Futures Education Audit

Embed Size (px)

Citation preview

  • 8/9/2019 Futures Education Audit

    1/24

    ffi

    LANESBORSUGH ELEMTNTARY SCHOOL

    DISTRICT

    AN

    EDUCATION

    SERVICES

    ANALYSIS

    CONT}UCTED

    BY:

    ERrrv

    EDWARDST ED.D. CCC/S-LP

    MTCHAEL NETMAN,

    PH.D,

    CCClS.LP

    SfiANNA

    DELPRETa

    M.A.

    CCCIS-LP

    Re

    sp ectfully

    S

    u b

    m

    itted

    :

    March

    2015

    i,,,,lic$h(ire(igh

    ilir..n*nii:r-v

    Sr:h0i;l

    0isiiic'"

    Hdnci.lti':lnal

    5*rvicr:s

    Analysis

    ii)?01ii

    itrt:ri::i fliiiica :ititt

    llPage

  • 8/9/2019 Futures Education Audit

    2/24

    TABLE

    OF CONTENTS

    TNTR$T}TI{:?$SN

    Executive

    Process

    Summary..

    .........,.......,3

    Glossary

    of

    Abbreviations..........

    .............3

    Glossary

    of

    Terms....

    ..............4

    Acknowle

    dg

    e

    me nts..,...

    ...,,,.........,.......

    4

    Document

    Organizotion.,,....,.,......

    ...,.,,...4

    *R$ANTUA?I$N,

    TJLTMATS,

    AND CULTURE

    Overview...

    Findings.....

    Re comme

    ndations

    ............

    STAPFTNS

    Findings,....

    .............73

    Recommendations

    ...............75

    S${"}RCHS

    &N$

    RfrS${JRCHS.."..".

    .""""...".."...."."."}7

    AppHs1sicfis".".........."

    ....".."......"."".x*

    krrcsht.;t'ottgir

    ilr:m*nia:

    y

    Slht>iil

    ilisliitl liclur;:litll-:ai

    S*rvir:r:s

    ilnai- sis-

    6;2i)

    1 5 i:r:ti.r

    res

    t

    Juc;i

    lirirt

    2lPage

  • 8/9/2019 Futures Education Audit

    3/24

    T*--**-*^-*----'

    I

    rxrcunvE

    PRocEss

    SUMMARY

    i

    The leadership

    of the

    Lanesborough

    Elementary

    School

    District

    (hereafter, referred

    to

    as

    the

    Dis

    commissioned

    this

    review

    of

    specific

    areas of

    special

    education

    service

    delivery

    that

    support

    strug

    learners. ln conducting

    this

    analysis,

    the

    review team

    employed

    proprietary methodology

    from

    a

    established

    paradigm

    (i.e.,

    an

    Educational

    Services

    Analysis),

    which

    triangulates

    information

    gleaned

    f

    qualitative

    and

    quantitative information.

    More

    specifically,

    the

    qualitative

    analyses

    comprised:

    (1)

    a

    seri

    interviews with

    special

    and

    general

    education

    teachers,

    related

    service

    providers,

    paraprofessionals,

    ce

    office administrators,

    and

    school-based

    administrators;

    (2)

    a

    review

    of documents

    (i.e',

    lEPs)

    to

    asce

    the degree

    and

    appropriateness

    of

    educational

    programming and

    services;

    and

    (3)

    site

    visits

    to

    Dis

    programs

    to

    ascertain

    the

    continuum

    of

    services

    and

    programs.

    Quantitative

    analyses

    included

    multidimensional

    analyses

    of

    information

    contained

    within the

    lEPs;

    (2) comparative

    analyses

    of

    staffing

    corresponding

    workloads;

    and

    (3)

    historical

    financial

    data

    pertaining

    to

    special

    education

    program.

    GLOSSARY

    OF

    ABBREVIATIONS

    ARI:

    Availability

    Rotio

    lndex

    CST: Child

    Study

    Team

    FAPE:

    Free and

    Appropriote

    Public

    Educotion

    FTE: Full-time

    equivolent

    IEP: I

    ndividualized

    Educotion

    Progrom

    LRE: Least

    Restrictive

    Environment

    OT: Occupationol

    Theropist

    or

    occupotional

    therapy

    services

    PD:

    Professional

    development

    Rtl:

    Response

    to

    lntervention

    S-LP: Speech-Language

    Pathologist

    or speech-language

    pothology

    services

    SWDs: Students

    with

    Disabilities

    GLOSSARY

    F{J"TLJ R*[

    S

    J}.U-GS"]AQ"N

    GLOSSARY

    OF

    TERMS

    Effectiveness:

    The

    degree

    to

    which

    the

    services

    under

    review

    promote optimal

    educationaloutcomes

    student access

    to the

    curriculum.

    Efftciency:

    The degree

    to

    which

    the special

    education

    services

    and

    personnel

    under

    review

    are

    responsi

    uniformly,

    and

    optimally

    utilized

    to ensure

    District

    resources

    are

    being

    expended

    in

    a

    fiscally

    sound

    manner.

    i..ar:trhi,r'r.rrIi:

    iitlctiir:::r::i

    Y

    il:ltrrr:l

    l-) sl iii: irliuriltiiill.''l

    ilal"victrj

    Ailililisi:;

    r:.rr:lili:-il$rij|i):il:liiii:sliJl:

    3

    |f

    elf

    g

    e

  • 8/9/2019 Futures Education Audit

    4/24

    I

    IACKNOWLE

    DG

    EM ENTS

    The

    authors

    wish

    to acknowledge

    District

    staff and school

    personnel.

    This

    project

    necessitated

    a

    great

    amou

    of effort

    in facilitating

    logistics

    and

    in

    securing documents;

    the team

    is

    grateful

    for the efforts

    of

    the st

    who

    helped

    facilitate the

    process.

    Throughout

    the entire

    process,

    the

    cooperative

    relationship betwe

    Futures

    and the

    District

    has enabled

    the team

    to

    work

    with

    District

    leadership in

    a collegial

    manner

    order to maximize

    the

    benefits

    of

    this analysis for

    the

    District. Futures

    team members are sensitive

    and focused upon,

    the

    ultimate

    objective

    of the

    project:

    To support the

    District leadership

    and

    stakeholde

    inattainingitsgoalsandtoimprovetheefficiencyandeffectivenessofthedeliveryofeducational

    services.

    I

    DOCUMENT ORGANIZATION

    The

    staff

    of

    Futures

    is

    pleased

    to

    provide

    this report

    of

    the comprehensive

    analysis of the

    programs

    and

    servic

    conducted

    in

    November

    of

    20L4.

    The

    primary

    purpose

    of

    this analysis

    is

    to describe,

    and to

    provi

    suggestions

    to

    improve,

    specific

    areas

    within

    its

    education delivery

    system

    that

    include:

    r

    Financial

    reports

    and data

    o

    Student

    performance

    and

    achievement

    data

    e

    Student

    placement

    data

    o

    Student

    identification

    (eligibility

    and

    declassification)

    data

    r

    Service delivery

    data

    including the

    types,

    duration,

    frequency,

    location, and

    grouping

    of

    studen

    o

    Staffing

    models

    and

    benchmarking

    (Futures'national

    database

    and similar districts

    will

    referenced

    as to benchmark

    staffing

    levels)

    o

    Rtl data and

    other

    information

    for

    special

    education referrals

    and

    subsequent identification

    rates

    o

    Caseloads

    and

    workload

    analyses

    of instructional, and related

    services staff

    o

    Correlation

    analyses

    o

    Professional

    development

    -

    topics, frequency,

    participation,

    etc.

    These

    ten

    components

    are

    considered

    with

    respect

    to:

    Orgonization, Climote,

    and Culture, Continuum

    Supports,

    and

    Stoffing.

    ln turn,

    each

    component

    is considered

    with

    respect an Overview,

    Findings, a

    Recommendotions.

    The

    report

    concludes

    with

    a

    global

    consideration

    of the delivery

    system and those

    k

    recommendations

    District

    leadership

    may consider

    as

    part

    of

    its

    short- and

    long-term strategic

    plannin

    t..-

    iOVERVIEW

    The

    authors

    intentionally

    begin

    this

    document

    with

    a consideration

    of the cultural

    capacities of, and

    within,

    special education

    delivery

    system.

    The reason for this

    is

    that

    without

    the

    requisite

    positive

    leadership

    4lP;rgo

  • 8/9/2019 Futures Education Audit

    5/24

    mindsets,

    all

    of

    the

    forthcoming

    recommendations

    concerning

    the

    programmatic

    and

    fiscal

    enhancem

    will have

    less

    potential

    for

    successful

    implementation'

    FINDINGS

    rn

    generar,

    those

    interviewed

    indicated

    that

    "ownership"

    of

    students

    with

    disabilities

    was

    quite high

    amo

    adults

    within

    the

    school.

    This

    was

    characterized

    as

    having

    improved

    across

    the

    District

    over

    recent

    years' T

    was

    arso

    cited

    as

    an

    area

    in

    which

    the

    District

    had

    "worked

    hard"

    and

    made

    significant

    progress,

    albeit

    w

    some

    remaining

    vestiges

    of

    "your

    kid-my

    kid"

    thinking.

