Albuquerque Special Education Report-FINAL

Confidential Attorney Work Product
IMPROVING
SPECIAL EDUCATION SERVICES
In the
Albuquerque Public Schools
Submitted to the Board of Education
of the
by the
Strategic Support Team
of the
Council of the Great City Schools
Spring 2019
Improving Special Education Services in the Albuquerque Public Schools
Table of Contents
Acknowledgements ............................................................................................................... 1
Chapter 1. Purpose and Origins of the Project ....................................................................... 2
The Work of the Strategic Support Team ...................................................................................................... 2
Methodology and Organization of Findings .................................................................................................. 3
Chapter 2. Background and Overview .................................................................................... 5
Chapter 3. Executive Summary ............................................................................................ 10
Chapter 4. Findings and Recommendations ......................................................................... 12
I. Multi-Tiered Systems of Support and Implications for Child Find .................................................... 12
NM Guidance for RtI ....................................................................................................................................13
PED’s RtI Webpage ..................................................................................................................................14
PED Guidance Manual .............................................................................................................................14
APS Guidance and Practices ........................................................................................................................17
RTI Academic Training (PowerPoint) .......................................................................................................18
FBA/BIP Training PowerPoint ..................................................................................................................19
SAT Forms ................................................................................................................................................20
Focus Group Feedback.............................................................................................................................21
Child Find Implications .................................................................................................................................24
General Education Oversight...................................................................................................................24
Focus Group Feedback.............................................................................................................................25
AREAS OF STRENGTH ...................................................................................................................................25
OPPORTUNITIES FOR IMPROVEMENT .........................................................................................................26
RECOMMENDATIONS ..................................................................................................................................28
II. Disability Demographics ............................................................................................................... 33
District Prevalence Rates .............................................................................................................................33
Comparison of APS, Urban Districts, National, and State Special Education Rates ................................33
Rates by Disability Areas for District, State and Nation ..........................................................................34
Specific Learning Disability ......................................................................................................................34
APS Disability Rates by Grade Levels .......................................................................................................36
Disability Incidence by Race/Ethnicity .........................................................................................................36
English Learners and Disability ....................................................................................................................37
Special Education Referral, Eligibility, and Timeliness ................................................................................39
Timeliness of Evaluations ........................................................................................................................39
Evaluation Data .......................................................................................................................................39
III. Teaching and Learning for Students with Disabilities .................................................................... 43
Education of Young Children Ages Three to Five Years ...............................................................................43
Achievement of Young Children with Disabilities ....................................................................................43
Educational Settings of Young Children Three to Five Years of Age........................................................45
Instruction at the Preschool Level ...........................................................................................................46
Academic Achievement for School-Aged Students .....................................................................................46
Council of the Great City Schools Page i

NAEP Achievement Rates for Students with IEPs ....................................................................................47

Statewide Assessment Outcomes for Students with Disabilities .............................................................49
Educational Settings for Students with Disabilities .....................................................................................50
Comparison of Rates for District, State, and Nation ...............................................................................51
Educational Setting Rates by Grade Level ...............................................................................................52
APS Educational Setting Rates by Disability Areas ..................................................................................52
District, State and National Educational Setting Rates ...........................................................................53
Educational Setting Risk Ratios by Race/Ethnicity and English Learner Status ......................................55
Suspension and Expulsion Rates ..................................................................................................................56
Out-of-School Suspensions ......................................................................................................................56
Suspensions by Race/Ethnicity ................................................................................................................57
Absenteeism ............................................................................................................................................57
Academic Instruction, Intervention, and Supports .....................................................................................58
Instruction and Specialized Support for Students in General Education Classes ....................................59
Instruction for Students in Specialized Programs ....................................................................................62
Instructional Support for English Learners with Disabilities ....................................................................65
Support for Student Behavior ......................................................................................................................66
Relevant IDEA, State Law, and Professional Literature ...........................................................................66
Background Relating to APS’s FBA/BIP Process Concerns.......................................................................68
Chronology of FBA/BIP Key Events and Description of Various Documents ...........................................69
Focus Group Participant Feedback ..........................................................................................................72
APS Survey of Special Education Teachers and Staff ...............................................................................73
Council Team’s Feedback ........................................................................................................................74
Secondary Transition Services and Support ................................................................................................75
IEP Compliance and Post School Experience ...........................................................................................76
Professional Learning ...................................................................................................................................77
Parent and Community Involvement ..........................................................................................................79
IV. Support for Teaching and Learning for Students with Disabilities ................................................. 93
Interdepartmental Communication and Collaboration...............................................................................93
APS Organizational and Meeting Structures ...........................................................................................93
Learning Zone Structure and Relationship with Special Education .........................................................94
Special Education and Equity, Instruction and Support Collaboration ....................................................94
Overall Comments ...................................................................................................................................95
Administration and Operation of Special Education ...................................................................................96
Special Education Department Organizational Structure .......................................................................96
School-based Special Education Support...............................................................................................101
Special Education-Related Staffing Ratios and Information......................................................................102
Overall School District Ranking .............................................................................................................103
Special Educators...................................................................................................................................104
Education Assistants ..............................................................................................................................105
Focus Group Participant Feedback ........................................................................................................106
Related Services Personnel ....................................................................................................................106
APS and ATF Support for Special Education ..............................................................................................109
Compliance Activities.................................................................................................................................111
Council of the Great City Schools Page ii

Written Procedures................................................................................................................................111
Electronic IEP System .............................................................................................................................111
IDEA Annual Compliance Determination...............................................................................................112
Due Process Hearings ............................................................................................................................113
Complaints Filed with PED .....................................................................................................................114
Order of Manifestation Determination and Impartial Discipline Hearings ...........................................115
Transportation .......................................................................................................................................115
Medicaid Reimbursement......................................................................................................................115
Accountability ........................................................................................................................................116
AREAS OF STRENGTH .................................................................................................................................117
OPPORTUNITIES FOR IMPROVEMENT .......................................................................................................118
RECOMMENDATIONS ................................................................................................................................124
Chapter 5. Summary of Recommendations ........................................................................ 135
Recommendation Matrices .......................................................................................................................135
List of Recommendations ..........................................................................................................................142
Appendices........................................................................................................................ 163
Appendix A. Incidence Rate and Staffing Ratios ........................................................................................163
Appendix B. Data and Documents Reviewed ............................................................................................170
Appendix C and D. Draft Working Agenda and Invited Participants .........................................................173
Appendix E. Strategic Support Team .........................................................................................................183
Appendix F. About the Council and History of Strategic Support Teams ..................................................186
Council of the Great City Schools Page iii

ACKNOWLEDGEMENTS
The Council of the Great City Schools (Council) thanks the many individuals who
contributed to this review of special education services in the Albuquerque Public Schools (APS).
Their efforts were critical to our ability to present the district with the best possible proposals for
improving special education and related services in the school system.
First, we thank Superintendent Raquel Reedy, the school district’s superintendent. It is not
easy to ask one’s colleagues for the kind of reviews conducted by the Council’s teams. Typically,
our reports are tough. It takes courage and openness to request them and a real desire for change
and improvement. Ms. Reedy has these in abundance.
Second, we thank the APS school board, which approved and supported this review. We
hope this report meets your expectations and will help improve special education services across
the school system.
Third, we thank district staff members who contributed to this effort, particularly Dr.
Richard Bowman, chief information and strategy officer, and Laurie Lehman, Budget and Project
Supervisor. They arranged the interviews and facilitated the detailed data and documents requested
by the team. The time and effort required to organize a review such as this are extraordinary, and
their work and support was excellent and much appreciated.
Fourth, the Council thanks the many individuals who met with us or communicated with
the team after the site visit. This included central office administrators, principals, general and
special educators, paraprofessionals and aides, related-services personnel, parents, state
educational officials, and representatives from the Albuquerque Teachers Federation. They work
passionately to support children with disabilities and ensure the school district serves these
students in the best possible manner. District staff we met with were clearly dedicated to their
students and showed a strong desire to improve student achievement.
Fifth, the Council thanks Marco Tolj, strategic planning and data management director for
the Los Angeles Unified School District (LAUSD) and Tanya Browne, special education executive
director for the Dallas Independent School district. We also thank their school systems for allowing
them to participate in this project. Their contributions to this review were enormous, and their
enthusiasm and generosity serve as further examples of how the nation’s urban public-school
systems are banding together to help each other improve outcomes for all urban students.
Finally, I thank Julie Wright Halbert, the Council’s legislative counsel, who facilitated the
work of the team prior to and during the team’s site visit, and Sue Gamm, a nationally recognized
expert in special education and a long-time consultant to the Council, who worked diligently with
Ms. Halbert to prepare the final report. Their work was outstanding, as always, and critical to the
success of this effort. Thank you.
Michael Casserly
Executive Director
Council of the Great City Schools Page 1

CHAPTER 1. PURPOSE AND ORIGINS OF THE PROJECT
Ms. Raquel Reedy, Superintendent of the Albuquerque Public Schools (APS), asked the
Council of the Great City Schools to review APS’s services for students with disabilities and
provide recommendations to support the teaching and learning of these students. It was clear to
the Council’s team that the superintendent and her staff have a strong desire to improve student
outcomes. This report was designed to help APS and its leaders achieve their goal and maximize
the district’s capacity to educate all students effectively.
The Work of the Strategic Support Team

To conduct its work, the Council assembled a team of experts who have successfully
administered and operated special education programs in other major urban school districts across
the country. These individuals also have firsthand expertise with the Individuals with Disabilities
Education Act (IDEA) and are well versed in best practices in the administration and operation of
special education programming.
The Council’s strategic support team (Council team) visited the district on September 23-
25, 2018. During this period, the Council team conducted interviews and held focus groups with
district staff members, the Albuquerque Teachers Federation (ATF), and parents. In addition, the
team had follow-up conversations with various district representatives and with staff from the New
Mexico Public Education Department. (A list of individuals interviewed is presented in the
appendices of this report.) In addition, the team reviewed numerous documents and reports,
analyzed data, and developed initial recommendations and proposals before finalizing this
document. (See the appendices for a list of documents reviewed.) On the final afternoon of its site
visit, the team briefed the superintendent and the chief information and strategy officer on the
team’s observations and preliminary recommendations.
This approach of providing technical assistance to urban school districts by using senior
managers from other urban school systems is unique to the Council and its members. The
organization finds it to be an effective approach for several reasons.
First, it allows the superintendent and staff members to work with a diverse set of talented,
successful practitioners from around the country. The teams provide a pool of expertise that
superintendents and staff can call on for advice as they implement the recommendations, face new
challenges, and develop alternative solutions.
Second, the recommendations from urban school peers have power because the individuals
who develop them have faced many of the same challenges encountered by the district requesting
the review. No one can say that these individuals do not know what working in an urban school
system is like or that their proposals have not been tested under the most rigorous conditions.
Third, using senior urban school managers from other urban school communities is less
expensive than retaining large management consulting firms that may have little or no
programmatic experience. The learning curve is rapid, and it would be difficult for any school
system to buy on the open market the level of expertise offered by the Council’s teams.
Members of the Strategic Support Team for this project included:

Sue Gamm, Esq.

