, it is not more money for which we ask. That alone will not achieve the change that is urgently needed.

We rarely hear concerns about the Special Education Per Pupil Amount (SEPPA). This confirms our conviction that most special education funding should be census-based, knowing the provincial grants per student each year for special education allows school boards to base long-term planning upon their overall population numbers.
It seems that Intensive Support Amount #1 is also working well for Ontario. Boards are reimbursed for prescribed, specialized equipment they have provided for individual students. Apparently, this money has never been overspent. The $800 “deductible” should be removed, and associated professional development and technical support be reimbursed, to ensure equipment is utilized well.

It is difficult for us to know what is happening with ISA #4 funding, which involves inter-ministerial cost-sharing.

ISA #2 and #3 and the Special Incidence Portion (SIP) violate all of the Guiding Principles of this Task Force, re:

  • Quality of Student Learning and Achievement
  • Equity and Fairness
  • Responsiveness to Local Needs
  • Accountability

1. Affordability

The problem is huge: essentially school boards demonstrate that increasing numbers of students are failing, while they divert millions of dollars away from the very programs that should assist them.

(For the purposes of the rest of this paper, we will refer to ISA 2 and 3 and SIP as “ISA”.)
This Task Force must clearly direct the government to stop the harm of ISA immediately, before more funds are allocated to it, this November.

Our definition of “a quality education” involves:

  • Respect for the potential and the contribution of all students
  • Maximizing all students’ learning by designing instruction to promote their strengths
  • Proof of improved outcomes – but now there are no outcome measures for students exempted from EQAO tests. (And surely improved outcomes mean guaranteeing attendance at school – as the first step!)
  • “Special education program” is defined in the Education Act essentially as an Individual Education Plan (IEP). It need not involve providing services in ways that force the congregation and segregation of exceptional students. Rather, this definition means that a variety of supports can be designed for individual students and brought to them in regular class placements.
  • The law must be respected – specifically, Education Act Regulation 181, which came into effect in September 1998 but is still not enforced.
  • The Ministry’s IEP Standards could promote accountability but must be implemented.

Quality of Student Learning and Achievement

  • ISA criteria and documentation prejudge, emphasize and encourage student failure – both social and academic. Students with developmental disabilities, with autism and with behavioural exceptionalities have been most harmed by ISA criteria.
  • Talk about failure! Some of these children are not attending school at all. Criteria that brings boards ISA $ for “behavioural” students is virtually the same as for expulsion of those kids. Boards are rewarded financially for NOT preventing and resolving problems. And then, Boards continue to get money when ISA-eligible students are not attending school – at all, or regularly or full days.
  • To meet ISA criteria, students with developmental disabilities are given assessments that may be invalid (eg outdated, not meant to predict academic performance, inappropriate for the population) and unreliable (eg at the extremes of the scale, in the first percentile)
  • Boards get more ISA funding if they limit a student’s educational programming to social and life skills. This encourages segregation. They can lose money if academics are even taught, let alone learned! Boards are also anxious to allow peers or other students to provide supports to learn through co-operative lessons, mentoring, or volunteering since it could jeopardize the perceived need for an Educational Assistant.
  • This harm is unlikely to end when this ISA Review is over. School boards are wary of ever documenting student progress, lest funding ever be threatened.
  • We warned Premier Mike Harris in 1999 that ISA is an incentive, promoting over-identification of student problems, as the research shows (Refer to Parrish and NASBE Winning Ways, and OECD) We were right, and ISA is wrong.

Equity and Fairness

  • ISA does not “respond to different needs of students” at all. It records student deficits and disabilities and dictates programming objectives. Instead, ISA actually creates more and more “need”
  • Is this about treating school boards fairly, or students? The “needs of school boards” should be the same as “the needs of students” – not at cross-purposes. Currently school boards gain ISA funding at the expense of their most vulnerable students
  • An unnecessary and harmful competition has been created between “ISA kids” (who have in no way been entitled to the ISA funds their documentation justifies) and “SEPPA kids” (who don’t really exist now) The Portability adjustments will turn this into a major problem.
  • Most Boards closed segregated schools for students with developmental disabilities 10-15 years ago. Why do they persist in Hamilton, Toronto and Ottawa public boards – the very ones with budget difficulties?
  • The Task Force should be considering the allocations, outcomes and costs of provincial schools, where students with sensory impairments may remain segregated and some with learning disabilities receive short-term help. It is inequitable that so much more government funding is available to students attending provincial schools than is ever available for them to be educated close to home – 24 hour a day care, room and board, school, and even transportation home on weekends
  • ISA exists because the Ministry says there are proven variations among school boards in percentages of “high cost” students. But Ministry comparisons are reliable and valid only if all boards have the same ability to amass such complex documentation, and only if all are equally willing to document students so negatively. ISA does not reimburse costs nor does it look at actual costs in determining eligibility.
  • The Ministry charts and graphs show variation among boards in percentages of ISA-eligible students. But the Task Force must consider numbers of ISA-eligible students too. Boards with the highest percentages may actually reflect small numbers.
  • Current provincial ISA funding would make it appear that 1.88% of Ontario students are ISA-eligible, even though only 1.12% have actually met the criteria.
  • Peter Gooch, Education Finance manager, predicted that 80% of Boards will “punch through their ceilings”, that is, demonstrate they should be getting more ISA money. Will the Ministry allocate the additional $120-150 million this involves? But it may be that many are getting more ISA funding than they deserve. Will the Ministry cut their special ed funding?

