Submission to the Education Equality Task Force02

Introduction

The Learning Disabilities Association of Ontario (LDAO) is the sole parent and support organization in the Province of Ontario focussing on and advocating on behalf of persons with learning disabilities. A key part of the Association's mandate relates to supporting the provision of special education programs and services to students with specific learning disabilities within the educational system of Ontario. These students make up 50% of the total population of exceptional students, approximately 100,000 out of a total of 200,000 exceptional students, served by the elementary and secondary schools of Ontario. Therefore, any changes that are made to the provision or funding of special education in Ontario have a greater impact on students with learning disabilities than on any other group of exceptional students.

Over the almost forty years of its existence, the LDAO has responded to and participated in all government initiatives which had a direct or indirect impact on the education of exceptional students and in particular students with learning disabilities. LDAO was directly involved in the development and ongoing implementation of Bill 82 and all the following activities which were expected to make the educational system more responsive to meeting the needs of such students.

In all of its past and ongoing systemic advocacy activities LDAO has always tried to find positive solutions to the concerns that it has raised. Since the introduction of the current funding formula for education in general and for special education in particular, LDAO has identified and shared with the Ministry many concerns about the impact of the funding formula and its implementation. As part of this, it has suggested an alternative formula for achieving the stated goals of the student focussed funding, which was supported not only by the members and board of directors of LDAO, but also the majority of the other parent organizations focussed on special education. This alternative model is attached as Appendix A to this brief.

Unfortunately, the Minister of Education and the staff of the Ministry's Finance Branch did not choose to consider seriously this model, on the grounds that "the system was too far along in refining the current formula to considering an alternative." That was almost two years ago.

The establishment of the Education Equality Task Force confirms that, in spite of all the rhetoric and past work, the funding formula for education in Ontario is flawed and requires significant changes. In our opinion, the formula for funding special education is the most problematic among the formulae for distributing the funding allocation and has resulted in the most harm for the students of Ontario.

It is LDAO's hope that the Education Equality Task Force will consider with greatest attention the concerns and recommendations of the special education-related parent organizations, when it determines how to deal with the funding formula for special education. These are not merely "special interest groups" that have a voracious appetite for more and more funding. Rather, they recognize that the current formula has resulted in the creation of a bottomless pit, which cannot be filled however much extra money is provided and which, at the same time, discriminates against and hurts the majority of students with special needs.
The goal of the current funding formula

The discussion paper states that the objective of the student-focussed funding is to ensure that educational funding is fair and equitable, responds to student needs, focuses resources on the learner and promotes accountable decision-making for student success.

These are laudable goals and we cannot imagine that anybody would disagree with them. Unfortunately, neither the formulae themselves nor the ways in which they are implemented by the Ministry or by most if not all school boards have achieved or even approached these outcomes.

The document also states that since the introduction of the current funding formula, continued improvements have been made to the ways in which the funding is allocated. An example of these improvements is cited under special education funding on page 4 as the review of the allocation of the Intensive Support Amount. Neither this example nor the general statement are actually true as an indication of improvement. In the time elapsed since 1998 the government has provided more funds to the ISA process, but this has not led to any improvements in the process or in the provision of special education programs and services to the majority of exceptional students. In fact, the ISA formula has rewarded poor performance by giving funding to boards who are able to demonstrate more problems.

Therefore, it is LDAO's recommendation that:

• the Task Force should not endorse the current funding formulae as acceptable and/or appropriate to meet the needs of Ontario's students, whether exceptional or not; and

• the Task Force recommend a series of significant changes, especially in the special education funding formula area, that will lead to fair and equitable funding that ensures that all students, including exceptional students, will have their needs met and will receive an appropriate education, in accordance with Ontario's educational and human rights legislation;

• the Task Force should recommend that the Ministry develop a mechanism for evaluating performance, as per the Auditor's report, and then develop a model that rewards good performance.; and

• the funding of special education be retained as a separate and fully accountable funding envelope.