Tanya L. Browne
Former Chief Officer for
Executive Director of Special Education
Specialized Services
Dallas Independent School District
Chicago Public Schools
Marco Tolj
Julie Wright Halbert, Esq.
Director
Legislative Counsel
Strategic Planning & Data Management
Los Angeles Unified School District
Methodology and Organization of Findings

The findings in this report are based on information from multiple sources, including
documents provided by APS and other organizations; electronic student data provided by APS;
group and individual interviews; documents; and legal sources, including federal and state rules
and guidance documents. No one is personally referred to or quoted in the report, although school
district position titles are referenced when necessary for contextual purposes.
Chapter 2 of this report provides background information on the district. Chapter 3 presents
an executive summary of the report. Chapter 4 contains the Council team’s findings and
recommendations. These observations and proposals focus specifically on areas that the
superintendent and district leadership asked the Council’s team to address.
The findings and recommendations sections of the report, Chapter 4, contain a summary
of relevant information, along with descriptions of the district’s strengths, opportunities for
improvement, and recommendations for change. The chapter is divided into four broad sections:
a) Multi-tiered System of Supports (MTSS)
b) Disability Demographics and Referral/Identification of Disability
c) Teaching and Learning of Students with Disabilities
d) Support for Teaching and Learning of Students with Disabilities
It is important to note that in New Mexico students who are gifted are included in the broad
definition of special education. However, the Council’s review focused more particularly on
students with disabilities covered by the Individuals with Disabilities Education Act (IDEA), and
to a lesser extent by Section 504 of the Rehabilitation Act (Section 504) and the Americans with
Disabilities Act (ADA). Gifted students were not the immediate focus of the team’s efforts.
Chapter 5 lists all recommendations in one place for easy reference, and provides a matrix
showing various components or features of the recommendations.
The appendices include the following information:
• Appendix A compares special education student incidence rates and staffing ratios in 75
major school systems across the country.
• Appendix B lists documents reviewed by the team
• Appendix C presents the team’s working agenda for its site visit.

• Appendix D lists individuals the team interviewed individually or in groups.

• Appendix E presents brief biographical sketches of team members.
• Appendix F presents a description of the Council of the Great City Schools and a list of
Strategic Support Teams that the organization has fielded over the last 20 years.

CHAPTER 2. BACKGROUND AND OVERVIEW
The Albuquerque Public Schools (APS) is the largest school district in New Mexico,
educating some 81,895 students in grades prekindergarten through 12. The district’s website lists
88 elementary schools, 29 middle schools, 5 kindergarten-through-grade 8 schools, and 21 high
schools. Some 66 percent of APS’s students is Hispanic; 23 percent of students are white; and all
other racial/ethnic student groups make up about 10 percent of the district’s enrollment.
Students receiving special education comprise 19.4 percent of all students at the
elementary, middle, and high school levels. English learners (EL) account for 18.1 percent of the
district’s student enrollment; and 24.9 percent of all English learners receive special education
services.1
A-F School Grading
APS is in a state that adopted the Common Core State Standards. The New Mexico Public
Education Department (PED) has implemented the federal Every School Succeeds Act (ESSA), in
part, by establishing an A-F school-grading model that includes scores for school improvement in
English language arts (ELA)/reading and mathematics, along with other indicators. (This grading
system was abandoned by the state after the team’s visit.) The following assessments were used to
determine a school’s grade:
• I-station Indicators of Progress (ISIP) Early Reading (grades k-2)
• PARCC (grades 3-11)
• Standards Based Assessment (SB), Spanish Reading (Certain ELs, grades 3-11)
• NM Alternate Performance Assessment (NMAPA for students with the most significant
cognitive disabilities, grades 3-11)
Any school that does not meet the 95 percent student assessment participation rate required
under ESSA in both ELA and math will have its school grade reduced by one letter. 2 Under the
state’s value-added model, each student’s prior achievement – along with school size, mobility
and alternate assessment indicators – are used to predict a scaled score. A student’s actual score is
compared to this prediction to determine if the difference is positive. Schools earn a high value-
added score if most scores show growth; they earn a low value-added score if most scores do not
show growth. The grading system also recognizes a school’s general learning environment. This
component includes both school attendance (with a target of 95 percent) and students’ classroom
experiences, which are assessed through an annual parent and student survey.
The A-F school grading model included schools that specialize in teaching students with
disabilities or were part of the dropout recovery effort in the Supplemental Accountability Model
(SAM). These schools were given additional ways to demonstrate success. For example, SAM
graduation rates recognized school graduations among students from cohorts that have aged out of
1
Data does not include students in APS charter schools.
2
Frequently Asked Questions, retrieved from
http://aae.ped.state.nm.us/SchoolGradingLinks/1718/Technical%20Assistance%20for%20Educators/School%20Gra
ding%20FAQs%202018.pdf.l

the 4-year, 5-year, and 6-year cohorts. Additional assessment indicators were used to calculate
college and career readiness. Also, an offset was applied when considering data for current
standing, and SAM schools were exempt from participation-rate penalties due to their high levels
of student mobility and turnover.
State Funding of Public Education
Since the early 1970’s, a variety of lawsuits have been filed to challenge New Mexico’s
system of financing public education. 3 The first lawsuit, which alleged that expenditures varied
unconstitutionally depending on local school district wealth, was settled prior to trial. New Mexico
leaders shifted funding to have the state provide over 80 percent of education costs. However,
school districts remained responsible for capital funding. With the deterioration of facilities in
many low-property-wealth school districts, another lawsuit was filed in 1998 to address this issue.
The trial court ordered New Mexico to establish and implement a uniform funding system for
capital improvements and to correct existing and past inequities. After surviving a 2001 filibuster
on a proposed $1.2 billion capital program, the legislature agreed to fund a $400 million capital
program and created a new capital funding system designed around a standards-based adequacy
level for facilities in all districts in the state.
In a second case, a group of school districts located on federal and tribal lands with low
property tax bases filed suit to prohibit New Mexico from offsetting their state funding by the
amount of federal impact aid payments they received. On April 27, 2007, the U.S. Supreme Court
ruled in the state’s favor.
The latest litigation was brought during the Spring of 2014 by two separate groups of
parents of educationally disadvantaged Latino and Native American students. The first suit
challenged New Mexico’s foundation funding formula. It highlighted a 2008 American Institute
for Research cost analysis that concluded that operational expenses were underfunded by
approximately $350 million. The second suit challenged the state’s teacher evaluation system,
which was based in part on student test scores and school rankings, as it allegedly discouraged
quality teachers from applying to or staying in New Mexico schools. In June 2014 the suit was
amended to contest the state’s financing of special education. The two cases were consolidated
later that year after the court denied the state’s motion to dismiss one of them.
On July 20, 2018, the state court in Yazzi/Martinez v State of New Mexico found that the
state’s public education system was not sufficient under the state constitution, especially for low-
income students, students of color, Native American, English learners, and students with
disabilities. The court ordered the state to make sweeping changes to provide students with the
programs and services they needed to be college and career ready. 4
3
SchoolFunding.Info: A project of the Center for Educational Equity at Teachers College, retrieved from
http://schoolfunding.info/litigation-map/new-mexico/#1485190871777-803f7877-73f9.
4
NM Center on Law and Poverty, Educators, advocates, and tribal leaders propose plan to transform New Mexico’s
education system, retrieved from http://nmpovertylaw.org/tag/yazzie-v-state-of-new-mexico/.