    Moreover,

    there

    were

    reports

    of

    a

    "disconnect"

    that

    gen

    education

    telachers

    ieported

    get,,push

    back"

    from

    speciar

    education

    staffto

    participate

    in

    lar

    meetings

    or

    activitles;

    for

    example,

    sPED

    teachers

    tend

    not

    to

    go

    on

    field

    trips'

    when

    it

    would

    be

    an

    id

    time

    for

    them

    to

    work

    with

    gen

    education

    staff

    to

    herp

    students

    generarize

    strategies

    and

    behaviors'

    As

    per

    the

    educationar

    environments

    presented

    in

    Tabre

    1

    berow,

    the

    resurts

    of

    the

    data

    as

    it

    relates

    keepings

    swDs

    in

    the

    general

    education

    environment

    is

    mixed'

    ln one respect'

    the

    District

    is

    doing

    a

    go

    job

    keeping

    students

    ii trre

    generar

    education

    environment,

    as

    88%

    of

    all

    students

    with

    disabilities

    (swD

    are

    in

    the

    general

    education

    environment

    for

    at

    least

    40%

    of

    the

    day

    as

    compared

    to

    the

    state

    rate

    of

    78

    Alternatively,

    within

    that

    subset,

    the

    number

    of

    swDs

    spending

    at

    least

    80%

    of

    their

    day

    with

    the

    regu

    crassroom

    is

    onry

    50%;

    this

    is 9%

    ress

    than

    the

    state

    averag"

    ,nJ

    10%

    less

    than

    the

    state

    target'

    This

    la

    finding

    is consistent

    with

    the

    need

    to

    bolster

    co-teaching,

    which

    is

    a

    theme

    in

    the

    continuum

    of

    suppo

    section

    of

    this

    document.

    Table

    1:

    Educational

    Environments

    Relatedly,

    there

    was

    reported

    to

    be

    a

    high

    degree

    of

    understanding

    on

    the

    part

    of

    staff

    and

    parents

    w

    respect

    to

    the

    concepts

    of

    free

    appropiiate

    puf,ric

    education

    (FApE) ind

    reast

    restrictive

    environment

    (L

    This

    refrects

    the

    hard

    work,

    knowredge,

    and

    dedication

    among

    ail

    rEp

    stakehorders

    to

    ensure

    "parent

    partners."

    However, per

    report there

    is

    a small,

    yet

    vocal, cadre

    of

    parents

    that

    expect

    special

    educa

    services

    to

    go

    beyon

    d

    oppropriate.

    perhaps

    in

    corroboration

    of

    the

    rearity

    of

    this

    vocal

    minority,

    members

    reported

    that

    "the

    squeaky

    wheel

    may

    get

    the

    grease"

    in

    reference

    to

    receiving

    more

    associated

    services

    than

    those

    who

    do

    not.

    rt

    is specurated

    that

    this

    crimate

    of

    special

    education

    being

    ,,onry

    game in

    town,,

    is correrated

    with

    the

    high

    speciar

    education

    rate

    of

    23%

    (i.e.,35%

    higher

    than

    state

    average),

    which

    is a

    topic

    that

    shall

    be

    expounded

    upon

    on

    the

    next

    section

    of

    the

    document'

    i..:li:i:shi,ili:.sil

    [l;:;lti::l

    i:i;1

    "

    ii.r:ii)

    i

    :.1

    ii\ri:ii

    f .:.i

    iir:ii:c;

    Iii

    :t:

    iilii,rri

    l-):slril:i

    ii':i

    LiIi'ttitrii:ii

    iiil-uir:cs

    Analysi:;

    5lllagc

  • 8/9/2019 Futures Education Audit

    6/24

     

    Most respondents

    expressed

    that

    the

    quality

    of

    the

    professional

    development

    opportunities

    that had be

    provided

    was very

    good

    to excellent; this was all

    the

    more

    appreciated

    given

    the staffs

    understanding

    the

    fiscal constraints faced by

    the District.

    With that

    said, a desire was

    expressed

    to

    ensure

    that

    all

    st

    were

    "hearing

    the

    same thing"

    with

    reference

    to content.

    i

    RECOMMENDATTONS

    ln

    order

    to

    provide

    the

    requisite

    balance between

    site-based

    management

    of

    special education servic

    and

    district support,

    provide

    the

    principal

    with

    a

    "special Education

    101" refresher

    session

    at

    the

    beginni

    of each

    year

    and

    institute

    a special education

    strain

    of

    professional

    learning

    during regularly

    schedul

    leadership meetings.

    (this

    is

    not a complete

    sentence) This

    capacity building

    model will

    allow

    the

    princip

    to

    take on a

    more active

    leadership role

    with

    special education

    and

    provide

    him/her

    with

    ongoing

    jo

    embedded

    professional

    learning and

    support.

    Such topics

    should include

    strategies

    to:

    Ensure

    all

    SWDs

    have opportunities

    to

    experience

    maximal

    Least Restrictive

    Environment

    (LR

    interactions with typical

    peers;

    Build

    instructional staff's

    knowledge regard

    ing inclusiona

    ry

    education;

    Align

    the continuum

    of services;

    Provide additional supports to new

    teachers;

    Ensure

    that

    building

    leadership

    understands

    their

    role

    in

    attending

    IEP

    meetings

    as

    the

    Distri

    representative; and

    Create

    heightened

    consciousness

    of

    the

    fiscal

    costs

    of assigned

    services and

    programs

    at

    eac

    school level.

    r

    As

    part

    of an expanded

    initiative

    to increase

    parent

    participation

    in

    the

    IEP

    process,

    the District

    shou

    consider

    inviting

    parents

    to a

    series

    of

    open,

    candid

    conversations regarding

    topics

    pertaining

    to

    speci

    education law

    at

    both

    the

    school and

    District

    level.

    Furthermore,

    to support

    representative

    paren

    engagement across

    the

    District, it may be

    beneficial

    to have

    the

    school-based PTO

    president

    work

    conjunction

    with

    principals

    to identify a

    parent

    stakeholder in

    special

    education.

    r

    As mentioned

    previously,

    some

    parents

    do not

    understand

    the educational

    model of services,

    the lega

    standards

    of

    FAPE

    and

    LRE, and the

    standard

    of

    required vs.

    beneficial for

    candidacy for

    special

    education

    services.

    This lack of understanding, coupled with

    the

    beliefs that special education

    services

    are

    "the

    onl

    game

    intown" and "more

    is

    better,"

    is

    contributingto

    manyacrimonious IEP

    meetings.

    Therefore,

    as

    pa

    of

    a community outreach

    initiative-perhaps

    within

    the

    context of

    SEPAC

    meetings,

    clarity

    of

    roles

    i.,r+ricsbirrr:*gh

    lilcn;:nl;::-y

    Srlil--i;l 0isirici: [i$

    t,rtli*r:.':i St:-vil*s Antl"tisis

    qril$1

    li

    l"rrtr;

    r:s

    ll :liic;:iiiirl

    6l$)age

  • 8/9/2019 Futures Education Audit

    7/24

    ffi

    responsibirities,

    and

    educationar

    mission

    of

    schoor-based

    service

    provision

    need

    to

    be communicated'

    this

    manner,

    parents

    and

    other

    stakehorders

    in

    the

    community

    wiil

    be

    further

    educated

    about

    school-bas

    services

    that

    wi,

    presumabry

    add

    to

    the

    camaraderie,

    coregiarity,

    and

    mutual

    agreement

    among

    all

    stakeholders regarding

    the

    appropriateness

    of

    services'

    ln

    addition,

    as

    part of

    its

    long-range

    plan,

    District

    leadership

    may

    consider

    an

    intensive

    community

    outrea

    initiative

    about

    Response

    to

    lntervention

    (Ril)

    components

    required

    in

    general education

    to

    addre

    learningneedsasa"firststep,"versusthemodelof"waitingtofail"withasubsequentreferraltospecial

    education.

    rn this

    manner,

    the

    pubric wiil

    understand

    speciar

    education

    is

    the

    last

    -

    not

    the

    first

    -

    resort

    educationar

    teams

    to

    consider,

    as

    a

    variety

    of

    supports

    exist

    at

    each

    schoor

    to

    maximize

    student

    learni

    and

    avoid

    fairure

    earry

    on

    by

    providing

    tor

    ir'e

    individuar

    needs

    of

    students

    in

    general

    education'

    rn

    order

    to

    maximize

    pD

    resources,

    a

    cohesive

    approach

    for

    both

    generar

    and

    special

    education

    teach

    that

    crearry

    identifies

    teacher

    expectation

    for student

    rearning

    and

    achievement

    is

    recommended'

    T

    approach should include

    and

    specify

    a

    collaborative

    procesJand

    the

    interdependency

    of

    general

    a

    speciarized

    instruction,

    which

    shourd

    be

    based

    on

    curricurum

    standards

    and

    evidence-based

    data

    for

    resu

    in student

    rearning.