Quality of Student Learning and Achievement

In introducing a funding formula that provides the same allocation for all students, regardless of where they live in Ontario, the Government also decided to influence what is defined as core education as opposed to other services that the various communities expect from their schools. For example, the equality represented by the Foundation Grant denies recognition of local priorities for the schools to serve as the hub of local community activities, including but not limited to classroom activities.

While all students must have a right to access a quality education no matter where they live in the Province, the definition of quality education may vary. The core of a quality education is the students' ability to access the curriculum no matter how the student learns best and achieve the outcomes expected, with or without accommodations. Such core curriculum should include for all learners:

• the traditional academic subjects, both in terms of skills and content,

• the arts, such as music, drama and visual arts,

• physical, health, parenting and outdoor education,

• literacy and guaranteed access to school library services,

• the ability to utilize technology,

• access to vocational subjects,

• educational and vocational guidance and personal development, including the skills of resilience and values education as well as transition planning and programming,

• acquiring learning strategies and metacognitive skills.

Students with learning disabilities have strengths and weaknesses in different areas and the broader curriculum allows them to excel in their areas of strength.

For exceptional students it is imperative that they be guaranteed access to all the special education programs, services and accommodations that are listed in their Individual Educational Plans, delivered in the most enabling learning environment in accordance with their needs and their parents' wishes.

The recent reviews of the IEPs carried out by the Ministry of Education demonstrated that many IEPs are poorly written and do not reflect the students' strengths and needs. Many of them do not list the requisite appropriate teaching modifications, accommodations and achievable outcomes related to the provincial curriculum.

LDAO recommends that the Task Force:

• review the 2001 Provincial Auditor's report related to special education, which clearly highlights many of the concerns raised by parents and parent organizations about the funding formula and the lack of apparent value for the funding allocated, and

• recommend a more realistic designation of what is considered core curriculum and an acceptable education.

Equity and Fairness

The discussion document primarily focuses on the issue of constitutional equity in terms of public, Catholic, English language and Francophone school boards being treated equally. It has been demonstrated in several policy papers that the changes in the funding formula have typically benefited rural, Catholic, Francophone and northern boards, i.e., that some of these boards are indeed receiving more funding than was the case in the past. However, this has not resulted in matching demonstrated improvements in the quality of education provided to students. This is particularly notable for special education programs and services, where the extra dollars frequently have not found their way into the classroom.

LDAO noted with concern that in discussing equity and fairness, the discussion document does not address important equity issues related to students with disabilities and their constitutional Charter and Human Rights Code rights. From our perspective, equity and fairness need to focus on the special education entitlements of exceptional students and in particular students with learning disabilities.

LDAO recommends that the Education Equality Task Force recognize and reflect in its recommendations that equality is not the goal of education funding and that equity must include the Section 15 of the Charter of Rights and Freedoms and the Ontario Human Rights Code entitlements of students with disabilities. This must include access to a full range of special education placements, including self-contained congregated special education classes, established to ameliorate the innate disadvantages faced by exceptional students within the educational system.

In some communities, there is a recognized and community-supported need for additional services, which do not relate directly to what happens in the classroom, but support student learning indirectly. These may include ESL, international languages, adult upgrading programming, continuing education, reception and support for recent immigrants, citizenship classes, alcohol and substance abuse counselling, services to pregnant adolescents and new mothers, day care, etc. While many of these services relate to social issues and circumstances, excluding them is very short sighted on the part of the Government. Whether they are funded through the education funding formula or some other mechanism, their availability is very important, especially in large urban centres, such as Toronto. The current funding formula does not work to support the delivery of these types of services.

LDAO recommends that the Task Force accepts that certain non-classroom based services are very important in some if not all communities and recommend that they be funded in one of the following ways:

mandating interministerial funding of services that are linked to social issues as well as care and treatment type interventions, and/or

additional funding should be allocated to the Students at Risk category by the Ministry of Education

the reinstatement of the ability of school boards to raise some local revenue to reflect local priorities and issues.

Responsiveness to Local Needs: Special Education Funding

LDAO has repeatedly made known to the Ministry of Education our serious concerns about the special education funding formula and how it affects students with learning disabilities.