Important court findings included the following:5

• State Demographics. In New Mexico, 71.6 percent of the state’s public-school students were
from low-income families, and 14.4 percent were English learners. In addition, 14.8 percent of
students had disabilities, and 10.6 percent were Native American.
• Teacher Evaluation. With inadequate funding for teachers and teacher training, New Mexico’s
test-based teacher evaluation system penalized teachers for working in high-need schools and
exacerbated the quality-teacher supply deficits in these schools.
• Personnel Needs. High-needs districts had more inexperienced teachers and higher vacant
teaching positions. Testimony revealed that New Mexico teachers were among the lowest paid
in the country.
• Material Resources. Schools across the state suffered from inadequate instructional materials,
curricula and teachers, including instructional material for Native American students.
Essential resources needed to deliver a reasonable curriculum, including those for at-risk
students, did not provide opportunities to compensate for barriers students faced.
• Student Outcomes. Inadequate resources had led to inadequate student outcomes, with New
Mexico students ranking at or near the bottom of the nation in English and math proficiency
and high school graduation. Achievement was lower for low-income, Native American, and
EL students. Of New Mexico’s students attending college, a substantial number required
remediation and were not college ready.
• Rejection of State Claims. The court also rejected state claims that outcomes were sufficient
because at-risk students showed growth in achievement, that any inadequate outcomes
stemmed from socio-economic factors not attributable to the school system, and that state
intervention was adequate in compensating for any inadequacies. The court found that state
assistance/oversight programs were piecemeal, and they could not replace adequate state
school funding. Also, the court found various school programs (e.g., quality pre-K, K-3,
extended school year, quality teachers, etc.) had mitigated these factors and raised the
achievement of at-risk students, but the programs had not overcome these factors.
• State Budget Constraints. Finally, the court dismissed the state’s argument that it was
constrained by the New Mexico budget from doing more. The court declared that, “the remedy
for lack of funds is not to deny public school children a sufficient education, but rather the
answer is to find more funds.”
During the Council team’s meetings, various focus group participants raised themes like
those found by the courts. Among the most prevalent themes included low teacher salaries and
high special education-related shortages, especially in schools with students having significant
needs. Concerns also included the need for additional human resources, materials, and professional
development.
To remedy the constitutional violations, the judge ordered the New Mexico legislature by
April 15, 2019, to “take immediate steps to ensure that New Mexico schools have the resources
necessary to give at-risk students the opportunity to obtain a uniform and sufficient education that
5
New Mexico School Funding Found Unconstitutional, by Wendy Lecker, Education Law Center, retrieved from
http://www.edlawcenter.org/news/archives/other-states/new-mexico-school-funding-found-unconstitutional.html.

prepares them for college and career.” The court also ordered the state to implement an
accountability system to measure whether programs and services in place provided the opportunity
for a sound basic education and to ensure that districts were spending funds in a way that efficiently
and effectively meets the needs of at-risk students. In early January 2019, the court issued a 600-
page order outlining deficiencies in New Mexico’s education system. The state’s new governor
announced that she would not challenge the ruling, and issued an executive order ending the use
of PARCC reading and math tests after the 2018-19 school year.6
After several cash-lean years, lawmakers earlier this year increased K-12 spending by 4
percent — or about $107 million — for the budget year that started July 1, 2018. As part of that
increase, legislators appropriated enough money to boost teachers’ salaries by 2.5 percent and
increase minimum starting teacher pay to $36,000 a year. The legislature also increased the amount
of money that goes toward programs for at-risk students by $22.5 million. Although the legislature
was considering various remedies proposed by the plaintiffs’ attorneys, funding changes consistent
with the requirements of the court’s decision will take longer to finalize and implement.
State Budget Impact on APS
In November of Superintendent Reedy’s second year as superintendent, PED notified the
district that due to lower gas and oil prices there was a need for APS to cut $12.5 million from its
budget. The district completed the process by mid-December. Again, in January, PED required
APS to cut another $12.5 million by the following month. The next year the state again required
the district to cut $12.5 million from its budget. During the spring and summer of 2016 APS
reorganized and reduced staff to achieve a balanced budget.
Superintendent’s August 24, 2018 Message with Special Education Focus
During a weekly message to employees, Superintendent Reedy discussed the results of a
special education personnel survey that APS and ATF jointly commissioned. The survey was
conducted by a professional research and polling company during a two-and-a-half-week period
in late-June/early-July 2018. Some 402 teachers and staff responded. The survey’s purpose was to
measure employee satisfaction among special education teachers and staff, including satisfaction
with their work environment, employee morale, and communications. Initial survey results
included–
• Benefit to Students and Employee Satisfaction. The vast majority of those interviewed (89
percent) felt the work they performed benefitted APS students, and about three-quarters were
satisfied with the type of work they do.
• Communication and Morale. Many special education teachers and staff members reported
that communication was lacking, and morale was low. Respondents cited a need for
clearer direction, timely communications, consistent professional development,
and opportunities for collaboration.
• Other Concerns. Many of those interviewed felt overworked, having to spend considerable
time on mandated paperwork, lesson plans and preparation, and expressed the concern that
they were not fairly compensated for the additional time spent on these tasks.
6
Retrieved from https://www.lcsun-news.com/story/news/local/new-mexico/2019/01/09/nm-school-public-
education-department-lawsuit-judge-governor-grisham/2524675002/.

As a result of the survey, APS/ATF developed a joint committee made up of special

education, school, and department staff to share insights, knowledge, and experiences, and to work
collaboratively on improved morale. In addition, the superintendent announced the Council’s visit
to APS to review special education processes and procedures, and to share best practices from
other large urban districts. The superintendent cited her knowledge of past Council reviews of this
nature that had proven to be beneficial to APS.
Most importantly, the superintendent recognized the dedication of APS personnel involved
in the education of students with disabilities, along with their hard work and expertise. She also
recognized the need to more clearly communicate ever-changing state/federal requirements with
an appreciation and protection of staff time. With special education positions being hard to fill in
APS and across the nation, the district had some 160 special education teacher openings at the time
of the superintendent’s message. In this respect, she shared the district’s goal to recruit, hire,
support, and retain the best teachers for APS students.
The superintendent closed with this message: “Please know that I value our special
education teachers and staff. If you are among them, then thank you for all you do. If you work
alongside them, please let them know how appreciated they are.”
The Council team met many of the dedicated APS personnel involved in the education of
students with disabilities and appreciates the time they took to share their observations and
experiences. With their input, and the qualitative and quantitative information we reviewed, the
Council team is hopeful that our recommendations and feedback will help the district and its
stakeholders achieve better outcomes for students and address the many concerns that the district
and staff have.

CHAPTER 3. EXECUTIVE SUMMARY
Ms. Reedy asked the Council of the Great City Schools to review the district’s special
education programs and to make recommendations on how to improve them for students with
disabilities. To conduct its work, the Council assembled a team of special education experts with
strong reputations for improving services in their own districts.
The Council team visited APS in September 2018, conducted numerous interviews,
reviewed documents, and analyzed data. At the end of the visit, the team formulated and presented
preliminary observations and recommendations to the superintendent. Following the visit, there
were additional informational interviews with the team and follow-up information provided that
proved to be extremely beneficial.
To be sure, the Albuquerque Public Schools have considerable challenges in the area of
special education, but the district also has a considerable number of assets. First and foremost is
that the school district has many very talented and dedicated staff members and teachers who are
working hard every day to improve the academic outcomes for students with disabilities.
Second, the instructional operations unit of the district has taken considerable leadership
in developing an RtI system that is used at least in some schools across the system. In addition, the
curriculum department has taken leadership on child-find issues, which are rightly the purview of
general education, not just special education. The Council of the Great City Schools considers this
a best practice.
Moreover, the special education and bilingual education departments of the school system
have collaborated nicely over recent years to work on issues involving English learners with
disabilities. In general, the school district has unusually high rates of students who have been
identified for an IEP, but some disability categories are no larger than what one might otherwise
expect. There are also some circumstances that need to be monitored, but the district does not
appear to over-identify students by race. There is some tendency to over-identify English learners,
compared to non-English learners, but the risks of over-identification among ELs does not meet
state thresholds.
In addition, the district generally conducts special education evaluations on time. The
number of due process hearing requests has also declined. The state, moreover, is devoting more
time and attention to ramping up early childhood education across the state. The graduation rate
among students with disabilities has also improved and is approaching levels enjoyed by students
without disabilities. Moreover, the district’s transition services are yielding outcomes that are close
to state compliance targets.
At the same time, the Albuquerque school system is faced with considerable challenges.
While no racial group is in serious trouble of being over-identified compared with any other group,
the district overall has one of the highest identification rates of any major urban school system in
the nation. In addition, the system is more likely to educate its students with disabilities in
segregated settings more so than state or national averages. Conversely, the district is far less likely
to educate students with disabilities in a general education setting than state or national averages.

In general, students with disabilities are frequently educated with materials that are different from
those used to educate all students. The result, in part, of both the segregation and the lack of access
to the general education program is that the reading and math performance of students with
disabilities is low, even compared with other urban school systems across the country.
While the district has several schools that use a well-articulated RtI system, academic
interventions for students who are falling behind are not evenly implemented. Accountability for
students with disabilities does not extend far beyond the special education department. The unit
itself is not well-organized as well. And the lack of collaboration on behalf of students with
disabilities was notably weak. All of this was exacerbated by a professional development system
that was not strong; a data system that was not well-coordinated across units; and classroom
monitoring that did not routinely observe students in specialized programs.
The Council team was particularly concerned that the district appears to have lost trust with
the teachers’ organization around issues of behavior and communications. These are always
sensitive issues in the relationships between district management and the unions, but the district
appears to have made a number of communications errors that it could have avoided. The results
of the joint APS and ATF survey of educators across the system ought to be a flashing red light.
A good part of the behavior issue, for its part, is because the district does not have a well-
defined positive-behavior program. Instead, the system places undue reliance on a heavy-handed
set of administrative procedures that could be significantly streamlined without a negative effect.
On top of that, the district does not have the numbers of school psychologists one might expect to
address these issues in a systematic way.
Finally, the district has structures in place to engage parents and the community, but the
efforts are poorly staged, ill-timed, and poorly coordinated to maximize participation and build
public confidence.
The Council team has made an extensive number of recommendations to address issues
large and small that were identified as part of the site visit, data analysis, and interviews. Broadly,
these proposals include additional work on the district’s MTSS system; identification rates and
positive behavior support; its instructional systems on behalf of students with disabilities; and its
special education supports. It is a complicated set of recommendations that have overlapping
components and will take some time to implement.
It was also clear to the Council team, that the implementation of our proposals will require
the good-will and coordination of both the district’s administrative leadership and the leadership
of the teachers’ groups, the state, and various university and community partners in the city. We
find it encouraging that the many actors who will be needed are starting to come together to
improve outcomes for the city’s students with disabilities. Trust is badly needed here. For its part,
the Council of the Great City Schools stands ready to help the district with next steps. There is
little reason that the special education program in Albuquerque can’t be one of the best in the
nation.