    Furthermore,

    this

    approach

    wourd

    ailow

    opportunities

    for

    the

    general

    and

    spe

    educators

    to

    ensure

    effective

    crassroom

    instruction

    and

    estabrish

    a

    revorving

    door

    whereby

    specializ

    instruction

    fiils

    in

    the,,individuar

    rearning

    gap"

    for

    students

    who

    arso

    then

    require

    less

    service'

    l

    recommendedthatsuchtrainingincludethefollowing:

    o

    The

    role

    of

    each

    teacher

    and

    related

    services

    staff

    o

    Meaningful

    classroom

    modifications

    and

    accommodations

    (using evidence-based

    dat

    demonstrate

    imProved

    lea

    rning)

    o

    General

    and

    special

    educator

    teaching

    models

    o

    Effective

    utilization

    of

    special

    education

    support

    services

    in

    the

    classroom

    o

    Techniques

    for

    prioritizing

    and

    accommodating

    instructional

    curriculum

    goals'

    objectives'

    assessments,

    etc'

    oHowtowritemeasurable,educationally-directed,andinstructionally-alignedgoals

    and

    objectives.

    ln

    order

    to

    ensure the content

    validity

    of

    these unified offerings the special

    Education

    Director

    might

    dire

    survey

    facurty

    with

    the

    principar

    in

    order

    to

    identify

    and

    promote

    meaningfur

    pD

    opportunities

    to

    prom

    the

    competencies

    of

    staff

    in

    meeting

    the

    needs

    of

    all

    students

    with

    disabilities'

    ,rlrtsha11.) .irihLiir.'ii:i:;li:::l]'ili:i.ti]UIl-ii:;iriliiI'lLitiltil)ll;''ii$srvici'iAn'*r\is

    TlFage

  • 8/9/2019 Futures Education Audit

    8/24

    I

    I

    OVERVTEW

    Although

    the

    term

    "continuum

    of

    services"

    is

    associated

    with

    special education, it

    is

    useful to broaden

    definition

    to

    "continuum of supports"

    because

    it

    can

    be used

    to conceptualize a

    system

    of

    instructional

    programmatic

    provisions

    for all students

    (i.e.,

    students

    with

    and without

    disabilities).

    ldeally,

    continuum

    provides

    programming, personnel,

    and resources

    to

    appropriately

    address

    the educatio

    needs

    of students

    in

    the

    general

    education

    classrooms;

    or,

    if needed, in

    special

    education

    progra

    designed

    to be closely

    integrated

    with

    the

    general

    education

    environment.

    I

    i

    FTNDTNGS

    Supports

    Through General Education

    r

    As

    part

    of this

    analysis,

    it

    was

    necessary

    to

    focus

    on

    the District's Response

    to lntervention

    (Rtl) process

    and

    procedures

    as a

    general

    education intervention

    to

    support

    students who are

    struggling

    to succeed

    school

    academically

    and

    in

    other

    areas.

    The

    Rtl

    process,

    although

    not

    typically

    a

    special educatio

    responsibility,

    has a significant

    impact on the frequency

    of referrals of

    students for

    evaluation

    for

    spec

    education

    eligibility.

    An effective

    Rtl

    process,

    or other

    general

    education

    intervention

    or support option

    can minimize the

    need

    for referral to

    special

    education

    because students are receiving

    the

    support they nee

    to

    be

    successful

    in

    school.

    Per report,

    early

    intervening

    procedures post

    (universal)

    Tier 1

    supports takes the form

    of the Child Stu

    Team

    (CST) process,

    and

    is a

    "work in progress."

    Although

    there exists a standard

    document to

    genera

    referrals

    (i.e.,

    an

    NL),

    there

    is no

    outcome data-so there

    is no

    firm information

    used to determine when an

    why

    a referral for

    full

    assessment

    should

    occur. lt

    was noted

    by one

    interviewee

    that CST is not fu

    developed within the school, that

    it needs fine

    tuning, and

    that it

    can be

    hard

    forteachers to

    understand

    th

    the

    first intervention

    is in

    the

    classroom

    (as

    opposed

    to

    someone else being responsible).

    Because

    the

    ear

    intervening

    process

    has

    changed

    in

    name and

    processes

    recently,

    this

    appears

    to have created mor

    confusion and skepticism among staff.

    A

    review of 10

    referrals

    emanating

    from the

    CST

    process

    revealed

    the following

    were

    lacking

    with respect

    to

    (1)

    the

    measurability of

    purported

    interventions;

    (2)

    the linkage

    between

    the

    stated

    need

    for

    furthe

    evaluation and

    content-validated

    assessments/screens;

    (3)

    a

    specific description

    of

    the weaknesses

    (e.g

    speech sounds,

    their

    contexts, and developmental norms);

    and

    (

    )

    specificity

    of

    how

    these

    purported

    nee

    areas

    were affecting the students

    access their

    general

    education

    curriculum.

    Although there are a

    number

    of

    reasons why a special

    education

    population

    may fluctuate

    (e.g.,

    a

    plethor

    of SWDs moving

    into

    a

    district,

    more

    stringent

    entrance

    criteria,

    etc.) one of the

    general

    "meta" indicator

    of

    the overall

    success

    of a

    District-wide Rtl is to

    compare

    the

    special

    education

    population

    across

    time.

    A

    BlPago

  • 8/9/2019 Futures Education Audit

    9/24

    @

    analysis

    of

    the

    data

    reveals

    that

    the

    current

    special

    education

    population

    of

    2o'8%

    compares

    to

    its

    rate

    16,%in2o7O_2OLr

    and

    L3.8%

    in

    2004-200s

    ittre

    year

    that

    R,

    was

    introduced

    as

    a

    federar

    mandate)'

    T

    trend

    data,

    of

    an

    increa

    se

    of

    SL%in

    the

    rast

    ten

    years and

    Z3yoin

    the

    rast

    five,

    is

    astounding

    especially

    in

    vie

    of

    the

    purpose of early

    intervening

    processes'

    Eligibility

    Practices

    with

    respect

    to

    the

    rEp

    review,

    a

    main

    component

    to

    determining

    the

    presence.of

    an

    educational

    disabi

    incrudes

    the

    findings

    from

    a

    comprehensive

    set

    of

    assessments,

    oiten

    including,

    but

    not

    limited

    to'

    cogniti

    testing,

    achievement

    testing,

    and

    speech/ranguage

    testing.

    nttt'rougr''

    the

    federar

    raw

    does

    not

    specify

    normative

    testing

    terms

    what

    qualifies

    as

    an

    .ir.rtionrt

    oisauiiiiv

    or"*hr,

    qualifies

    a

    student

    for

    specializ

    instruction,

    a

    commonry

    accepted

    criterion

    of

    standardized

    scores

    faring

    1.5

    standard

    deviations

    below

    t

    mean

    (with

    the

    mean

    equaring

    100

    with

    a

    standard

    deviation

    oi

    rs

    rt.narrd

    points)

    indicates

    that

    a

    disabi

    may

    be

    Present.

    rn

    consideration

    of

    this

    standard,

    the

    educationar

    ream

    exhibited

    inconsistent

    adherence

    when determin

    erigibirity

    for

    academic

    services

    and

    quarification

    fo*p..irt

    education'

    of

    particular

    note

    was

    substantiary-sized

    group

    of

    students

    rzz'of

    40)

    for

    whom

    the

    information

    presented

    in

    the

    IEP

    did

    not

    supp

    erigibirity

    for

    speciJrized

    academic

    instruction

    (i.e.,

    standardized

    scores

    were

    not

    1'5

    standard

    deviatio

    berow

    the

    mean

    or

    rower

    and

    no

    other

    deficits

    were

    described

    to

    substantially

    impact

    the

    student's

    ability

    accessthecurriculum)orwasinsufficienttoadequately,,ppontheneed.Thereweremanyinstancesin

    which

    achievement

    scores

    did

    not

    substantiate

    the

    need

    for

    academic

    services.

    rn

    many

    circumstances'

    th

    findings

    reveared

    soridry

    average

    skilrs.

    ln

    other

    instances,

    the

    rEps

    were

    devoid

    of

    any

    achievement

    resu

    and

    thus

    did

    not

    adequately

    support

    stated

    academic

    needs'

    r

    Related service

    providers

    reportedly

    do

    not

    use

    particular

    guidelines

    or

    eligibility

    criteria'

    but

    a

    combina

    of

    standardized

    scores

    and

    clinical

    judgment.

    There

    is

    a

    feeling

    from

    some

    team

    members

    that

    too

    m

    students

    have

    been

    found

    to

    quarify

    for

    speech

    and

    ranguage

    slervices.

    This

    perception

    is

    corroborated

    the

    data,

    which

    shall

    be

    explicated

    in

    the

    Stol/rng

    section

    of

    this

    report.

    r

    consistent

    with

    the

    aforementioned

    data

    of

    nearly

    21%

    eligibility

    for

    special

    education'

    it

    was

    reported

    dismissar

    can

    be

    a

    fairry

    easy

    procesr,

    .nd

    that

    parents

    and

    team

    members

    are

    generally

    supportive

    of

    recommendation.

    others

    reported

    that

    students

    are

    kept

    on

    caseroad

    too

    long,

    and

    that

    there

    alw

    appeared

    to

    be

    ,.something

    more,,

    that

    could

    be

    addressed.

    one

    team

    member

    noted

    that

    there

    are

    stud

    oncaseloadgettingarticulationintervention,mostlyatparentinsistence'

    t

    n-District

    I

    nst

    ucti

    o

    n

    a

    I

    P

    ra

    cti ces

    r

    consistent

    with

    the

    aforementioned

    LRE

    data,

    the

    majority

    of

    instruction

    for

    SWDs

    is accomplished

    v

    traditionar

    resource

    moder,

    whereby

    students

    reave

    the

    gen"r.r

    education

    crassroom

    to

    receive

    targ

    instruction.