On January 27, 2000, the then Minister of Education made a series of major announcements related to special education. Among other things, this announcement also focussed on the issue of special education funding. The Minister committed the province to:

protect special education funding, i.e. school boards will be held accountable for spending their special education funding allocation on special education expenditures only;

maintain the (then) current SEPPA funding allocation, including the additional 30 million dollar increase introduced for this year;

confirm the maintenance of the ISA funding process for "high needs" students, with an additional 40 million dollars available for this, where school boards can demonstrate the need;

give boards more flexibility to use these resources in the most effective way to meet the objectives of a student's IEP.

In a series of questions to the Ministry's Policy Branch LDAO obtained clarification of this January, 200 announcement. We then expressed the following concerns:

Since SEPPA and ISA dollars can now be pooled (except for ISA 1 and 4), this has simply increas3ed the focus on making more students ISA eligible to generate more ISA dollars. Students with learning disabilities, most of whom are not and should not be eligible for ISA 2 and 3 designation, no longer have access to diagnostic assessments and are therefore missing out on the provision of appropriate special education programs and services.

The ISA Resource Guide and the IEP Standards document both stated that school boards are accountable for meeting their mandated obligations under the Education Act and for delivering the programs and services outlined in the student's IEP. However, as is clear from the concerns expressed by parents, parent associations and the observations in the Provincial auditor's report, there is no suggestion as to how parents can manage to achieve and how the Ministry will enforce this level of accountability. Since program and the IEP are not appealable under Regulation 181/98, parents and students have no means of ensuring that the programming delivered to the student reflects the contents of the IEP or that the IEP is appropriately based on the strengths, needs and the programming discussions included in the IPRC's statement of decision. For students who have IEPs, but are not deemed exceptional by an IPRC, there are even fewer due process rights in place.

As was discussed at some length at the recent policy forum hosted by the Education Equality Task Force, we are still awaiting the program standards first discussed in January 2000. Thus, parents and students continue to be at a major disadvantage in knowing what they can expect from the school system to meet their students' identified strengths and needs.

The Ministry stated that funding generated from ISA Level 2 and 3 submissions is part of the board's total special education funding that must be used by the board to provide support for all its special education students, whether they have high, medium or low needs. Students can expect to receive the programs and services outlined in their IEPs.

LDAO recognizes the value of this statement, but, in practice, students are provided with the level of services, often minimal and mediocre, that are available and not ones that reflect their strengths, needs and IEPs. ISA eligible students rarely have access to the services and supports described in the ISA eligibility documentation that has been submitted to the Ministry to support their eligibility

While the legislation has not been changed, most exceptional students are in regular classroom settings regardless of their needs or their parents' wishes, as hardly any boards still have a range of placement options for their exceptional students. This is particularly detrimental to the provision of appropriate educational programs and services to students with learning disabilities.

While the Standards for School Board plans have been developed and distributed, compliance with the legislation has not followed. School boards have plans, but students with learning disabilities frequently have limited or no access to appropriate special education programs and services.

Although, on paper, it is mandated that special education funding must be spent on special education programs and services, it is clear that the Ministry is not prepared to limit the provision of special education programs and services to students who satisfy the requirements for being identified as exceptional by an IPRC. This means that school boards can spend the funds on any number of students that they think require such services and for whom they have developed IEPs. Since due process rights related to special education are embedded in Regulation 181/98 and the sections of the Education Act that relate to exceptional students, school boards in fact are not held accountable for meeting their legislated obligations to exceptional students

It is obvious that the ISA process has hijacked the whole special education service delivery system for most school boards. This is inevitable, when the boards do not have to limit their ISA applications to identified exceptional students and can, with impunity, provide minimal or no services to the majority of their exceptional students. Assessments are now fully linked to the generation of ISA dollars. Many school boards are quite open about the fact that they do not provide assessments to students who are clearly not going to be eligible for ISA funding.