CHAPTER 4. FINDINGS AND RECOMMENDATIONS
This chapter presents the Council team’s findings in four areas: multi-tiered systems of
support, demographics and identification, academic achievement among students with disabilities,
and support for teaching and learning. Each section includes a summary of the team’s findings and
concludes with overall strengths, opportunities for improvement, and recommendations.
I. Multi-Tiered Systems of Support and Implications for Child Find

A multi-tiered system of supports (MTSS) involves the systematic use of multi-source
assessment data to efficiently allocate resources and improve learning for all students with a series
of integrated academic and behavioral supports.7As described in the Council of the Great City
Schools’ report, Common Core State Standards and Diverse Urban Students,8 MTSS is designed
to improve educational outcomes for all students. It focuses on prevention and early identification
of students who might benefit from instructional or behavioral interventions. The framework is a
merger of response-to-intervention (RTI), which typically focuses on academic achievement, and
systems to improve positive student behavior. When the term MTSS is used in this report, it
includes RTI, Positive Behavior Intervention and Supports (PBIS), and other systems for
supporting positive student behavior. It also applies to gifted students.
As described in the CGCS report on diverse urban students, the essential components of an
MTSS framework include:
• Well-defined district- and school-based leadership and organizational structure;
• District policies and practices that align with and support a multi-tiered system;
• Technology sufficient to support instructional decision making and implementation of
instruction (e.g., Universal Design for Learning or UDL);
• Robust and valid core or Tier I instruction (“first teaching”) delivered to all students;
• Assessment of expected rates of progress;
• The use of three tiers of increasingly intensive (time and focus of instruction) instructional
supports and strategies;
• Professional development to ensure fidelity of implementation of MTSS methodology and
the Common Core State Standards;
• An evaluation process that monitors both implementation and outcomes, and continuously
reflects on practice; and
• The engagement of parents and caregivers.
In a functioning MTSS framework, schools have systems in place to identify the needs of
all students and monitor and evaluate progress throughout the school year, using multiple data
7
Florida’s Multi-tiered System of Supports, retrieved from http://florida-rti.org/floridaMTSS/mtf.htm.
8
Retrieved from https://www.cgcs.org/cms/lib/DC00001581/Centricity/Domain/87/77--
Achievement%20Task%20Force--RTI%20White%20Paper-Final.pdf.

measures (e.g., district assessments, attendance, suspensions, grades, numbers of office referrals,
etc.). Data are analyzed, and differentiated instruction and interventions are delivered based on
results. Teachers and leaders regularly review and monitor student progress to determine trends
and identify instructional adjustments needed for remediation, intervention, and acceleration.
When a student fails to make adequate progress after robust core or Tier I instruction has
been delivered, then instructional interventions are put into place and their effects are tracked.
Without this monitoring system in place, it is unlikely that schools will have the documentation
needed to determine whether underachievement is due to ineffective core instruction and
interventions or something else that might trigger a special education referral. Nevertheless, when
teachers and parents observe students who are struggling to learn and behave appropriately, there
is a predictable desire to seek legally protected special education services.
To make this system work, it is imperative that districts and schools have processes in place
to help educators determine why a student is not performing or when they might need acceleration.
When implemented as intended, an MTSS framework focuses on rigorous core instruction and
provides strategic and targeted interventions without regard to disability status. In addition, MTSS
can lead to better student engagement and lowered disciplinary referrals—and fewer students
requiring special education services. It can also help reduce disproportionate placements of
students from various racial/ethnic groups and those with developing levels of English proficiency
who might otherwise fall into the ranks of those needing special education services.
In fact, MTSS is recognized in the Every Student Succeeds Act (ESSA)9 as an appropriate
framework for supporting student achievement and positive behavior, and it is a permissible use
of federal Title I funds. The Act defines MTSS as “a comprehensive continuum of evidence-based,
systemic practices to support a rapid response to students’ needs, with regular observation to
facilitate data-based instructional decision-making.”
To provide a context for MTSS in APS, the subsections below describe New Mexico’s
framework and guidance. They also address the extent to which APS has implemented this
framework to support student achievement/positive student behaviors and to guide follow-up
strategies (including referrals for special education) when student progress was not evident.
NM Guidance for RtI

According to New Mexico state code, the response to intervention (RtI) framework is
described as a three-tier model of student intervention that uses a set of increasingly intensive
academic or behavioral supports matched to student needs. It is viewed as a system for making
educational, programming, and eligibility decisions supported by a continuum of school-wide
supports that contribute to comprehensive school improvement efforts. 10
9
The Elementary and Secondary Education Act was reauthorized in 2015 as the Every Student Succeeds Act
(ESSA).
10
New Mexico Administrative Code, subsection D of 6.29.1.9.

PED’s RtI Webpage

The PED’s webpage provides guidance on the state’s framework. 11
• Tier 1. All students are screened (universal screening) for potential problems. They receive
appropriate, standards-based, core instruction, including any classroom, grade-level, or school-
wide interventions (universal interventions) needed for academics and/or behavior. Tier 1’s
universal interventions are provided in a general education classroom.
• Tier 2. Students who have not responded significantly to the Tier 1 core program with universal
interventions are referred to a school’s Student Assistance Team (SAT) and may receive a
targeted, individualized intervention plan. This plan could include more intense instruction,
individually or in small groups, and is provided in addition to the general education curriculum.
Students with disabilities who do not qualify for special education services may also be served
at this tier through a Section 504 accommodations plan.
• Tier 3. In New Mexico, this tier is reserved for students qualifying for special education or
under the state criteria of giftedness. Students receive Tier 3 specially designed instruction and
related services that are included in their Individualized Education Programs (IEP).
In all tiers, school personnel monitor student progress to determine the effectiveness of
instruction and/or interventions. Based on these results, instruction is adjusted to produce better
outcomes.
The Council team was concerned that the information provided by the state might appear
to some that students receiving specially designed instruction/related services via an IEP could be
instructed with Tier 3 instruction/interventions only. However, such students may not need
intensive interventions for every aspect of their education. For example, a student may have
adequate reading/ELA proficiency but may require supports for math or behavior. Another student
may require Tier 2 interventions provided to students without IEPs to support his/her reading, but
he or she may require more intensive Tier 3 interventions in other areas. School teams should
always consider providing intervention in general education to the greatest extent possible before
moving to other tiers.
PED Guidance Manual
In 2014, PED published a comprehensive guidance manual to support implementation of
the RtI framework. 12 The manual provided more detailed information with respect to the three tiers
of instruction/intervention described above. PED expected districts and charter schools to
implement student interventions in line with this guidance manual.
School and District Implementation Plans
According to the manual, each school and district must have an RtI implementation plan
based on the state framework. As the manual describes on page 7, these plans are essential for
guiding school-team decisions on the course of interventions and decision-making, and for gauging
the success of those interventions.
11
Retrieved from https://webnew.ped.state.nm.us/bureaus/safe-healthy-schools/response-to-intervention-rti/
12
Retrieved from https://webnew.ped.state.nm.us/wp-content/uploads/2018/03/RtI-Manual-most-updated-2.15.pdf.

Locally devised implementation plan. As each school develops its local

implementation plan for each tier, it also determines its data-based decision rules
for when interventions should be changed and when students should move from
Tier 1 to Tier 2 or Tier 3 or reverse course. In Tier 1, the school determines what
cut scores are used on universal screening measures, and additional progress-
monitoring assessments indicate advanced, proficient, satisfactory growth, or need
for more intense interventions/ remediation. The key criteria for referring a student
to Tier 2 and an SAT process (see below) involves the lack of student progress on
multiple data points despite the documented delivery of differentiated instruction
and interventions to that student. A recommendation for a Tier 2 referral for
behavior, for instance, is based on the school’s judgment and/or discipline data
showing the lack of progress using documented behavioral interventions.
RtI Components
The state manual identifies the following 10 key RtI components:
• High-Quality Classroom Instruction
• High Expectations
• Assessments and Data Collection
• Problem-Solving Systems Approach
• Research-Based Interventions
• Positive Behavioral Supports
• Fidelity of Program Implementation
• Staff Development and Collaboration
• Parent and Family Involvement
• Disability Determination
As described further below, the state manual provides specific guidance for English
learners and how the framework is to apply to them.
In many important ways, the state’s framework is like the MTSS framework described in
the Council’s booklet referred to above and used by many other states, such as Michigan.
Multi-Tiered Systems of Support (MTSS) is an integrated, multi-tiered system of
instruction, assessment, and intervention designed to meet the achievement and
behavioral needs of all learners. It is a framework designed to ensure high-quality
instruction. The MTSS framework aligns to the Michigan Continuous School
Improvement Process. The essential components to MTSS include: Instruction and
Intervention, Data and Assessment, Implementation of Evidence-Based Practices,
Problem-Solving, and Stakeholder/Family Involvement. 13
School-Based Assistance Team
PED mandates the use of a school-based student assistance team (SAT) to gather all
available data about a student who is not making adequate progress in Tier 1; develop an
hypothesis about possible cause(s) for the student’s problems; and then design an individualized
13
Retrieved from http://www.resa.net/specialeducation/rti/ and http://www.rtinetwork.org/getstarted/checklists-and-
forms.