    However,

    by

    raw,

    a

    oistrict

    needs

    to

    provide

    a

    fuil

    continuum

    of

    instructional

    supports

    that

    be

    inclusive

    of

    co-teaching

    and

    targeted

    instruction

    in

    the

    general

    education

    environment'

    i,iittr:ihf

    i

    i:liSh

    ijlr'ln+\]:ill'l'

    'xi'i1i--ljl

    ilislt'ilt

    I*tilLiiirrti']l

    ''i$r\:il*'i

    Antl sis

    ::::i.liiil.llit:ir.::l::llLii:i:;:ri:ill:

    9l

    l}*g{}

  • 8/9/2019 Futures Education Audit

    10/24

    Co-teaching model is operationally

    defined

    as

    an "integrated

    teaching model"

    in which

    a

    content expert

    (i

    a

    general

    education teacher) and a strategy

    expert

    (i.e.,

    a special

    education

    teacher) taking

    joint

    instruction

    responsibility

    of an academic course. Co-teaching

    can

    be

    an extremely

    effective

    Rtl

    intervention.

    ln

    effective

    co-taught

    classroom,

    student

    needs

    can be

    met through

    the implementation

    of varied

    teachi

    methods

    and strategies thereby

    promoting

    student

    achievement

    (i.e.,

    optimizing

    horizontal

    alignment) in

    general

    education setting

    without the need

    to

    identify

    students

    as having

    a disability

    to

    receive

    support.

    Despite its

    pedagogical

    value, co-teaching is implemented

    sporadically across

    the

    District. The

    prima

    reasons

    that were cited were

    logistical

    (e.g.,

    lack

    of

    time).

    Consequently, a

    student

    'lumps"

    to mo

    restrictive

    environments

    as soon

    as

    they are identified

    given

    the

    absence of a well-articulated

    inclusiona

    (i.e.,

    co-teaching

    and/or targeted

    instruction

    within

    the

    general

    education

    classroom)

    options.

    With

    respect to the

    related

    service

    providers

    (RSPs),

    there

    appears

    to

    be a

    mixture

    of

    pull

    out and

    push

    in,

    the

    perception

    of teaching staff

    that

    integrated

    services

    is dependent

    upon

    the

    scheduling

    issues

    of

    the

    RS

    I

    nrconnMENDATroNs

    Response

    to

    lnte rve ntion

    It

    is

    suggested that

    District

    leadership revisit

    the District-level

    plan

    to re-introduce

    Rtl

    as

    a

    priority

    area

    part

    of a

    strategic

    framework.

    lt

    is

    recommended

    that

    the message

    be

    clearly

    and

    consisten

    communicated that one of

    the

    primary purposes

    of

    Rtl is

    to

    ensure

    that

    special education eligibil

    decisions are

    not

    the

    result

    of a student's lack of

    access to research-based

    instructional

    practices

    behavioral

    supports

    and

    interventions.

    lt

    is

    suggested, in

    order

    to

    ensure

    that the

    Rtl process and

    referra

    emanating

    from that

    process,

    that the

    following

    become

    part

    of the modus

    operandi:

    No less that 10-12

    weeks

    of interventions

    shall take

    place (as

    per

    the

    recently

    submitted ex

    and entrance criteria).

    Screening

    tools should

    have

    construct

    and content

    validity

    (i.e.,

    not

    just

    occur

    as

    informa

    observations or screens).

    Referrals

    need

    to

    be

    specific

    with

    respect

    to

    the

    description of

    the

    concern

    in

    reference

    t

    developmental

    norms

    and the

    linkage

    of how

    the deficit

    areas impact

    the student's

    access

    t

    the

    curriculum

    as

    a

    key consideration

    for

    special

    education

    (if

    the deficits do not

    impact th

    student they

    will not

    qualify

    for

    special

    education

    and thus a time-intensive

    evaluation

    proces

    will

    yield

    a

    decision not

    to

    qualify

    the student

    in any

    event).

    A description of how specia I education

    services,

    if deemed

    appropriate, will

    support the

    studen

    in

    a

    manner that interventions

    in

    general

    education

    cannot.

    Rtl interventions should never

    exceed

    IEP

    intensities,

    and therefore

    should not

    exceed

    3

    minutes

    per

    week.

    i,lrncsh*rr.ru$h iLl,r:lrrr:i:;r-v

    ilclxrtl

    iJisi;

    jir

    lili.r.:;itii;r il S$rvicr.;

    Analvsis

    ii: l$

    1

    ii

    iiulrlr::; lli;:ii:.:ililiIl

    10lP;r*-c

  • 8/9/2019 Futures Education Audit

    11/24

    rn order

    to

    increase

    schoor-based

    capacity,

    awareness,

    and

    imprementation

    of

    the

    Rtl

    framework

    th

    foltowing

    i,

    ,rgg"rt.o,-ai

    ...r'

    ,.r'oor-*ii.

    ,l"tine,

    l:.:,,:jin

    all

    staff:

    (1)

    data

    on

    how

    students

    ar

    performing

    in

    core

    inrtrr.tion

    (Tier

    1)

    as

    we,

    as

    those

    ,...iring

    .oditionar

    instruction

    and

    support

    in

    Tie

    2and

    3;

    (z)

    the number

    of referrars

    for

    *,,

    ,na

    ir,"

    ,.esurtant

    numii,.

    of

    raro.nts

    referred

    for

    a

    special

    educatio

    evaluation;

    and,

    (3)

    professionar

    rearning

    "op"nr^,,,es

    avaitanle

    to

    buird

    capacity

    to

    problem-solve and

    us

    data

    to

    make

    instructionar

    changes

    ro

    ,rppli

    student

    rearning

    and

    accereration

    on

    core

    standards'

    ln

    order

    to

    support

    the

    consistency

    of

    Rtl

    across

    the

    District,

    it

    is

    strongly

    recommended

    that

    principals

    "ro

    up,,

    their

    Rtr

    data

    ,nJ*

    their

    monthrv

    *..,ing,

    to

    share.th.ir

    i.a,

    *iir,

    each

    other.

    As

    with

    the

    scho

    based

    meetings,

    these

    can

    be

    a

    poweriri

    ,iringuoard

    oiscuss

    student

    achievement,

    monitor

    stude

    progressonbenchmarkassessments'andtosharebestpracticesasagroup'

    .

    As

    part

    of

    the

    parent

    outreach,

    continue

    to

    educate

    parents

    on

    the

    continuum

    of

    supports

    outside

    t

    singurar

    purview

    of

    speciar

    education

    or";;;;;nJ

    p.rron,',"r.

    rn

    ir,lr

    ,'nner,

    further

    understanding

    will

    fostered

    to

    ensure

    that

    parents, advocatJs,

    and

    other.orrrniiy

    members

    correctly

    view

    special

    educati

    as

    just

    one

    option

    arong

    a

    continuum

    ,o.rppon

    a,

    rearners..

    rn

    particurar,

    this

    imporiant

    communication

    w

    herp

    attenuate

    irr-wi,

    ai

    ihose

    tEp

    ,..tinil"*r,"r.

    ,or.

    stat

  • 8/9/2019 Futures Education Audit

    12/24

    Figure

    1.

    Utilization

    of the

    "Step

    Down"

    from

    an lEp

    Student A

    Acli.tltt trc sYSTEtt4s

    rre*

    S

    arre.*ir.,

    tfidiyidurt

    ,nttryertioni

    r

    lndivtdrai

    Biudent$

    r

    Asw*s*snt-b*$s.,

    r Hitll

    lrtensity

    r

    0{

    lon*sr

    .ruratisfl

    :rax

    2

    r*r.6*.*.1

    {}rsuF trlrqrwnrtsn*

    -

    sdfte $cud**

    t*t-ai9k)

    r

    Hteh erffclency

    f,

    R*p;d r*$ >on$s

    ,r*o 1

    ao.*

    ,ns*ucrisn6l

    intG.@nti6nx

    r,Al,

    *t {tanrs

    a

    Pr#entlvs,

    prsacdve

    Stud6fi*s

    Stude

    EEHAVI{}R.AL

    $YSTEM$

    164

    $

    tnte.*tv*,

    ltdividuit

    lnrervemi*ns

    .

    ]rdi$ldrql

    $srdonu

    r

    Assct*sr*nt-t

    aktl

    a

    Iti*sr}*e.

    d{rrshl* prs(e

  • 8/9/2019 Futures Education Audit

    13/24

    IovERVr;w

    For

    the

    purposes

    of

    this

    section,

    Efficiency

    is

    operationary

    defined

    as

    the

    degree

    to

    which

    the

    personnel

    un

    review

    are

    responsibry,

    uniformry,

    and

    optimorty

    ut,ized

    to

    ensure

    District

    resources

    are

    being

    expended

    i

    fiscotty

    sound

    monner.

    A

    cororary

    concept

    to

    a

    discussion

    of

    efficiency

    is

    Return

    on

    lnvestment

    (Rol)'

    Ro

    best

    defined

    as:

    A

    performonce

    meosure

    used

    to

    evoluate

    the

    efficiency

    of

    an

    inu.estment

    or

    to

    compare

    efficiency

    of

    o

    number

    of

    different

    investments.