Responsiveness to Local Needs:

  • Who defines “local needs”? After all, the province is disputing school trustees’ ability to make such judgments. Kids should not bear the brunt of battles between boards and the Ministry over funding
  • “Local needs” should mean the cumulative total of all of the individual needs of students attending school in that locality. What is very clear is that students’ educational needs are not the same as ISA criteria.
  • Every exceptional student is entitled to an IEP that states individual needs and “responds” accordingly. Ministry IEP Standards could help a lot, if ever implemented.

Re: Transportation:

  • Regulation 181 requires that regular class placement be considered for every exceptional student every year. Money saved, accordingly, on transportation should be reinvested to pay for support for educational success closer to home.
  • Huge savings in transportation costs to and from provincial schools should be reallocated for every student effectively supported at home.
  • The Ministry must enforce Regulation 181, to ensure “that integration should be recognized as the norm of regular application because of the benefits it generally provides (Supreme Court of Canada decision re Emily Eaton). The Coalition knows that many families’ wishes are disregarded and support is altogether denied in regular classes, forcing segregation of exceptional students, particularly those having intellectual disabilities. And why should transportation costs be inflated in this way?
  • The Ministry must effectively monitor placement statistics in Boards’ October Reports and analyze the vast difference among boards in rates of segregation of students, in each exceptionality category.

Re: Special Education:

  • Again, “need for funding” should be determined by all the support requirements of all of the student IEPs.
  • School boards submitted Special Ed Plan reviews last July but it took more than a year for any response from the Ministry. It is unacceptable that another year’s cycle of planning and spending has occurred without feedback.
  • The Provincial Auditor has pointed out that no one can “balance need and efficiency” unless the school board can actually show that students’ goals are met and the system’s performance targets are evaluated.
  • A small proportion of the province’s current ISA funds should not revert to SEPPA but be kept as a reserve fund, to respond to very unusual local circumstances. Boards could apply for extra money under special circumstances (e.g. perhaps to make a major “deinstitutionalization” effort to return a large number of deaf or blind students home from provincial schools). Another proactive move would be to make schools accessible – pay for capital changes once and you’ll save on operating costs. Boards might also apply to the Ministry for professional development projects for systemic change. In any of these instances, a more responsive funding model would not only be educationally and cost-effective, but it would also be transparent. Trustees, SEAC, parents, and taxpayers could all be involved in planning and monitoring – to check if there was value for money.

Re School Renewal:

  • ISA is regressive. Boards are rewarded when they do not accommodate students, and problems result. Making schools accessible is a pro-active measure.
  • All Ontario schools should be free of barriers of all kinds It is better to build schools barrier-free or to invest in appropriate renovations than to keep students unnecessarily dependent on adults, such as EAs
  • The Pupil Accommodation Grant should provide grants for accessibility. This is not a special education expense.


  • It is shocking that people refer to ISA as “I’ll Say Anything”, or “I’ll Sign Anything”. Teachers have been told their job is to get the money, no matter what this means to students. The Association of Professional Support Services Personnel says it is against the codes of ethics for psychology, social work and speech pathology to describe students in ways that match ISA criteria – but thousands of such reports have been written.
  • Who checks whether ISA files contain fraudulent documentation? Most Boards have not followed the Ministry directive to inform parents even of the ISA file’s existence.
  • Because Boards get money by telling the Ministry they are providing certain supports, they can be held legally responsible to provide them.
  • But, in no way is ISA “student-focused” – at present there is no requirement that ISA money be spent on the students whose documentation met the criteria. ISA is said to be merely a “surrogate statistic” – i.e. a crude way to determine which Boards have higher costs.
  • Now that Portability measures mean that the funding must follow “ISA students” when they move from one board to another, Boards’ legal liabilities will increase.
  • The ISA model is not accountable to students, their families or ultimately to their communities – and thus taxpayers. There is no value for money – quite the opposite.
  • Only as long as there is an envelope approach, should the SEPPA special ed envelope remain “sealed”. It was inappropriate, last year, to allow boards to spend increases in SEPPA due to increased enrolment other than on special ed expenses.
  • Ultimately, however, inclusive education ends the distinction between “special” and “regular” education. Funding should be spent flexibly – for the benefit of all, without “envelope” restrictions. e.g. classroom teachers not specialists benefit from professional development money. Exceptional students might benefit from smaller regular class sizes, or more teacher planning time (as would ALL students). But there surely is a long way to go!
  • The Ministry should not give Boards greater flexibility unless it gets rid of ISA and ensures there are effective accountability measures in effect – such as true enforcement of Regulation 181 and its IEP and Special Ed Plan Standards.


  • ISA is an increasing waste of money. The Ontario Principals’ Council estimated in September 2000 that 20% of ISA funds were wasted on obtaining it. That added up to $120 million across Ontario. Peel Board estimated that ISA documentation used to cost $0.5 million a year, but rose to $2.8 million this past year, taking most of its resource staff time. Another $10 million more was allocated to school boards in the Ontario Budget last June - for ISA assessments.
  • The Task Force should ascertain how much the Ministry of Education has spent for its part in ISA. We don’t think the documenting and audits will ever end.
  • Much more money will have to be spent on legal action supported by the Education Act and Regulations, the Ontario Human Rights Code and the Canadian Charter – especially once Portability provisions begin, when ISA money moves with students.
  • It may well be that school boards need more money, but how can we ever know? ISA is a totally inappropriate measure of educational needs, and their distribution across Ontario. It burdens teachers and harms students, shaming all who are implicated.

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