SAT intervention plan and/or behavioral intervention plan (BIP), as necessary. By identifying
students who could benefit from more intensive interventions, the SAT process is designed to help
students remain and succeed in general education and reduce unnecessary or inappropriate
referrals to special education.
Neither the state’s website nor guidance manual provides information on SAT management
of commonly used and important problem-solving processes. These processes are better described
in the Council’s Common Core State Standards and Diverse Urban Students report,14 as well as
in documents produced by other organizations and school districts, e.g., the RtI Action Network, 15
Miami-Dade County Public Schools,16 and the State of Florida.17 The processes are also described
in other publicly available professional development documents. 18
Addressing Student Behavior
PED has focused particularly on support for student behavior in its guidance manual,
Addressing Student Behavior, which was last revised in 2010. The manual’s title includes the
subtitles, “Conducting a Functional Behavior Assessment” and “Developing a Behavioral
Intervention Plan,” and it begins on page 6 with a discussion of a broader context for supporting
positive student behavior:
[s]chool-wide behavioral programs and standard strategies … prevent inappropriate
behavior through teaching and reinforcing appropriate behaviors. Solid teaching
practices, clear rules and expectations, caring about students, as well as praising
and encouraging positive behaviors are good techniques.
The manual emphasizes the need for schools to adopt school-wide positive behavioral and
support programs to create a safe school environment that is conducive to learning for all students.
These programs could reduce the need for Tier 2 behavioral interventions, which are intended to
support students with frequent, persistent, or severe problem behaviors after Tier I behavioral
interventions have proven to be ineffective. Guidance on the development of FBAs and BIPs is
also provided for students referred to SATs with no Section 504 or IDEA qualification, and for
students who are eligible under one of these federal laws. The manual specifies that individuals
performing an FBA must be adequately trained, and that when the problematic behavior is severe,
it may be appropriate to use a qualified professional, e.g., counselor, psychologist, or behavior
management specialist.
The manual provides several sections that expand IDEA requirements for the development
of FBAs and BIPs. The table below compares relevant PED and IDEA rules. Most notable is that
PED requires the use of FBAs/BIPs for students with IEPs when they are involved in disciplinary
14
Retrieved from https://www.cgcs.org/cms/lib/DC00001581/Centricity/Domain/87/77--
Achievement%20Task%20Force--RTI%20White%20Paper-Final.pdf.
15
Retrieved from http://www.rtinetwork.org/essential/tieredinstruction/tier1/accurate-decision-making-within-a-
multi-tier-system-of-supports-critical-areas-in-tier-1.
16
Retrieved from http://rti.dadeschools.net/pdfs/Rtl_Guide/Ch4-four_step_problem_solving_model.pdf.
17
Retrieved from http://www.floridarti.usf.edu/floridaproject/mtss.html.
18
Judy Elliott, Ph.D., presented at the 2015 AASCD Annual C/I. Conference, retrieved at
http://www.arkansasascd.org/images/pdfs/AR_ASCD_BreakoutFInal_June2015_HOs.pdf.

proceedings. Congress removed FBA/BIP requirements for students when their disciplinary
behavior was unrelated to their disability.
Exhibit 1a. Comparison of PED and IDEA Requirements for FBA/BIP
PED IDEA
In response to disciplinary actions Required only when considering

by school personnel (Page 7) long-term suspension/expulsion and
behavior is manifestation of student’s
FBA/BIP required If behavior is related to student’s
disability (e.g., related to the
disability, team conducts FBA and
disability).
develops/revises BIP to address
behavior (Page 9)
When considering long-term

suspension/expulsion and behavior is
FBA/BIP as NOT manifestation of student’s
appropriate disability. Also, as appropriate,
provide behavioral intervention
services/modifications
When behavior impedes learning of Same for IDEA but without reference
Consideration of student or others, a BIP that is to BIP.
positive behavior integrated into the IEP is the strategy
interventions and to address behavior (Page 9)
supports
Fidelity of Implementation Tools

Although the state PED webpage refers to implementation tools, the link does not contain
any publicly available resources like the ones published by the RtI Action Network, 19 the Center
on RtI,20 North Dakota,21 and Arizona.22
APS Guidance and Practices

APS’s assistant superintendent for equity, instruction, and support and her small
curriculum and instruction (C/I) department have taken responsibility for providing professional
development for RtI, including Tiers 1 and 2 interventions. In addition, department personnel:
• Design training and support for K-12 principals, instructional coaches, and teachers in core
instruction;
• Provide support for core instruction; and
• Support the implementation of Common Core State Standards for ELA/math, and for New
Mexico state standards in other core content areas.
19
Retrieved from http://www.rtinetwork.org/rti-blog/entry/1/107.
20
Retrieved from https://rti4success.org/sites/default/files/RTI_Fidelity_Rubric.pdf.
21
Retrieved from https://www.nd.gov/dpi/uploads/194/2.NDMTSSFidelityofImplementationRubric.pdf.
22
Retrieved from https://cms.azed.gov/home/GetDocumentFile?id=56f5c458aadebe1f54acc6a7.

According to the department’s webpage, core curriculum/instructional practices are

focused on student outcomes; informed by the best available research on effective learning and
teaching; and evidence-based and data driven to guide improvement and measure impact. The
webpage does not provide any written information on RtI, the SAT, and or any problem-solving
processes. However, the district’s Employee Intranet has an SAT webpage with links to SAT
training dates and materials, forms on academics, ELs, behavior, gifted, tracking, manifestation-
determination reviews, and related material for RtI-SAT, behavioral issues, and special education.
RTI Academic Training (PowerPoint)
A 2018-19 PowerPoint document provided to the Council team and presented by APS
personnel to SAT chairs provides information on SAT forms and procedures; language screeners;
behavior referrals; EL considerations; FBA/BIP training; and how to upload APS student data into
the information system.23 Some notable aspects of this training document include the following –
• Tier 1. Students are identified through the “AIP (Academic Improvement Plan) process” or a
teacher’s professional judgment, and strategies include: pre/“first teaching”, sheltered
instruction, and differentiated instruction. The PowerPoint does not repeat the New Mexico
state manual’s reference to culturally and linguistically responsive instruction, research-based
strategies and programs, or high-impact instruction. Further, it does not reflect New Mexico’s
guidance for schools with high rates of SAT referrals and/or retention, which requires further
evaluation of a school’s Tier I core program, practices, and behavioral systems that ensure
students are not failing due to instructional and/or school behavioral system inadequacies.
• Tier 2. Strategies include small group instruction, research-based curriculum and materials (I-
Station, I-Reading, Fundations, Read180, Common Core Standards, Treasures, Stepping
Stones, Direct Instruction, ST Math, etc.) If such programs are not available, teachers are to
teach the lesson in a different way. Guidance for recommended intervention-service minutes
are provided, i.e., from 90 to 120 minutes per week in addition to core instruction (20 minutes
daily at the elementary level, and 20 minutes 3 times/week at the middle/high school level.)
Progress monitoring is expected for each intervention in every area of concern, for eight weeks
using four data points. Tier 2 interventions are not to stop until a student is exited from SAT
or “placed” in special education. Upon cessation of special education, students are then “placed
back in Tier 2.” Students who do not qualify for special education continue to receive Tier 2
strategies.
• Language Screeners. Information is provided for screening young students, and for behavioral
referrals for students with behavioral concerns.
APS gave to the Council team a form that was used to document Tier 1 reading, writing,
and math interventions/results on a biweekly basis over a six-week period, and for behavioral
interventions daily. Another form for Tier 2 reading/math interventions was used to document
implementation/results over an eight-week period. Notably, there was no comparable form to be
used for Tier 3 interventions, which in New Mexico is restricted to special education. The
PowerPoint document did not contain any information on the problem-solving process, which
provides a structured approach for reviewing and discussing progress-monitoring results.
23
Information is also provided with respect to gifted students, which is beyond the scope of this report.

FBA/BIP Training PowerPoint

Information was also provided in APS’s 2017-18 FBA/BIP training document that was
available on the district’s Intranet. The document describes the following forms, which are also
posted on the Intranet: Teacher Self-Reflection of Classroom Environment, FBA, BIP, and the
general Tier I form described below.
• Teacher Self-Reflection. Classroom teachers complete this document prior to the collection of
Tier I data. Based on the results of the self-reflection, the teacher is to implement any changes
identified as a result of a week of data collection. Relevant information is documented on the
SAT Academic Improvement Plan and Classroom Improvement Plan Tier I (Form RT-1),
which are described below. If the targeted behavior continues, there is guidance on moving
forward with the FBA/BIP process.
• FBA. According to the training document, the FBA has seven sections (A through F). The
sections are straightforward:
- Section A provides more detail about problem behavior (what it looks like, frequency,
duration, and intensity/level of danger).
- Section B provides a checklist of events that predict when problem behavior will occur
(setting events, e.g., illness and environmental features).
- Section C provides a checklist of outcomes that appear most likely to maintain problem
behavior (things that are obtained, e.g., adult attention; and things avoided or escaped from,
e.g., hard tasks). A video is provided in this section.
- Section D provides a checklist of current efforts (strategies for prevention) used to control
problem behavior (e.g., schedule change; and strategies for responding to problem behavior
- reprimand, office referral, detention, other).
- Section E provides a summary of behavior to support the development of a BIP. A video
is provided in this section.
- Section F describes the hypothesis statement of a student’s functional behavior, i.e., why
the student engages in the targeted behavior.
- Section G indicates whether the student’s behavioral patterns require instructional
modifications or accommodations, or the development of a BIP.
The Intranet does not provide an FBA form and the PowerPoint does not describe other forms
that should be completed prior to the completion of the FBA.
• BIP. The BIP has four sections.
- Section A describes the behavior’s setting, antecedents (trigger), function, desired
behavior, outcomes, and replacement behavior.
- Section B describes behavioral support strategies and an implementation plan. Items
include the manipulation of the antecedent, the behavior to be taught, and altered outcomes
(through positive reinforcement and redirection).
- Section C describes how the BIP is to be evaluated. It includes a short-term behavioral goal
that is specific, observable, and measurable, and reflects the replacement behavior that is