    To

    carcurate

    iot,

    the

    benefit

    (return)

    of

    on

    investmen

    divided

    by

    thecost

    this-r".iion

    wi,

    consider

    that

    benefit

    againit

    the

    number

    of

    staff

    devoted

    to

    the

    positions

    compared

    to

    other

    Districts

    the

    authors

    have

    analyzed'

    Tothisend,thepersonnelunderreviewavailabletosupportSWDswasgaugedbybenchmarkingthenumbe

    of

    fur_time

    equivarent

    (FTE)

    staff

    members

    to

    this

    overail

    in-Districispecial

    education

    population

    o

    students

    (as

    per

    the

    most

    recent

    data).

    rn

    essence,

    this

    statistic

    is

    an

    "availability

    ratio

    index

    (ARl)" and

    allo

    an

    equivarent

    comparison

    of

    other

    districts

    with

    respect

    to

    staffing

    from

    a

    "macro"

    perspective'

    Altho

    numbers

    of

    staff

    typicaily

    vary

    widery

    from

    state

    to

    state

    and

    disirict

    to

    district,

    a

    recent

    report

    from

    urban

    speciar

    Education

    Leadership

    coilaborative

    Education

    Deveropment

    center,

    rnc.

    reveals

    an

    import

    benchmark:

    speech-language

    pathologisis

    (115:1);

    psychologists

    (248:1);

    occupational

    therapists

    (469

    and

    physical

    therapists

    (1015:1)'

    The

    authors'

    data

    ba'e

    suggest"

    ]no'"

    liberal

    staffing

    modelfor

    spe

    ranguage

    pathorogists,

    occupationar

    therapLts,

    .nd

    physicar

    therapists

    with

    the

    caveat

    that

    these

    specia

    also

    vary

    significantly

    from

    District

    to

    District'

    with

    respect

    to

    effectiveness,

    this

    was

    triangurated

    utifizing

    a

    murtitude

    of

    sources

    including

    a

    review

    of

    l

    interviews,

    and

    inferential

    statistical

    analysei.

    The

    subsequent

    commentary

    section

    considers

    the qualita

    variables

    of

    the

    analYsis'

    iffiirues

    Comparative

    Dota

    Table

    2.

    Current

    FTEs

    Aooss

    Disciplines

    't.f,l.si-rriir-)l.i{il

    liiclli::liiiil

    ili:hilt:i

    l-iisi:i'icl

    ijtl*c:lliIt::li

    ii$rYir':g:l

    An*lysis

    ,ii)ii1:-i

    irtrli.:l

    i:li

    i:i,:iii.,ri:iiJl:

    13

    |

    p

    A

    g

    f

    Special

    Education

    Teachers**

    Speech

    Language

    PathologY

  • 8/9/2019 Futures Education Audit

    14/24

    School Psychologist

    700-1,000:1

    (all

    students)

    **Note

    the special education teochers ratio

    includes

    o numerator

    of

    35, bocking

    out

    Speech Only studen

    Commentary

    Special Education Teachers: Currently,

    the

    pre-school

    teacher

    has 5

    SWDs. ln

    effect, when

    the

    pr

    numbers

    are

    backed

    out,

    the

    ARI

    for

    the K-6

    special

    education

    staff

    is

    8.8:1,

    which

    is

    4 %

    more

    hig

    staffed than

    the

    expected ARI

    of

    L5:1.

    Paraprofessionals: As indicated in

    Figure 2

    below,

    the ARI

    for

    para-professionals

    of 3:1 represents

    m

    than twice the most

    generously

    staffed District

    in Massachusetts

    the authors

    have

    analyzed. lt is nota

    that

    two

    para-professionals

    who

    actually

    serve as

    general

    education

    para-professionals

    are

    funded

    fr

    special

    education. The removal

    of these 2 FTEs,

    only

    changes

    the

    ARI

    by

    .46

    to

    3.46:1.

    Figure 2. AR for Paraprofessionals

    Aross 13 Districts

    in Massachusetts.

    Note

    that Northampton is

    t

    most

    generously

    staffed with an ARI

    of 6:1

    1t

    F"

    3

    I

    ffiffiwffiffiffiffiffiffi

    "--

    ..,-'d

    -*.-"*tr

    ,c$e

    ,*rnd

    *r,r$

    ---*s

    -,'.*r"

    ---

    -"""-

    -"J

    l,:1lirslr*:"i:Lisli

    lik:*rr':rir,:i v

    Srhool

    l-)isii ir:t iLiiri.nti{J1ii:i ll*rvicfs

    An*lysis

    t:.?$

    i-i

    irr:i::.ire:;

    FjrJric;:iilr:

    14lIlag*

  • 8/9/2019 Futures Education Audit

    15/24

    s_Lp

    and

    or:

    The

    twice

    as

    many

    staff

    as

    expected

    is

    directly

    correlated

    with

    practice

    patterns'

    Eigh

    percent

    of

    SWDs

    ,...r"

    S-LP

    services-eithei

    as

    a

    primary

    or

    related

    service-and

    this

    compares

    to

    a

    expected

    range

    of

    40-60%.

    ryT'

    or:

    13d'

    in

    the

    students

    receiving

    s-Lp

    supporrs

    through

    504

    and

    R

    23%of

    the

    entireschoor

    popuration

    receives

    speech-rangrr*.

    ruooorir.

    rr'ir

    is

    an

    ararmingry

    high

    numbe

    astO%would

    be

    considered

    a

    more

    typical

    number'

    As

    excerpted

    from

    the

    rEp

    review,

    the

    tendency

    towords

    over

    quarification.within

    the

    reroted

    servi

    domains

    of

    s-Lp

    oni"o,

    ,rrnds

    o,t

    os

    the

    most

    striking

    "'n'd

    ""ai'd

    by

    the

    analysis'

    Quolitati

    analyses

    of

    the

    oforementioned

    cohorr

    rt

    ,irlrru

    "Y:.?.l.d,a

    substantiolly'sized

    group

    for

    whom

    t

    informotion

    present

    in

    the

    current

    rcp

    ,uTpoiJi

    ietigiairity

    (i.e.,

    standordized

    scores

    were

    less

    thon

    stondord

    deviotions

    berow

    the

    meon

    ori

    no

    other

    deficit,

    irie

    described

    to

    substantially

    impoct

    t

    student,s

    abitity

    ro

    oJrrrr

    rne

    curriculum)

    or

    wos

    insufficient

    to

    adequotely

    support

    the

    need'

    ltisnotablethattheoTprovideswhole-classpush-inservicesattheyoungergrades.

    schoor

    psychorogy: considered

    as

    a

    whore,

    the

    psychology

    staff

    of

    .5

    FTE

    (the same

    professional

    is

    designa

    as

    a

    .5

    counseror)

    is

    in

    the

    much

    more

    g.n.rorrtv

    staffed

    ,..nr"

    In

    .o,'prii'on

    to

    the

    Notional

    Associatio

    School

    psychotogists(NAsp)

    recommend"i

    ,rai"

    range

    of

    t,ioo

    ,"

    i:1OOO

    students

    (generar

    and

    spe

    education).

    rt

    is

    notabre

    that

    that

    the

    ,.r,ooiprv.r'oroeiit

    is

    arso

    '..ro"rr,ur"

    for

    chird

    study'

    Rtl'

    and

    commu

    building.

    '

    [;'"t'il,il:lm:*';J:::,:#[:;T,?J:ffi'i,"#;;;ffi1"'"e

    "'oent

    independence

    rherer

    the

    District

    may

    consider

    adding

    quantitative

    prliL"].-:{or

    e'gibirity for

    paraprofessional

    supports'

    ln

    manner,

    further

    parity

    and

    equarization

    of

    access

    to

    service-s'zrr

    u"

    ensured

    for

    the

    students

    across

    District,

    irrespective

    oi

    tft"

    level

    of

    parental

    or

    legal

    advocacy'

    As

    per a

    best

    practices

    modus

    operandi,

    the

    District,s

    ,'defaurt'moderwi,

    be

    to

    assign

    paraprofessiona

    teachers

    and

    programs

    and

    not

    to

    ,p..rn.

    students.

    If

    paraprofessionar

    supports

    are

    deemed

    nece

    beyond

    the

    progrJmmatic

    assign,n.n,

    oii^.

    paraprofess'#;[;

    ;commenoeu

    that

    objective'

    measur

    and

    expricit

    rEp

    goars

    specifying

    .orrurponJ,ns

    trn.lionut

    ,t

    itt,

    that

    will

    allow

    attenuation

    (if

    not

    com

    discharge

    of

    the

    paraprofessionar

    suppJris)

    be

    incruded

    as

    a

    featured

    component

    of

    the

    IEP'

    The

    author

    provideDistrictleadershipwithasamplerubricthatencompassesalloftheseparameters'

    .

    The

    District

    re-caribrate

    criteria

    for

    s-Lp,

    or,

    and

    pr services.

    rt

    is

    recommended

    that the

    related

    s

    providers.onr.n"-,o

    review

    this

    documen,,o

    .nrure

    ttrai

    ati

    of

    trre

    stakehorders

    agree

    on

    the

    req

    criteria,

    thereby

    ensuring

    their

    equitauf

    ,ppii.r,ion.

    lt

    the

    outset,

    this

    document

    should

    focus

    on

    the

    b

    issue

    of

    whether

    or

    not

    a

    student

    ;;;;

    ;r.,fy

    for

    tr-nv-or'rru

    rerated,

    services

    based

    on

    func

    educationarperformanceandperforr;;;;.riandardizedtei,riru*'"protocols

    may

    be

    amended

    to

    s

    the

    intensity

    of

    service

    derivery

    urr"J-on

    the

    variabr.r;i;;;'efiect(s)

    of

    the

    disability

    on

    aca

    RECOMM

    EN

    DATIONS

    It

    is

    axiomatic

    that

    the

    "true"

    number

    olp?raejof-e-s1oi::?

    "i:::i[l1.t#:iff:LT'i"lll[;l:::::?i:H

    i...,1;q. .'1r1

    t:i5i:

    iiir:t:lc;rl:il'"r

    i-irll''*l

    li:si::

    ir'i

    iliiriiiliirll:'ii

    S*iuir:+:;

    i1nll\'sis

    iitr?ii:l:i

    lilrii]r..

    lli:iii(il:illi)

    15

    |

    i)

    *

    y;

    tl

  • 8/9/2019 Futures Education Audit

    16/24

    ffi

    performance,

    and

    the

    nature

    of

    the

    educationalcurricula.

    ldeally,

    this

    document

    will

    incorporate

    guidelines

    from

    the

    state

    of

    Massachusetts

    as

    well

    as

    best-prac

    deemed

    to

    be

    paramount

    by

    the

    District.