While LDAO recognizes that the provision of special education services in a regular classroom by the classroom teacher depends on the Foundation Grant, rather than on special education funding, every identified exceptional student is guaranteed access to special education programs and services as well as accommodations, as part of his or her identification. It is not clear how parents can expect full implementation of their child's IEP and the delivery of appropriate special education programs and services, if the regular classroom teacher has no special education qualifications or competencies and there are no withdrawal supports or other support services available.

Based on all of the above information and commentary, LDAO wishes to offer the following comments and recommendations to the Education Equality Task Force regarding the special education funding formula:

Targeted special education funding should only be spent on providing services and supports to identified exceptional students in order to deliver to them programming, services and accommodations based on their strengths and needs and as they are described in the student's IEP.

The ISA process, is so faulty that the best step would be to change it completely (see Appendix A). Intensive levels of funding, i.e., large dollar allocations, should continue to be provided for those few severely disabled exceptional students whose needs can only be met through the provision of very expensive and highly differentiated services. Many of these students have significant health and other requirements, beyond the costs of their education. In these low incidence, very high needs/ costs situations, the funding allocated should be linked to the programming and services needed by the student in question, regardless of the location/placement where that student's special education programming is delivered. This type of funding should be fully portable. Furthermore, the costs of meeting the high needs of these students should be shared by other ministries, in addition to the Ministry of Education.

While it is very difficult to determine whether the total dollar allocation for special education is in fact adequate to meet the needs of exceptional students or whether there is a real shortfall, as claimed by school boards, the current balance between ISA grants (if the ISA approach is to be maintained) and SEPPA grants should be reviewed and substantially readjusted.

Given the numbers of exceptional students, (approximately 200,000) and the approximately 20,000 students currently deemed eligible for ISA funding, the 50:50 balance of dollar allocation is unacceptable. (In fact, the 20,000 is far too large if we really focus on intensive needs and supports.) If the ISA grant allocation and eligibility criteria were readjusted to reflect the principles set out in point #2 above, then the ISA levels 2 and 3 allocation should be no more than approximately 10 to 15% of the total special education funding allocation, including the current Special Incidence Portion.

The ISA level 1 funding for assistive equipment should be maintained as a separate "pot of money". In addition to purchasing the equipment, funding should also be available for training, just-in-time technical support and curriculum development.

Since the ISA level 4 relates to care, treatment and other related services, the bulk of these costs should be received from the Ministries of Health, Community, Family and Child Services and Correctional Services.

Students should not have to match any pre-determined profiles in order to be deemed eligible for any type of special education funding. In fact, the current profiles and the requirement that they be used must be eliminated. Special education programming eligibility should be determined on the basis of the IPRC decision related to the student's exceptionality, strengths, needs and the programming requirements, as set out in a measurable and quantifiable manner in the student's IEP. The current practice of having to present students in as negative a light as possible in order to prove their ongoing eligibility for funding must be discontinued. The purpose of special education programming is to assist students to learn, make gains and progress towards independence, rather than trying to keep them as dependent as possible.

All exceptional students should have access to being taught by appropriately qualified special education teachers in the most enabling learning environment, as their primary special education program component. This must include access, as stated earlier, to a full range of special education placement options, including self-contained congregated special education classes in accordance with Section 31 of Regulation 298.

School boards should be held accountable for meeting the needs of their exceptional students and for delivering to them the programs, services and accommodations contained in their IEP. Furthermore, school boards should also be held accountable for providing to their exceptional students programs and services in accordance with their special education plan.

As part of the process of improving special education programming and funding, the Ministry of Education should consult upon, adjust and amend as needed, cost out and mandate the implementation of the exceptionality-specific program standards.

Accountability

Over the past few years, much has been said about the importance of accountability. However, in fact there has been no sign of any political or administrative will to ensure that school boards are held accountable for meeting their legislated mandate. Accountability has become the synonym purely for paper reporting. At the same time, ensuring compliance with legislation, evaluating and reporting upon student performance outcomes and accepting responsibility for ensuring that students are learning simply do not happen. It is time to change this, as part of the Government's overall approach to enhancing student learning and assuring that the Province's taxpayers receive value for their money.