being taught. The expected date for meeting the goal is at least two weeks from the date of
the BIP. The long-term behavioral goal reflects the desired behavior, which is at least eight
weeks from the date of the BIP. If the goal is not met, the BIP is reviewed/revised.
- Section D lists the educational team members implementing the BIP.
Concerns about FBA/BIP Process
Last year the special education department rolled out a new FBA/BIP process that caused
considerable concern about the amount of time needed to complete it. During the Council team’s
discussions with stakeholders, there was little reference to the FBA/BIP training material and
forms on the district’s Intranet. Detailed information on the district’s FBA/BIP forms and
requirements is provided further below in Section III. Teaching and Learning of Students with
Disabilities.
SAT Forms
Of the various SAT-related forms posted on the APS Intranet, including those for English
learners, the following are of note:
• SAT Academic Improvement Plan and Classroom Improvement Plan Tier I (Form RT-1).
This form must be completed by classroom teachers prior to referring students to the SAT.
Teachers are required to identify a Tier 1 strategy (or program) and document the results after
two, four, and six weeks of use. For student behavioral issues, teachers check the area of
concern, e.g., aggressive physical behavior and other relevant information. In addition, the
teacher is to document the student’s daily behavior for one week.
• Speech/Language Services. A note on the Tier 1 form (RT-1) indicates that Tier 1 activities
do not apply to speech/language concerns, such as speech not understood in multiple settings
or speech interfering with academic performance. In such circumstances, the SAT chair
notifies the speech/language pathologists to initiate an evaluation process.
• SAT Classroom Intervention Plan: Tier 2 (Form R4). Teachers insert information on
strategies being used by listing a program name (i.e., Double Dose Fundations, Read 180,
Common Core State Standards,24 ST Math) and documenting results after four, six, and eight
weeks.
• SAT Student Observation (Form R-10). This form, which involves a certified staff member’s
observation of a student not on a staff member’s roster, is used only if the student is being
referred for a full observation. The form is used for academic and behavioral issues. Except in
the areas of reading and writing, separate observations must be completed for each area of
concern. The form’s contents, however, which focuses on student’s learning and behavior,
does not include any prompts, check lists, or narrative that describes the teacher’s interaction
with the student. By comparison, the New Mexico RtI manual indicates that the SAT should
include whether Tier 1 instruction was appropriately differentiated, and consider such factors
as the student’s teaching and learning preferences, possible lack of instruction, etc.
• SAT Dyslexia Characteristic Checklist: Teacher (Form R11). To be completed on students
being referred for a full evaluation, the form has a helpful checklist showing various
24
Note: Common Core State Standards are not intervention strategies per se; rather, they are standards to guide
instruction.

characteristics of dyslexia.
• Follow-up SAT Meeting Summary Form (Form R5). The SAT is required to document the
success of Tier 2 interventions. The team has the following options: maintain/modify tier II
interventions; exit from SAT; start tier II interventions on a new area of concern; initiate special
education testing; and other. No option is specified for initiating a referral for a Section 504
evaluation, which is referenced in the New Mexico RtI manual. The form includes the potential
for five meetings. The only reference to implementing Tier 2 interventions “with fidelity” is
related to the use of a behavioral intervention plan (BIP) but not to any academic interventions.
Focus Group Feedback

Focus group participants provided the following feedback on their use of a multi-tiered
system of supports in the district.
• State Leadership. According to information provided at an October 2018 meeting that PED
convened, there was an expectation that New Mexico would be moving forward with a
framework called “multi-leveled services and support (MLSS).” The new framework, which
PED’s safe and healthy schools bureau was leading, also included health and wellness. It was
also anticipated that PED would issue a guidebook on MLSS, but the election of a new
governor raised considerable uncertainty about PED’s continuity of leadership and the future
of MLSS.
• APS Guidance Document. As indicated above, APS has some training information and SAT
forms on its Intranet. However, the district has not developed a comprehensive framework or
written guidance on the state’s RtI Framework. Furthermore, focus group participants did not
seem to be aware of PED’s document that was available on the state’s website. 25 Only one
school representative indicated that their school had clear RtI practices, which included data
dialogues and schoolwide goals. That school also had special educators in their professional
learning communities (PLCs). The process was put into place 10 years ago by a former
principal and it has continued to the present.
• SAT. Although it appears that every school had an SAT chairperson, the process varied across
the district. As seen in training and SAT forms, there was an expectation at the school level
that students would be provided between six to eight weeks of intervention prior to the
possibility of a special education referral. Accordingly, assessment personnel would return
evaluations if the expected interventions were not documented. Neither the New Mexico
manual nor APS training materials provided any guidance for short-cutting this period (other
than for parent evaluation referrals) because of exigent circumstances, i.e., severe intellectual
disability. Also, there were concerns that the SAT process in some schools was overloaded,
which would make it difficult to function effectively and meet documentation expectations.
• Tier 1 ELA/ELD Instruction and 90-Day Plans. All APS schools have 90-day plans for
continuous improvement based on New Mexico’s school improvement model. The
improvement of Tier 1 instruction is part of these plans, which are designed to reduce the
number of students requiring Tier 2 interventions. It is likely that Tier 1 academic instruction
was negatively affected by using eight-year old English language arts (ELA) and English
language development (ELD) materials. However, the district has initiated a five-year
25
Retrieved at https://webnew.ped.state.nm.us/bureaus/safe-healthy-schools/response-to-intervention-rti/.

instructional material purchasing plan to align materials with the Common Core State
Standards. Benchmark Advance had been purchased for ELA and ELD with full
implementation in grades kindergarten through five expected by August 2019. The vetting
process involved a diverse group of stakeholders, including union representatives. 26
• Single Line of Accountability. APS does not have a single line of accountability below the
superintendent for instruction and social/emotional supports for students, and there were
competing priorities established by zone leaders, curriculum/ instruction staff, special
education personnel, principals, etc. As a result, there were administrative silos that do not
support a common vision, mission, or set of practices.
- New Curricular Materials. There were concerns among focus group participants that
schools were not consistently using the newly purchased curricular materials and that there
does not appear to be any system of accountability in place to address this issue.
- Special Education ELA Materials. Students with and without disabilities receiving
instruction aligned with the Common Core State Standards (CCSS) do not have similar
curricular materials. Because there was a need for curricular materials aligned with CCSS,
the special education department purchased I-Ready and I-Station materials prior to
curriculum/instruction’s vetting process that resulted in the purchase of Benchmark
Advance. Furthermore, general education reading materials were not consistently ordered
for students in specialized classes, so teachers were finding their own materials. As a result,
students with disabilities may be receiving instruction using different materials than their
nondisabled peers. This circumstance can negatively impact their ability to receive
instruction in general education classes when different materials are being/have been used.
- Instructional Coaches. With grant funding, curriculum/instruction’s coaches were
providing professional development around the work of Eric Jensen and his studies of
poverty’s impact on the brain. However, principals who do not always agree with this
approach use different approaches for their coaches. This disconnect jeopardizes grant
funding and splinters the professional development being provided school-to-school. (The
team did not see evaluation data that assessed the efficacy of the approach.)
- Universal Design for Learning (UDL), as the name implies, is a universal framework that
fosters student engagement by presenting information in multiple ways and allowing
diverse avenues of expression. 27 It is an evidence-based approach designed to meet the
needs of students with a wide range of abilities, learning styles, learning preferences, and
educational backgrounds, and is appropriate for general education students and students
with low achievement, disabilities, and ELs. The approach is intended to meet student
needs upfront and requires fewer accommodations. Applying the principles of UDL means
that students with varying abilities are better able to access high-quality instruction.
26
Various focus group participants expressed concerns that curricular materials for students receiving special
education instruction are different, i.e., I-Ready and I-Station.
27
UDL is defined as “a scientifically valid framework for guiding educational practice that (a) provides flexibility in
the ways information is presented, in the ways students respond or demonstrate knowledge and skills, and in the
ways students are engaged; and (b) reduces barriers in instruction, provides appropriate accommodations, supports,
and challenges, and maintains high achievement expectations for all students, including students with disabilities
and students who are limited English proficient.” by Higher Education Opportunity Act (PL 110-135). See the
National Center on Universal Design for Learning at http://www.udlcenter.org/.

The district has a UDL team, but it is composed of special education personnel only. In
that sense, it is not universal and excludes students without disabilities who might benefit
from the approach.
• Tier 2 Interventions. Because of inconsistent delivery of high-quality Tier 1 instruction, more
teachers are struggling to access and use evidence-base Tier 2 interventions. APS surveys of
teachers revealed that some teachers were using Pinterest and other websites to supplement
their inventory of interventions.
• Behavior. Although student behavior was a major reason for SAT referrals, APS does not have
a systemic framework for addressing these issues. In the past, APS used the well-known and
recognized positive behavior intervention and support (PBIS) model, but it no longer does.
Some schools, however, have continued their PBIS practices on their own. Nevertheless,
behavior is a primary focus of FBA/BIP, but they are used without a foundation of school-
wide and class-wide supports. This results in an undue reliance on these more complex and
difficult to implement FBA/BIP. Furthermore, student-focused interventions are less
worthwhile when there is no underlying and structured approach or professional development
designed to address school and class expectations and practices.
- Special Education Initiatives. The special education department purchased curriculum
designed for social/emotional learning, but it was applied only to special education classes.
Also, the department paid for counselor training and books for principals to support
positive behavior, but participation was voluntary and lacked universal buy-in.
- General/Special Education Collaboration. There does not appear to be much
collaboration between general and special education personnel to address behavior. The
two sets of personnel are perceived to be unnecessarily “siloed.” Although full and part-
time general education “redirectors” are available in elementary schools to deescalate
student behavior, there is not much interaction with special education personnel who also
address behavioral issues. The special education department’s training is available and
required for nonviolent crisis intervention (NVCI), but personnel from all schools have not
attended or set up crisis teams.
Generally, there is a misperception that supports students need to address behavioral needs are
readily available through special education, meaning that the special education solution is
applied to too many other students.
• English Learners. With the support of language and cultural-equity personnel, instruction for
ELs has improved over time. Focused efforts in 64 schools having the largest numbers of EL
students are being used to provide more support, assess use of the district’s curricular materials,
and determine the effectiveness of teaching and learning.
• Intervention Fidelity. Reportedly, principals sign a form to verify that intervention strategies
were implemented with fidelity. The form (SAT Tier 2 Required Signatures for SAT, Form
R12) requires the principal to sign statements about parental consent for additional screening,
speech/language screening results, and completion of Tier 2 interventions. The statements
contain a yes or no response to the provision of targeted, small group or individual instruction
provided in deficit areas and evidence that interventions had produced a positive response.
Neither of these statements address fidelity of implementation. There were significant concerns
from focus group participants about the extent to which interventions were implemented as