    The

    document should

    be

    amended

    to:

    (1)

    specify

    the

    intensi

    servicedeliverybasedonthevariablesof

    age,effect(s)ofthedisability

    on

    academic

    performance,

    and

    nature

    of

    the

    educational

    curricula;

    (2)

    specify

    roles

    and

    responsibilities

    in

    conjunction

    with

    o

    educational professionals

    and leadership;

    (3)

    and

    assure

    that

    i.:1

    treatment

    is

    reserved

    for

    the

    nee

    students'

    The

    authors

    have

    provided

    District

    leadership

    with

    examples

    of

    criteria-guidelines

    for

    th

    services,

    and

    are

    available

    to

    assist

    as necessary.

    i,i,]l

    )

    cshr

    r

    l i) ri$h

    Lile

    rili::r ia:.y

    .li:h$*

    I

    Ll

    isl:.ili

    iiri tii::l tir

    r tit

    i

    S.;

    rr.iltts

    .,1

    niilvsi

    s

    ,r.

    .1$

    l

    :i I

    r inr

    (

    rr

    fl,:iii,:,r;:ii,r:

    16lli*ger

    The

    rising

    costs

    of

    special

    education

    across

    the

    country

    and

    the

    state

    are

    well-documented.

    ln

    the

    District,s

    c

    however,

    expenditures

    devoted

    to

    special

    education

    are

    growing

    at

    an alarming rate

    and,

    although they

    essentially

    at

    the

    state

    average

    as a

    percentage

    of

    the

    operating

    budget (19.9%),

    thecurrent

    model

    makes

    growing

    trend

    unsustainable.

    This

    trend

    data

    is

    presented

    in

    Appendix

    c.

    clearly,

    the

    rising

    financial

    cost

    special

    education

    are

    not

    in

    anyone's

    best

    interest:

    not

    the

    general

    education

    students, parents,

    or

    community'

    More

    importantly,

    these

    expenditures

    are:

    (1)

    being

    devoted

    to

    students

    who

    may

    not

    need

    spe

    education

    services

    (due

    to

    over-identification,

    a fragmented

    Rfl

    process,

    and

    a

    culture

    that

    special

    educatio

    the

    only

    means

    of supporting

    struggling

    students);

    (2)

    are

    not

    necessarily

    affording

    students

    FApE

    in

    the

    LRE;

    a

    (3)

    supporting

    an

    extraordinarily

    generous

    staffing

    model

    across

    virtually

    all

    disci[lines.

    The

    sustainability

    of such

    resources

    aside,

    the

    District

    does

    need

    to

    take

    immediate

    action

    in

    order

    to

    change

    culture

    of

    unrealistic

    expectations

    among parents,

    capacity

    of

    staff,

    and

    unity

    of

    purpose

    among

    educators

    support

    all

    learners in

    the

    most fiscally and programmatically sound manner

    porribl..

    The

    authors

    re-prese

    the

    seminal

    recommendations

    that

    District

    leadership

    may

    consider

    as

    part

    of its

    long-range

    plan

    in

    order

    address

    the

    seminal

    issues

    deemed

    of

    particular

    import:

    1'

    Re-calibrate

    Ril

    as

    the

    "first line"

    of supports

    for

    struggling

    students.

    2'

    Expand

    the continuum

    of services

    to include

    co-teaching

    and

    other

    inclusionary

    models.

    3'

    Re-calibrate

    entry

    and

    exit

    guidelines

    for

    the

    related

    service providers

    and

    paraprofessionals

    th

    adhere

    to FApE,

    LRE,

    and

    educationalbenefit.

    4.

    Consider

    reductions

    in force.

  • 8/9/2019 Futures Education Audit

    17/24

    ffi

    2009).Guidelines:PhysicalTherapyScopeofProctice(Scopeof

    Practice)'

    ntt'i"utO't'om

    APTA:

    www'apta'org

    ^--^tnnA

    choracteristics

    Retrieved

    from

    ASHA:

    fflertsatt

    t

    rrre'--.

    ^r

    r,^m APTA:

    WW\

    L,ja$a.utF. _ ,_-.^r {,^m ASHA:

    :

    "::*:::',:"::r;:,

    ^ffi

    10)

    s

    -r

    p

    ca

    s

    e

    t

    o

    a

    d

    ch

    o

    ra

    cte

    r i

    stics

    Retrieve

    d

    rro

    m

    As

    eof

    www'asha'org

    '-^'

    ^\

    c'aao nf Proctice

    in

    speech

    Langu

    American

    speech

    and

    Hearing

    Association.

    (2010).

    scope

    of

    proctice

    in

    speech

    Language

    PothologY

    (scopt

    Practice)'

    **n"utd

    from

    ASHA:

    www'asha'org

    Americans

    with

    Disabilities

    Act

    (ADA)'

    42

    U'S'C'

    Sections

    LL1:OL

    -

    t22L3

    "

    '^^AE\

    qtonded practices

    for

    teaching young

    student:

    "t""o},i

    ,*ro.Bloomington'

    lA:

    Nation,l

    Eoucattv'

    :ticor

    guide

    for

    educational

    leaders

    (4th

    e

    Essex,

    N.

    L'

    (2008)'

    School

    low

    ond

    the

    public

    schools:

    A

    proc

    BostOn,

    MA:

    Pearson

    EduCation'

    lnc'

    . a rr,^hcira of the

    Day

    5/19/09

    ,.,,.,:'::J;',

    "ffi"

    ;"*::,":::::::"-:::J"o'''le

    o*he

    Dav

    s/1el.e

    Friend,

    M'

    (2013)'

    lnteractions:

    Collaboration

    Skills

    for

    School

    "",'*"'L::rv

    lj

    h"i-i

    lrrsii

    {Ji

    Ii rii:ri:i'Jii:)1

    5(luiiJ:;'\niilt\is

    l':il1';r:,;.,:'i,,,,'.,,',""

    17lP

    a

    gt:

    ffi::].::.:,

    il:

    -

    I[il;,il;;1'-

    a

    "no'a

    prac'iices

    ror'Ieach

    ns'"':-

    ]:-":"

    :-*ff

    ;.:mH*m-;,ff

    ff

    :"ar

    a

    nd

    speciar

    Education

    corraboration

    I

    n

    Forum

    u.s.

    Department

    of

    Education'

    t"'*:;^:.-',.

    (2006,

    May/June

    2006).

    Afour-step

    proces

    Clayton,

    J',

    Burdge'

    M''

    Denham'

    A"

    Kleinert'

    H'

    L''

    &

    Kearns'

    J'

    accessing,n.

    e"n"rrtcurriculum

    r""r;r;;;itrr

    signitffir"i'""

    o'"0;;;'

    Teachins

    Excepil

    Students'38(5)'

    20+'

    Coleman,M.R.(2001).Survivingorthriving:2lgiftedboyswithlearningdisabilitiessharetheirschoolstories.

    Gifted

    Child

    TodaY

    '2413\'

    56-53'

    r-^+, art nphind:

    ln

    search

    of

    equity

    for

    all

    Donlevy,

    J.

    (2002)'

    Teachers,

    technology

    and

    training:

    No

    Student

    Left

    Behind:

    ln

    se

    stu

    de

    nts''

    """'

    *i"'

    t

    l

    o

    u'

    n

    o

    t

    of

    ''

    n''ir

    u,jnr)

    ot

    M'

    d

    i

    o'

    29

    13)'

    257

    +'

    DuFour,

    R'

    &

    Eaker'

    R'

    (1998)'

    erof

    eslio'n'l-l

    earning

    *:'u"::'"7's

    t

    workt

    Best

    proctices

    or

    enhancing

    stud

    o chi

    v

    e

    me

    n''

    t""rn'

    t*ton'

    lA:

    N

    ationa

    I

    Ed

    ucation

    Se

    rvtce

    --:-^t

    ntirlP for

    educational

    leaders

    (4th

    e

    Professionals'

    Lynne

    Cook'

    Catifornia

  • 8/9/2019 Futures Education Audit

    18/24

    ffi

    U

    n iversity,

    Dom

    ing

    uez

    H

    i lls

    Gallagher'

    s'

    A"

    &

    Gallagher

    J.

    J.

    (2002).

    Giftedness

    and

    Asperger,s

    syndrome:

    A

    New

    Agenda

    for

    Educati

    nderstanding

    Our

    Gifted.

    L4,l_1.2

    Gartin'B'

    c''&Murdick'N'

    L'

    (2005)'

    lDEA2004:

    The

    rEp.

    Remediarondspecioreducation,26(6),327+

    L'

    H'

    (2005)'

    No

    student

    Left

    Behind:

    opportunities

    and

    threats.

    The

    Journor

    of

    Negro

    Educotion,

    T4(2),

    5+.

    Hall'

    s'

    (2007)'

    NCLB

    and

    IDEA:

    optimizing

    success

    for

    students

    with

    disabirities.

    perspectives

    on

    Longuag

     

    nd

    Literacy,

    33(1),

    35+.

    Hang'

    Q'

    &

    Rabren'

    K'

    (2008)An

    Examination

    of

    co-Teaching:

    perspectives

    and

    Efficacy

    rndicators

    Remediat

    pecior

    Education

    september/october

    200g

    30:

    259-26g.