Many other jurisdictions have struggled with the concept of enhancing accountability.

New Zealand, for example, has made some major changes to its accountability practices. Up to 1997, regular reviews of schools took the form of assurance audits and effectiveness reviews. Assurance audits were based on an examination of the extent to which school board trustees met their board's legislative obligations and contractual undertakings. Effectiveness reviews focused on student achievement.

Since 1997, they have adopted a new approach based on an assessment of risks to the Government as the provider of funding and purchaser of educational services and risks to the student as the primary beneficiary of these services. The new accountability reviews, carried out both on a school-by-school and board-by-board basis, focus on governance, management, delivery of the curriculum and the quality of student achievement. In other words they have shifted the focus from compliance to performance, since there were no longer any concerns about mere compliance.

The United Kingdom and Australia carry out similar reviews. While there are many concerns about the impact of making public the results of such reviews, recommendations for change in the accountability review, which is sometimes accompanied by the provision of additional resources and may occasionally contain some punitive directions, are generally well received and quickly implemented.

Here in Ontario, the legislation allows for both incentives and, if absolutely necessary, punitive measures. The latter range from directing school boards to change their special education plan to reflect legislation to exacting financial penalties to the removal of supervisory officers. However, none of these are utilized to any great extent, especially when it comes to the field of special education service delivery. For example, where school boards spend a significant amount of their resources on legal fees to oppose parental rights to due process, there is no suggestion from the government at any time that those funds could better be spent on meeting the needs of the student in question.

Although much of this is way beyond the question of how the funding formula should be amended, it is imperative that the Task Force recommends enhanced accountability measures as a key requirement in making the educational system responsive and accountable for student learning and outcomes.

LDAO recommends that the Education Equality Task Force recommends the development of a meaningful performance and outcome based accountability framework, which allows for the introduction and implementation of both incentives and penalties for non-compliance.

In addition, LDAO recommends that since no reliable data on special education needs exist, that the Task Force recommend that the Ministry collect independent and unbiased data to support any special education funding model.

LDAO is committed to continuing to work with the Ministry to improve all aspects of the special education system in Ontario, including the improvement of the funding formulae, the development and monitoring of school board special education plans, IEPs, exceptionality-specific program standards and in particular the implementation of better accountability standards and measures for the benefit of all exceptional students in Ontario's schools. While our primary mandate is to speak on behalf of the almost 100,000 students with identified learning disabilities in Ontario's schools, we are also concerned about the impact of some of these initiatives or lack of them on other exceptional students.

We know what these students need. It is time that the educational system appropriately identified and met their needs and helped them to become successful independent learners. The adjustment of the special education funding formula and the implementation of the above recommendations are an integral part of achieving this goal. For all exceptional students these represent major steps towards becoming successful contributing citizens of the Province.

Appendix A.

A proposal for amending the process for funding special education in Ontario

The current process for funding special education in Ontario was adopted following the recommendations of the expert panels, after the Province assumed responsibility for fully funding education in 1998. The current model of a layered funding envelope consisting of SEPPA, the four levels of ISA and the SIP, introduced last year, has been amended and adjusted on an annual basis. Similarly, the total amount allocated to special education was also amended annually, to reflect the Minister's stated desire to make the process and the allocation more equitable and more responsive to meeting the needs of all students with special needs.

In spite of many concerns about the details of this approach, many parent organizations initially endorsed the principles upon which funding model was based. However, as the process has unfolded most parent organizations and many parents have expressed major concerns about the process and the way in which students with special needs are currently treated in Ontario's schools.

As the process has been amended, we have also learned a great deal.

The allocation of the SEPPA grants on a per pupil basis for the total enrolment of a school system is believed to be the appropriate way to proceed. This reflects the original decision regarding special education funding, after the introduction of Bill 82 in 1980, which suggested that the incidence of most exceptionalities is fairly consistent across the Province and further that the provision and availability of funding should not be driven by school boards identifying more students for special education programming and services than should actually be the case.