intended and whether intervention quality was assessed during the process. While interviewees
generally referred to using intervention programs or strategies, they were often viewed as a
necessary step “to get through the SAT” so students could be referred for a special education
evaluation.
• Instructional Coaches. APS’s general use of instructional coaches has been funded through
federal Title II funds. However, with reduced funding levels, this model does not appear to be
sustainable and is being reviewed. Instructional coaches have been juggling their instructional
duties with operational tasks that some principals require. Although most of their time is
supposed to be devoted to instruction, this does not happen consistently. Other duties often
include chairing SATs, acting as testing representatives, providing interventions, addressing
discipline, and acting as assistant principal when the principal is out of the building, etc.
• Professional Development. More funding was available in the past from a New Mexico
reading grant for kindergarten through second grade. As a result of cutbacks, professional
development has suffered for “first teaching” and tiered interventions. For example, to support
the implementation of Benchmark Advance, the curriculum/instruction department is relying
on district and school level personnel who have been trained as train-the-trainers. Another
training will take place at the beginning of 2019-20 in preparation for the new school year.
Reportedly, only principals and SAT chairs were offered training on the SAT process.
Child Find Implications

All school districts that have been reviewed by the Council team use an SAT-type process
to assess student progress and consider the need for a special education or Section 504 evaluation.
It is also typical for school districts to have general education administrators oversee the SAT
process. The process for identifying and determining a student’s need for special education or
Section 504 intervention is commonly known as “child find.” According to information provided
by APS, initiatives that relate to ensuring the appropriate referral of students for special education
evaluations over the last several years fall under the responsibility of school principals and other
school-based personnel. This approach, however, negates the importance and efficacy of
districtwide initiatives that leverage systemic resources and ensure broader and more uniform
implementation.
General Education Oversight
In the experience of the Council team, school districts generally charge their special
education departments with addressing child find concerns (also referred to as “failure to identify”)
that are raised through local, state, or federal complaints or through due process hearing requests.
This approach, however, sometimes creates the false impression that the special education
department should oversee the child find portion of the SAT process. It is commendable that APS
does not use this approach and instead addresses child find issues by giving the responsibility to
the curriculum/instruction unit. Having curriculum/instruction oversee the resolution of these
issues enables the district to better understand quality and implementation problems associated
with first teaching, interventions, the SAT process, and special education referrals. When the
Council team visited, APS was seeking to hire a compliance officer to oversee child find issues.
To support general education’s oversight of child find, all APS principals were trained prior
to the start of the 2018-19 school year. Also, each principal was responsible for training their staff

using resources provided by the district. Following training, principals were required to provide
documentation verifying that training had occurred with all staff. Training materials, however,
were not posted on the district’s Internet or Intranet.

According to focus group participants, the following issues affect the quality of the SAT
and child find processes.
• Implementation of SAT. While some interviewees reported that students who show little or no
improvement are required to participate in the SAT process for too long, others reported that
special education referrals were initiated prematurely, and students were not given an
appropriate amount of time to improve their reading and/or behavior.
• Access to Interventions. There was insufficient access to high quality and consistent Tier 2
interventions for students and uneven scheduling of their use.
• English Learners. Various SAT and other referral forms have been revised to address
language acquisition needs. In general, support for English learners was seen as having
improved, although most interviewees indicated that there was room for further improvement.
AREAS OF STRENGTH
The following were areas of strength in the district’s support for first teaching (i.e., tier 1),
interventions to improve academic and social/emotional well-being, and how they related to the
referral of students for special education evaluations.
• Leadership. APS’s assistant superintendent for equity, instruction, and support and her small
curriculum and instruction department have taken responsibility for leading and supporting
RtI, including Tier 1 and Tier 2 interventions. Strong principal leadership was given credit by
interviewees for some schools having stronger RtI practices.
• Intervention Programs. The district has various intervention programs available for students.
The district provides some guidance on their appropriate use and provides some progress
monitoring.
• Documenting Progress. APS has forms to document progress on the use of Tiers 1 and 2
reading, writing, and math interventions.
• SAT Dyslexia Characteristic Teacher Checklist is used for students referred for a special
education evaluation. The form’s checklist is useful for identifying various characteristics of
dyslexia and is a model for other Council-member districts.
• ELA/ELD Curricular Materials. APS has initiated a five-year instructional materials
purchasing plan to align instruction with Common Core State Standards. The vetting process
for materials involved a diverse group of stakeholders, including union representatives.
• English Learners. Instruction for ELs has improved with the support of language and culture-
equity personnel. Focused reviews of 64 schools having the largest numbers of EL students
have provided more support, assessed use of the district’s identified curricular materials, and
addressed the effectiveness of teaching and learning.
• General Education Leadership for Child Find. APS has given the curriculum/instruction

department the responsibility for addressing child find issues in recognition that the process is
triggered within general education—and is not solely a special education responsibility. This
is a model for other urban school districts. Given that APS has received a sizeable number of
complaints on this issue, having curriculum/instruction oversee their resolution enables general
education personnel to better understand how special education referrals are associated with
the quality of first teaching, interventions, and the SAT process.
OPPORTUNITIES FOR IMPROVEMENT

The following areas provide opportunities to improve MTSS implementation and the
reliability of special education referrals.
• Accountability. APS lacks an all-encompassing single line of accountability below the
superintendent for instruction and social/emotional supports of students. In addition, there are
competing priorities established by zone superintendents, curriculum/instruction staff, special
education personnel, principals, etc. As a result, administrative silos exist that do not support
a common vision, mission, or set of practices. Furthermore, the central office has not initiated
a structured or uniform set of procedures to support the appropriate referral of students for
special education evaluations. Rather, such activities are deemed to be under the responsibility
of school principals and other school-based staff. This approach, however, disregards the
importance and efficacy of districtwide initiatives that leverage systemic resources.
• Comprehensive Written Framework. APS does not have a comprehensive framework or
written guidance that includes and expands upon the state’s RtI framework of 2014. Although
PED’s guidance is in flux and not fully developed, the MTSS literature is well-established and
contains a consistent description of MTSS components that are found on multiple websites
across the country. Many of these could be used by APS to develop its own guidelines.
• SATs. Although it appears that schools have an SAT chairperson, the SAT process varies
across the district. When inadequate implementation causes special education referrals to be
returned, the evaluation process for students can be delayed. Also, there were concerns that the
SAT process in some schools was overloaded, which makes it difficult to function effectively
and meet expectations.
• Systemwide Implementation of Tiers 1 and 2 Processes. Generally, focus group participants
reported inconsistent implementation of RtI practices. When low-quality Tier 1 instruction was
provided, more teachers struggled to access and use evidence-based Tier 2 interventions.
APS’s teacher survey revealed that some teachers were using Pinterest and other websites to
supplement their inventory of interventions. Furthermore, the absence of a systemic framework
and districtwide support for positive student behavior contributes to the high proportion of
SAT referrals for behavioral issues. Although referral forms require the documentation of
behavioral interventions, this expectation is not uniformly done because of the absence of
school-wide and class-wide supports. The result is that the more complex and difficult to
implement FBAs and BIPs are unduly relied upon.
• Implementation Fidelity. Although there is a form for principals to verify the provision of
SAT-related Tier 2 interventions, the form does not address the extent to which interventions
are implemented. Furthermore, the quality and appropriateness of interventions are not
assessed. Focus group participants generally referred to interventions as necessary “to get
through the SAT” and proceed to a special education referral.

• Tier 3 Interventions for Special Education. Although PED’s website28 specifies that Tier 3
interventions are designed for special education, not all students receiving special education
require Tier 3 interventions. Depending on a student’s profile, some might benefit from Tier 1
and 2 interventions as well.
• SAT Meeting Summary Form and Follow-up Form. The SAT meeting form does not include
an option for referring students for a Section 504 evaluation. Other than its reference to
implementing a BIP, the follow-up form (R5) does not address whether interventions have
been implemented with fidelity.
• Follow-up SAT Meeting Summary Form (Form R5). The SAT is designed to document the
success of Tier 2 interventions. No option is specified for initiating a referral for a Section 504
evaluation,
• Speech Interventions. APS does not offer Tier 1 support for students in the area of
speech/language support. Services are offered only with a speech/language evaluation showing
the need for special education. Many urban districts now offer such services through the MTSS
framework to address relatively minor speech/language issues that could be addressed through
Tiers 1 and 2 interventions.
• SAT Student Observation. Information on the observation form focuses on a student’s learning
and behavior. However, it does not include any prompts, check lists, or narrative on a teacher’s
interactions with the student. By comparison, the New Mexico RtI manual indicates that the
SAT should consider whether Tier I instruction was appropriately differentiated, and to
consider such factors as teaching and learning preferences, the possible lack of instruction, etc.
• Problem-Solving. APS training materials do not contain information about the problem-
solving process, which is a structured set of practices for reviewing and discussing a student’s
progress monitoring results and next steps.
• Instructional Coaches. With reduced Title II funds, APS is reconsidering the sustainability of
the instructional coach position. There are also concerns about the use of instructional coaches
for school activities unrelated to their official job responsibilities, e.g., addressing discipline,
acting as assistant principals when principals are out of the building, chairing SATs, etc.
• Professional Development. Due to reduced Title II funding, professional development related
to first teaching and the SAT/RtI process have been reduced. The need for more training was
a recurring theme in focus group meetings.
• Child Find. There was considerable variability in the length of time students were engaged in
the SAT process and what constituted enough student progress. Reportedly, students showing
little or no improvement engaged in the SAT process for too long, while others were referred
for special education evaluations prematurely. Neither the New Mexico manual nor APS
training materials provided guidance for streamlining this process for students with obvious
disabilities, e.g., severe/profound intellectual disability.
In addition, the concerns described throughout this section of the report broadly contribute
to issues around the quality of APS’s special education child find activities.
28
Retrieved from https://webnew.ped.state.nm.us/bureaus/safe-healthy-schools/response-to-intervention-rti/