    Henderson'

    A'T"

    &

    Mapp'

    K'L'

    (20a4'A

    new

    wave

    of

    evidence:

    The

    impact

    of

    school,

    family,and

    comm

    onnections

    on

    student

    achievement'

    Nationat

    center

    for

    Famiry

    &

    community

    connections

    with

    sch

    ustin,

    TX:

    southwest

    Educationar

    Development

    Laborat

    ory.

    '

    -

    vv"""u"'.Li

    Huefner'

    D'

    s'

    (2008)'

    Updating

    the

    FAPE

    standard

    under

    IDEA.

    Journorof

    Law

    and

    Education,

    j7(3),367+.

    Hughes,

    caroryn,

    et

    al.

    ""

    They

    Are

    My

    Best

    Friends,,:

    peer

    Buddies

    promote

    rnclusion

    in

    High

    schoor."

    TEA,HTNG

    Exceptionar

    students31.5

    (1999):

    32_g7.

    Hyatt,

    K.

    J.

    (2OOt). The new IDEA:

    Chan

    42(3),731,+.

    r'rs

    'rtvv

    rrrEA;

    Lnanges'

    concerns,

    and questions.

    lntervention

    in

    school

    and

    clinic,

    lmber'

    M''

    & van

    Geel'

    T'

    (2010)'

    Educotion

    Law (4thed.).

    New

    york:

    Routredge.

    rndividuars

    with

    Disabiritie

    Act

    (IDEA),

    at

    20

    U.S.C.

    Section

    l,a}t

    G)

    e2).

    '"''''J"1;,I;'*''flfr,ffi::j'.|,?;:1',1;ll,ilililj.lting

    Regurations

    at

    34

    c

    F

    R

    section

    300

    2

    (1s)(

    Jameson'

    J'

    M"

    &

    Heufner,

    D'

    s'

    (2005).

    "Highly

    qualified"

    special

    educators

    and

    the

    provision

    of

    a

    fre

    ppropriate

    public

    education

    to

    students

    with

    disabilities.

    Journar of Low

    and

    Education,35(r),29+.

    t''"'I;l;

    i;:;:';r';,

    (200s)'

    rhe

    New

    ,DEA:

    A

    summary

    or

    signiricant

    rerorms.

    Notionat

    Association

    "'o';lj::;:r::::?r{i:rt.every

    teacher

    shoutd

    know

    obout

    .DEA

    2004

    taws

    and

    resutations.

    Boston,

    MA

    Lancsbt;r'$r:gii

    Iler11*r:Iarv

    il,:iriir:l

    llislrirt

    [i*u*;ltii:nrl

    Suruicss

    Ana]vsis

    ,:.?)(i

    I S Ir:iiil

    i::;

    h.,:iilc,ii

    i{rri

    '

    ut

    L:L''ir,irr'ri

    ru{

    t'

    lBfP*5,"e

  • 8/9/2019 Futures Education Audit

    19/24

    McConkey,

    R.,

    Dowling,

    s.,

    Hassan,

    D.

    and

    Menke,

    s'

    (2012), Promoting

    social

    inclusion

    through

    Unified

    sp

    for

    youth

    with

    intellectual

    disabilities:

    a

    five-nation

    study.

    Journal

    of

    lntellectual

    Disability

    Researc

    Means, J.

    (2006). The

    impact

    of

    IDEA

    04 and

    NCLB

    on

    speech

    and

    language

    related

    services:

    How

    do

    we

    m

    thechallenges'ForumonPublicPolicy:AjournaloftheoxfordRoundToble.

    Mele-McCarthy,

    J.

    A.

    (2007). Approaches

    to

    assessment:

    IDEA

    and

    NCLB'

    Persp

    ectives

    on

    Languoge

    ond

    Lite

    33(1),25+.

    Moore_Brown,

    B.

    (2004). Becoming

    proficient

    in

    the

    ressons

    of

    No

    student

    Left

    Behind.

    perspectives

    on

    sc

    Based

    lssues,

    5(1),

    7-10'

    Moore_Brown

    Barbara

    case

    in

    point:The

    Administrative

    predicament

    of

    speciar

    Education

    Funding.

    Journ

    Special

    Education

    leadership'

    (20L1)Vol

    14'

    No'1

    Murer,

    Eve.

    Reading

    First

    and

    speciar

    Education:

    Exarnpres

    of

    state

    Lever

    coraboration' lnForum

    Department

    of

    Education,

    Washington,

    D.C.

    (August,

    2007),

    Murray,

    c.

    &

    Pinata,

    R.

    (2009).

    The

    importance

    of

    teacher-student

    relationships

    in

    adolescents

    with

    high

    incidence

    disabilities'

    Theory

    into

    Practice'

    46121

    NationalEducationAssociationwebsite,www'nea'org

    National

    Institute

    on

    Disabilities

    and

    Rehabilitation

    see

    lnstitute

    on

    Disability

    and

    Rehabilitation

    Research

    (.www. ed.gov/a

    bout/offices/list/osers/nidrr/index'html)'

    Notional

    lnstructional

    Materials

    Accessibility

    Standard

    Report.

    U.S.

    Department

    of

    Education,

    Washington

    D.C.

    (October,

    14,

    2004)'

    occupationalTherapyinschoolsettings'(2010).Retrievedfromwww.aota.org

    parent

    lnformation

    Research

    center,

    (2006).

    lnvolving

    parents:

    Best

    practices

    in

    the

    middle

    and

    high

    school.

    Rehabiritation

    Act

    of

    L973,

    section

    504.

    United

    states

    Department

    of

    Education

    (http://www'ed'gov)

    Sacker,A.(2002)'socialinequalityineducationalachievementandpsychologicaladjustmentthroughout

    childhood:

    Magnitude

    and

    mechanisms.

    Socio

    I studies

    and

    Medicine'

    55'

    863-880'

    Shuman,D.(2004).AmericanSchools,AmericonTeachers:/ssuesandperspectiyes,Boston,MA:Pearson

    Education,

    lnc'

    Various

    documents

    from

    DESE

    l-:ii:cih(tia-}t*h

    iji{:l:1i'i}i:iil

    1'

    Sih$i:;l

    lJis::

    ir:i

    iiiricctiut:;:l

    Strlvil*s

    Analysis

    rit:?$lliiitrllll:::;lir:ittc;t::iiit

    Lgl

    P

    a

    g

    Cl

  • 8/9/2019 Futures Education Audit

    20/24

    iiiiir.,.li

    :

    :;1i

    ,tl;Nt;:';ir

    i

    'r

    ':=l

    '

    r ,

    :

    .

    i,.r41,l:-rrj.r

    i:

    :

    rr.:.::

    :: :.:.:..:: t:

    ,

    tt.r t,r.1:ir:.:i

    iLi::::

    'lfit

    Jb

    ii,t::],.:,

    t,

    ?|i;ff:,|

    ilil:i.ti:l*,,;;rlii\.t,,1

    t.f:i'

    :::r.:

    CentralOflice

    1 1

    Special

    Educotion Teochers

    t

    4

    General Education

    Teochers

    2

    2

    Specia

    I

    Ed

    u cation

    Paro

    professiona

    I t

    L

    Spe

    e

    ch

    -

    La

    n

    g

    u

    a

    g

    e P atholog ist

    2

    Occupotional Therapist

    1

    Principol

    L

    Psychologist

    L

    ReadingTeocher

    t

    Totals

    10 9

    1,3s1'5f 1yr.ru5h Hr:rne::

    i;,rr

    y

    Srhi'ri;l

    i-iistriti

    Ii

    Lirati{}n;,}i

    Ssruicts

    A ni}lvsis

    lu?01

    li irutlri:.t

    Eiiui:a

    i:iiirt

    20lPag*:

  • 8/9/2019 Futures Education Audit

    21/24

    Reldted

    Services

    o

    Quantitative

    and

    qua'tative

    anaryses

    of

    45

    rEps

    reviewed

    direct

    and

    indirect

    service

    time'

    servic

    delivery

    models,

    goals

    and

    ouj".ti,",,

    and

    internal

    consistency

    of

    information

    pertaining

    to

    th

    relatedserviceareasof,p"".r'-r,ng,,gepathology(S-LP)andoccupationaltherapy(oT).Whileth

    analysis

    technically

    included

    pr,vri..Lit',"rrpy

    (PT), th;

    "*prt

    included

    only

    one

    student

    with

    services.

    rnformation

    greaned

    trom

    tr,.

    .n.iyr",

    wiil

    assist

    in

    the

    deveropment

    of

    recommendatio

    intended

    to

    facilitate

    program

    effectiveness,

    enhance

    student

    achievement,

    maximize

    stude

    learning,

    and

    capitalize

    upon

    staffing

    and

    cost

    efficiencies'

    o

    An

    anarysis

    of

    the

    schoo's

    utirization

    of

    service

    moders

    within

    s-Lp

    and

    or

    reveals

    a

    healt

    distribution

    of

    service

    minutes

    ,.ro*

    the direct

    ,ra.itii".,

    push-in and

    pull-out)'

    oT

    is

    noted

    to

    the

    most

    frequent

    utirizer

    of

    push-in

    services,

    .,

    int"i*ntion

    within

    the

    general

    education

    sett

    constitutes

    2Lo/o

    oftotar

    weekry

    or

    service

    minutes.

    s-Lp

    treatment

    within

    the

    generar

    educat

    setting

    totars

    Lo%

    of

    weekry

    service

    minutes,

    and

    is

    armost

    excrusivery

    derivered

    within

    ea

    chirdhood

    programs.

    push-in

    services

    can

    faciritate

    co-teaching,

    and

    thus

    maximize

    a

    studen

    generarization

    of

    targeted

    skirs

    ,.ro*

    her/his

    academic

    environment.

