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ISA funding harms Ontario students. STOP IT!

October 2000 - Analysis and Recommendations

The Ministry of Education is planning its third "consultation" regarding parts of 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 enrollments: 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 ISA funding that we will refer in this analysis.

ISA has meant worse outcomes for students:

ISA profiles do less harm to students who have hearing and vision impairments - requiring objective measurement of their sensory losses.

But the more students who face other challenges are shown to be not learning, not safe, not independent, neither communicating nor relating to others, the more money School Boards get - such subjective descriptions

More and more students are thus being described in extremely negative ways. This increases the handicapping effect of any impairments. This terrible "outcome measure" should bring shame to 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 even when Boards say they are providing support staff  - such as hearing resource teachers and educational assistants - no one ever checks.

Because this 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. It's about disabilities not supports.

When ISA began, Boards were required to show they "attached" educational assistants to ISA-eligible students. Providing extra staff is just one of the many ways to provide additional support in regular class; EAs should not be "joined at the hip with velchro" to all students. But it was irrational for the Ministry to "de-link" ISA funding too. This has meant that the few students who do need this help might not get it.

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 all students - as Boards prepare for the 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 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 Boards' 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 consent, and failure to meet IEP commitments. Boards must provide the supports 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 this 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 this ISA money on other exceptional students instead. It should not be a surprise if 10 unsupported students seek better education by moving away, or even changing religion. How will the Board cope when more than one quarter million dollars of ISA money moves with them?

Since last year, ISA validation rates for students labeled 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 student 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 timetables have no relevance in determining 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 - but Boards are pushing for the "IPRC Statement of Needs" suggested as part of the 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 enrollment", 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 had such high ISA rates?
  • The Ministry says Toronto District may not have tried as hard to document ISA, since its rate was 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 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 the Ministry intervene?

Principals feel pressure to limit the commitments they make to students in IEPs, fearing that they won't get the resources.

ISA money is only "attached" to eligible students when they move to another Board.

We wonder if more students are being labeled "multi-handicapped" because this makes it easier to satisfy ISA criteria.

Staff Support Worksheets done in the Spring cannot indicate how money is spent come the Fall, when the students documented may not even be attending school.

The Ministry knows that more younger students have had 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 mislead people to expect that ISA has something to do with the 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 among and within Boards in the rate of pay for educational assistants. (One Board cut the working hours of EAs 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 paid to boards. The Ministry spent $127 million more than anticipated the first year, $30 million more the second, and now 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, people 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 needs students. Will everyone just stop caring about educating many of the students whose negative documentation justifies this funding?

What is the cost of repeated "consultation" and redesign of this ISA funding formula? It cannot be made to work, no matter what the vested interests of 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 is 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% of 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 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 is doing "a better job of 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 $800 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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