Some of the current concerns, as expressed by school boards, are based on the premise that the incidence of the various exceptionalities is quite diverse across the Province and that school boards need more and more money to meet the needs of these students. No school board is apparently reporting a declining incidence of any exceptionality, even when the total numbers of students, as reported by school boards to the Ministry of Education, have not actually increased.

It was universally agreed when Bill 82 was introduced that funding should never drive the process, but rather that the level of funding should be determined on the basis of student needs and the programming necessary to meet those needs. There is no need, in our opinion, to depart from this long held belief. In fact, many of the parent organizations are concerned more about the process than about the total funding allocation.

Much of the focus during the past three years has been on the ISA process. In spite of the fact that the ISA process was initially meant to create greater equity for students with high cost needs, especially when they live in small or isolated communities and where the availability of resources is limited, it has become the primary focus everywhere for dealing with special education matters. This is certainly not equity, when the vast majority of exceptional students and even others who are identified as needing special education programming, but not necessarily deemed exceptional by an IPRC do not receive what they need due to this focus on process rather than the outcome of the process. Even the relatively small number of ISA eligible students are sometimes forgotten during the pressure to generate more funds, by whatever means may be possible.

Clearly the Ministry has recognized that the ISA process, as currently structured, has gone "off track" and has disenfranchised a great many students. We believe that this is the reason for this latest consultation process. We recognize and agree that the current process represents a major administrative burden for school boards and their staff. It also represents major problems for students, who are not being appropriately served. In fact, it appears to us that the current process does not work well for anyone. Students, parents, teachers, supervisory officers, Ministry personnel are all dissatisfied and are looking for a solution. Therefore, what follows are a series of recommendations for changing the process to make it more equitable, accountable and manageable. Our primary goal in developing this process was to eliminate or at least significantly reduce the many concerns about the process and to move to a much more student-centred approach.

Looking at the ISA process

The current ISA level one

The revised process (ISA level one) for the provision of personalized adaptive technology and equipment has benefitted many students. This should be maintained, ensuring that all students who need access to such equipment should be guaranteed this and the accompanying accommodation of their special needs. Some members of PAAC feel that the $800 deductible leads to many students not receiving this help or not having access to the specific equipment that they need. Therefore, it may be necessary to consider eliminating the deductible and having full funding for all necessary equipment that is included in the student's IEP. We understand that the Ministry would anticipate many complaints about an increased administrative burden if this were to happen. However, the bottom line needs to be that students should have access to any equipment that will enable them to access the curriculum and achieve in school.

Technology has made a tremendous change in the lives of students with disabilities. We must not allow administrative concerns to limit access to such important accommodation for all students with special needs, who would benefit from this.

The current ISA level four

We agree with the supervisory officers who see this as a problem. Ministry staff also comment that these students are not "pupils of the board" and the allocation for this should therefore not be seen as part of the funding envelope that the school board is accountable for.

Our recommended solution to this is to make the process more like the service provision and funding of programming through the Provincial and Demonstration schools, using perhaps the Ministry's interministerial co-ordinated services approach for identifying who the students are who would most benefit from Section 19 placements and the services available in them. In fact, the IS level four process should be totally removed from school board funding.

The current ISA levels two and three

After three years of piloting the ISA process, it is clear that approximately 1% of all students within the educational system, approximately 20,000+ students, have been deemed eligible for receiving the services and supports delivered on the basis of the current ISA levels two and three. This number reflects the careful audit of ISA applications during the past three years.

While this is a significantly higher percentage than was anticipated during the public consultations during 1997, presumably it is the correct or very close to the correct percentage for the cumulative incidence figure. While the percentages identified by individual school boards have initially varied widely, they have become more consistent, as the process has been amended year after year. The range from school board to school board is typically between .75% and 1.5%. Obviously, small school boards may have a slightly higher percentage, while the larger boards typically come in at a somewhat lower percentage level.