    Embedded

    in

    this

    deliv

    model

    can

    be

    the

    benefits

    ot,

    ,"*i."

    provider,s

    auiritv

    to

    model

    intervention

    strategies

    and

    suppo

    for,

    as

    well

    as

    consult

    with

    classroom

    staff'

    o

    The

    rerationship

    between

    direct

    and

    indirect

    service

    time

    within

    the

    schoor

    refrects

    somewhat

    of

    underutirization

    of

    the

    consurtative

    moder.

    A

    minimar

    amount

    of

    time

    is

    devoted

    to

    teacher-thera

    consurtation

    across

    both

    rerated

    service disciprines 1s-w=zw;

    o-t=4%).

    The indirect deliver

    services

    (i.e., direct

    consurtation

    with

    teachers

    and

    other

    rerated

    service

    providers)

    is

    invaluable

    t

    coilaborative

    team

    effort,

    as

    weil

    as

    the

    generarization

    of

    skiils

    across

    a

    student's

    curriculum'

    wh

    utirized

    as

    part of

    a

    dedicated

    coilaboralive

    team

    .tro.t,

    coisuttation

    can

    be

    a

    particurarly

    effec

    tool.

    o

    A

    weak

    negative

    correlation

    (-.19)

    between

    total

    weekly

    service

    minutes

    (sL-P'

    OT'

    and

    PT)

    studentagesuggestsapooradherencetothefrontloadinemoaer.Thismodeldescribesaframewo

    whereby

    the

    greatest

    intensity

    of

    se*ices

    are

    focused

    onlo'ngt|.

    students'

    and

    as

    students

    adva

    in

    age,

    service

    minutes

    gradually

    o".iin..

    The

    poor

    ro't.rln.""to

    this

    model

    can

    be

    best

    exempl

    by

    the

    observation

    thatof

    the

    10

    students

    receiving.ii.rr,

    100

    weekry

    rerated

    service

    minute

    students

    were

    9

    Years

    or

    older'

    o

    Despite

    rerativery

    'ttre

    movement

    in

    service

    minutes

    across

    age,

    the

    s-Lp

    data

    show

    service

    t

    acrossmean,medianandmode(oo,oo,60)tobewithinexpectedlimits'oTserviceminutes

    noted

    to

    be

    slightly

    higher

    than

    expected

    (49' 45'

    60)

    i,i]l CshiJftlisi:

    ijlr..::l..li::i.Y

    i]rhi)iJi

    i-}jsir.iii

    Iij

    $,llii;t:t|

    jillvir:*s

    Anil rsis

    ,:;l-ltlli :rr\:ltr:::;

    ilt:ii:ciii:ilii

    21

    |

    I)

    n

    g fl

  • 8/9/2019 Futures Education Audit

    22/24

    ffi

     

    F'i"'

    "*:-,'c

    The tendency

    towards over

    qualification

    within

    the related

    service

    domains

    of

    S-Lp and

    OT stands

    as

    the

    most

    striking

    trend revealed

    by

    the

    analysis.

    eualitative

    analyses

    of

    the aforemention

    cohort of students

    revealed

    a substantially-sized

    group

    for

    whom

    the

    information present

    in

    current

    IEP

    supported

    ineligibility

    (i.e.,

    standardized

    scores

    were

    less

    than

    1.5 standard deviatio

    below the mean and

    no

    other

    deficits

    were

    described

    to substantially

    impact

    the

    student,s

    ability

    access the curriculum)

    or was

    insufficient

    to

    adequately

    support

    the

    need.

    With

    specific

    regard

    to the

    36

    students

    receiving

    S-LP,33%

    of

    lEPs

    did not

    contain

    adequate

    supp

    for these services.

    Although

    some lEPs

    completely

    lacked

    reporting

    of

    standardized

    speech/langua

    testing,

    the assessment findings

    for

    the

    majority

    students

    within

    this

    subset

    were

    noted

    to

    be

    with

    the average range.

    A

    nearly

    identical

    percentage

    (32%)

    of

    the

    19

    students

    receiving

    OT had

    tEPs

    that

    did

    not

    substantia

    the need

    for

    intervention

    in

    this

    area.

    A

    preponderance

    of

    these lEps,

    however,

    did not

    rep

    standardized

    scores, and

    therefore

    the evaluator could not

    thoroughly

    determine

    whether

    or not

    t

    students met

    the eligibility

    criteria.

    lntegrity

    and

    internal

    consistency

    of

    the lEPs

    were

    also

    evaluated.

    particular

    attention

    was

    paid

    measurability

    of

    goals

    and objectives

    and

    the extent

    to which

    information

    within

    Student

    Strengt

    and Key Evaluation

    Results

    Summary

    was

    complete

    and

    consistent

    with

    services

    rendered

    and

    th

    alignment of

    goals

    to the curriculum.

    While

    curricular of

    goals

    was

    often

    adequate,

    information

    contained

    within

    Student

    Strengths

    an

    Key

    Evaluation Results

    Summary was

    at times

    sparse

    and

    not

    appropriately

    comprehensive.

    reported

    above, results

    of standardized

    testing

    was

    at

    times

    missing

    and

    Current

    performance

    Leve

    tended

    to

    provide

    a

    limited

    amount of

    information. Within

    S-LP,

    articulation

    was

    noted

    to

    be

    the

    are

    most in need

    of

    more

    comprehensive

    Current

    Performance

    Levels.

    The level

    of severity

    of th

    articulation disorder

    and

    specific

    sound

    errors

    were

    consistently

    omitted

    from

    the

    lEps.

    Along wi

    areas targeted

    by OT, social

    language

    tended

    to

    be an

    area for

    which

    very

    little

    standardized

    testin

    was

    provided.

    o

    overall, measurability

    was

    judged

    to

    be

    adequate,

    as

    goals

    contained

    the

    necessary

    conditio

    operationally

    defined

    target behavior,

    and

    appropriate

    criterion.

    Acddemics

    The analysis

    was comprised

    of the

    lEPs

    of

    40

    students

    receiving

    specialized

    academic

    intervention

    (e.g.,

    special education

    consultative

    services,

    instruction

    within

    the

    inclusion

    setting,

    pull-ou

    services).

    o

    Per

    the statutes

    and

    regulations

    of IDEA

    2004,

    several

    factors

    must

    be

    considered

    in

    th

    determination

    of eligibility.

    Specialeducation

    services

    can only

    be

    provided

    if

    the

    educationalTeam

    22lI);ig*

  • 8/9/2019 Futures Education Audit

    23/24

    ffi

    has

    determined:

    1)

    the

    presence

    of

    an

    educationar..disabirity;

    2)

    ineffective

    academic

    progress

    resulting

    from

    the

    ,'.l;i;,i;

    .^i

    ,r

    tr,.

    "".i

    ior

    specialized

    instruction'

    when

    using

    the

    discrepancy

    model,

    a

    lain

    component

    to

    determining

    the

    presence

    of

    an

    educationa

    ffiliJx,t:::;ffi

    ,:liXH:ff

    {'.",:,'.::Hfff

    *r'i:Llffiu.xlll*f;$fl*fuI

    raw

    does

    no,

    ,o".I,rr]^',.'"""t''"

    *JH;;?*n"

    iY"rint:i::i'"'tffiX-"j ;;';'rdized

    scoJe

    [T

    i';ff

    ,;,]*]i

    Xi:

    n

    :$i;*'1:{[:

    rilillli:t:il;ffi

    i.,

    w'ih

    a

    s'1a

    n

    d

    a

    rd

    d

    ev

    a'l

    o

    of15standa'OO"*i'f'*iitttt'thatadisabilitymaybepresent'

    o rn

    consideration

    of

    this

    standard,

    the

    educationar

    ream

    exhibited

    inconsistent

    adherence

    whe

    determining"*r,oliorioracademc-s*ffi

    ntlTlXfi

    *l';";ffi

    ;*;:ipS:iffililiil

    was

    the

    ,uur,.n,i.irJ-,'oedgT'r-lll,.,,r.o

    academic,.r,Jri,1".'ii.,

    tt'nottdized

    scores

    were

    n

    Hl;:"Ht;TJ,tx;:x:t

    j*trpi[::[:,n:tt::tri?"1#Hr:ii:iT'bed"subs'ian'[a

    impact

    the

    student's

    abiritv

    .o

    ....r,

    ,n-"

    curricutum)

    ,,

    ;::H*d;io

    'a"ourrerv

    support

    th

    . ;::r,

    to

    the

    arorementio""l^:::*o

    ::*::^i'::ings'

    there

    were

    manv

    instances

    in

    wh

    achievemen,

    ,.or.,

    did

    not

    ,uurtrnii.J.

    ii"

    n"ua

    to,

    ..ro.ri."

    r.J."r.

    -rn

    many

    circumstanc

    these

    findines

    ,.r..reo

    ,oriorv..rr.ol.=

    ili,t

    i.

    ":-ltj

    il;;;;;;'

    the

    lEPs

    were

    devoid

    of

    a

    achievemenr

    r"rri,r,

    and

    thus

    oio

    "oili"q,tt"ty

    support

    stated

    academic

    needs'

    23lP:rgtr

  • 8/9/2019 Futures Education Audit

    24/24