Given the numbers of students deemed eligible for level two and level three by the Ministry's validation process and the appropriate funding allocation, it would appear that the average dollar allocation on a per student basis is somewhere between $15,000 and $20,000. This reflects the current ISA level two and three funding and the breakdown for each level on a Province wide basis. This would result in a total allocation of $300,000,000 to $400,000,000. Even if we were to suggest that 1.5% of the total student population should be considered for this funding at $15,000 per student, the total would amount to $450,000,000. Given the current ISA expenditure of close to $600,000,000, this would allow some significant flexibility for the educational system.

Therefore, rather than pursuing minor adjustments to the current process, consisting of:
· the time consuming and complex process of identifying individual students,
· carrying out unnecessary assessments in many, though not all cases,
· using the highly unpopular profiles and stressing the negative aspects and impacts of each potentially eligible student's disability on the basis of which many students may be significantly stigmatized,
· completing a series of complex annual application forms for a huge number of students,
· undertaking the costly and time consuming validation process and
· then not applying the funds obtained on a dedicated per individual student basis but spending them on a system wide way,

the whole ISA process should be changed.

We recommend that the available funds should be provided to school boards as follows:

1. There should be a single funding envelope for special education.

2. The SEPPA funding process be maintained, with additional per student dollars as they become available, to support the provision of special education programs and services to all students with special needs in accordance with the Education Act, the Regulations and other relevant legislation.

3. The ISA level one process should be maintained as the process for obtaining personalized adaptive equipment for students who need this, with the adjustments suggested above.

4. The ISA level four process should be removed from the direct school board funding process, as described above.

5. In order to enhance equity, each school board should receive a sum equal to 1% (or some other similar percentage) of its total enrolment times $15, to $20,000 dollars. This would be significantly less than the current ISA allocation of almost $600,000,000 (see above). While eventually this could all become part of an enhanced SEPPA allocation, initially this amount should be tracked separately.

6. School boards should include in their annual special education plan a budget for how they plan to utilize their full allocation of special education funding. As the rest of the plan, this should be discussed fully with and approved by the SEAC.

7. The Ministry should issue guidelines for how to create such special education budgets as well as how to report each year on the expenditures made. This would enhance school board accountability in a way that the Minister and Ministry staff should find appropriate and school board finance officials should be able to live with.

The balance of the funds should be kept "in trust" for the following:
· individual applications for those much fewer students for whom the Special Incidence Portion is intended or for some other anomalous circumstances, e.g., the influx of a large number of new students with very high cost needs, for whom the school board had not been able to plan in its annual special education plan. This should become the new much more streamlined ISA amount, the allocation of which could then really be linked to real student needs and programming and service decisions by all relevant stakeholders including professionals and parents.
· much needed professional development funding;
· incentives for school boards that provide exemplary programming or services to one or more groups of exceptional students.

This revised process would allow for:

greater predictability and stability,

virtually eliminate concerns about the school boards' "administrative burden",

enhance accountability through the involvement of SEAC in setting a special education budget, monitoring it and reporting annually on the expenditures,

eliminate the much disliked and restrictive profiles,

ensure that assessments are carried out for programming and IEP development purposes, and not for the negative labelling of students and their performance,

eliminate the current practice of having two IEPs, one for parents and one for ISA purposes,

enable professionals such as psychologists, speech pathologists, etc., to resume working with students as needed and intended, rather than focusing on filling out forms almost to the exclusion of everything else,

allow school boards to allocate more staff time and dollars to students in the classroom,

improve parent participation and support for the process,

create greater equity.

In conclusion, this process would enable the Ministry to achieve all of its goals for student-focused funding and education finance reform and in the process enable all students with special needs to receive the special education programs and services that Ontario guarantees to them in its progressive legislation.

This proposal was presented to members of PAAC on SEAC on November 24, 2000. The general principles, (though not necessarily all the text accompanying them), were approved, in principle by most of those who were present. The original material has been amended to reflect some of the comments and recommendations of PAAC members.

The proposal was presented to the LDAO Educational Policy and Legislation Committee and to the Board of Directors of LDAO on Thursday, November 30, 2000. It was sent to the Minister of Education and to the Ministry's Finance Branch by LDAO and by PAAC on SEAC in December, 2000. Neither organization received any formal acknowledgement or response.