RECOMMENDATIONS
The following recommendations are offered to improve APS’s implementation of first
teaching and its system of multi-tiered interventions for all students.
Align Academic Support for All Students. Revise APS’s organizational structure to align
administrative support for teaching/learning to better leverage district resources. Either have
all associate superintendents report to a deputy superintendent or a chief education officer, and
promote the curriculum/instruction leadership position to the associate superintendent level to
reinforce the importance of this function. (For these recommendations, the term deputy
superintendent is used.) Establish expectations for collaborative decision-making and program
implementation across department’s in the district. For example, these more coordinated
activities would include the:
• Selection and implementation of new curricular materials, use of universal design for
learning strategies, training activities, and the solicitation and implementation of district
grants.
• Collaboration between general and special education personnel to address academic and
behavioral concerns, while ensuring that compliance responsibilities were being met.
Multi-tiered System of Supports. Even though the New Mexico’s PED framework for tiered
instruction and interventions is in flux, there is overwhelming consistency in the educational
literature on the components of an effective MTSS framework. The nature of this work is too
important for APS to wait for state guidance. Rather, the district should immediately build on
its SAT and RtI practices to develop/implement a framework of MTSS in academic
achievement, positive behavior, and social/emotional growth--for all students. 29 Consistent
information is readily available nationwide for this purpose. It is highly likely that state
guidance will be founded on the same literature.
The Council team has chosen to use the term MTSS because of its universal meaning in the
educational literature and its use in the federal Literacy Education for All, Results for the
Nation Act (LEARN Act), H.R. 2272, which authorizes state grants to improve literacy at birth
through grade 12. This broad usage makes it easy to find relevant information in any internet
search. The term that PED is reportedly using, i.e., “multi-levelled services and support”
(MLSS), is not in use outside the state. If PED is not convinced to change the term, we
recommend that APS maintain the term MTSS. In any event, the district should clarify to
stakeholders that the framework is essentially MTSS to avoid confusion and maximize use of
resources publicly available across the country.
a. Board Policy and Vision. Establish a school board policy in support of the district’s MTSS
framework (for academics and behavior). The policy should indicate that, when high-quality
Tier 1 instruction is provided and is effective, fewer teachers will need to access and use
evidence-based Tier 2 interventions. When first instruction and interventions are successful,
the MTSS framework ceases to be a process to “get through” in order to justify special
29
The term MTSS is used generically because of its universal meaning in educational literature and its use in the
federal the Literacy Education for All, Results for the Nation Act (LEARN Act), H.R. 2272, which authorizes state
grants to improve birth through grade 12 literacy. APS may choose instead to use the term adopted by PED, multi-
levelled services and support (MLSS).

education referrals. Charge the administration with developing and implementing an MTSS
framework and roll-out plan. Expect that the framework will be used, and that it includes all
grades, students, and supports to provide linguistically appropriate/culturally competent
instruction. Require school-based MTSS implementation plans, e.g., 90-day plans. Have APS
modify the district plan and school plans as the district gains experience with it.
b. District, Zone and School Leadership Teams. Establish leadership teams at the district, zone,
and school levels to support MTSS planning and implementation activities. These activities
could be delegated to existing teams and augmented with personnel who are able to absorb
and carry out the work.
• District MTSS Leadership Team. Have the deputy lead and oversee the development and
implementation of MTSS across the system, using a broad, diverse, and representative team
of stakeholders from district, zone, and school levels. When completed, schedule a two-
day overview for staff and monthly meetings for the MTSS leadership team to ensure use
of a common language, high-quality implementation, and effective resource allocations.
• Zone MTSS Leadership Teams. Have each zone establish an MTSS leadership team with
principals and representatives of zone-based administrators and school personnel who
would be responsible for implementation.
• School-Based Leadership Teams. Based on the district’s MTSS-implementation plan
(Recommendation1c below), establish school-based leadership teams to provide
training/guidance on activities that could be incorporated into each school’s 90-day plans
or other school-improvement plans. These teams should lead each school’s MTSS work to
ensure a common understanding of the framework at the building level. The teams should
also have defined responsibilities, such as providing professional development and
technical assistance, monitoring implementation and supports, and reviewing student data.
c. Implementation Plan. Charge the districtwide MTSS team with developing a written multi-
year action plan with expectations, professional learning, data analytics, and accountability
measures. Identify an aggressive time frame for implementation with short and long-term
objectives. Engage ATF representatives during the development process to address concerns
and maximize buy-in. Disseminate the draft framework to stakeholders, including parents
who are English learners, and obtain their feedback prior to the framework’s finalization.
Incorporate components from the MTSS literature, including universal screeners, formative
assessments, standard protocols for interventions/supports, curricular materials, supplemental
and intensive resources, data platforms, use of data, professional learning, budget allocations,
etc. Make clear that the framework includes all students, including students with disabilities,
English learners, and accelerated learners. Include the following components in the MTSS
framework–
• Framework Design. Review information from PED as well as credible websites, such as
Florida’s Multi-Tiered System of Supports,30 to address recognized MTSS components.
• Department Alignment. Require each department to align staff and priorities to support
the MTSS plan’s implementation. Ensure department deliverables are collaboratively
developed and do not produce competing priorities across schools.
30
Retrieved at http://www.florida-rti.org/floridamtss/index.htm.

• UDL. Embed universal design for learning (UDL) principles into the MTSS framework,
expanding its reach beyond special education by involving technology and general
education in the process.
• Involvement of Students with Disabilities. Although PED associates Tier 3 interventions
with special education, make clear that students with disabilities will not be excluded from
core instruction along with Tier 1 and Tier 2 interventions.
• School-wide Behavior Supports. In addition to work being done to support “first
teaching,” set expectations that schools will provide social emotional learning (SEL) as
part of its MTSS work. This might include the use of a SEL curriculum, community
wraparound services, and the development/implementation of districtwide positive
behavioral intervention and supports. The implementation of behavior interventions or
FBAs/BIPs is not meaningful without a foundation of school-wide and class-wide supports.
• Speech Interventions. Consider how speech/language services can be provided as part of
Tier 1 and Tier 2 interventions. This service model is now more common in urban school
districts nationwide.31
• Implementation Fidelity. Ensure that observation forms for student learning/behavior
include appropriate Tier 1 instruction, including its differentiation; and that other forms
used by principals/others include components on the appropriateness of selected
academic/behavior interventions. Ensure that interventions are implemented as intended,
i.e., with fidelity.
• Instructional Coaches. As part of the district’s review of instructional coaches and the
sustainability of their positions, clarify the extent to which coaches are used for non-
instructional duties, such as addressing discipline, acting as assistant principals when
principals are out of the building, chairing SATs, etc.
• Instructional Rounds. Develop indicators on the district’s instructional rounds to monitor
whether MTSS components are being put into place. Use follow-up rounds to track trends,
identify strengths, and determine action steps. Ensure that instructional-round teams
monitor the needs of multiple student groups.
• Exemplary Implementation Models. Provide a forum where school and zone personnel
can highlight and share best practices, lessons learned, victories, and challenges in
implementing MTSS for all student groups. Identify and encourage staff to visit exemplary
schools and set aside time for that to happen.
• District Website. Develop a highly visible, well-informed, and interactive web page
highlighting the district’s MTSS framework. Include links to other local and national sites.
Highlight schools in the district that are showing results with this approach and share
stories and data on the effect of MTSS on student outcomes.
• Communication. Communicate with all internal and external stakeholders, ATF
representatives, parents (including those who are English learners) and others about the
purposes and expected outcomes of the plan. Consider commissioning a survey of all
stakeholders to obtain regular feedback on implementation and areas needing follow-up.
31
For example, see SPLI and MTSS, retrieved from http://www.nsseo.org/wp-content/uploads/MTSS-SLPs.pdf.

• Map Resources and Analyze/Address Gaps. As part of the MTSS planning process, assess
current human resources and instructional materials provided by the district or funded
through schools to ascertain their effectiveness and return-on-investment in terms of
improved student outcomes. Compare the value of resources and materials currently in use
in the district with other evidence-based resources in the marketplace and replace low-
value resources currently being used. Establish a menu of increasingly intensive
interventions and resources, which should be vetted against current evidence on
effectiveness and alignment. Ensure that the menu of interventions differentiates levels of
intensity, criteria for use, and contains strategies that are linguistically and culturally
appropriate for a diverse student population. Consider how federal Title I resources could
enhance, supplement, or pay for more effective interventions. If necessary, phase in new
interventions over a reasonable number of years.
d. Written MTSS Guidance. Develop written guidance on the MTSS framework that is
sufficiently specific to develop universal understanding of core principles. As part of the
guidance, address SATs, their composition, roles, responsibilities, and protocols for referral
to special education evaluations. Include reasonable time frames from referrals to parental
consent for evaluation. Incorporate information that reflects APS expectations, including
minimum requirements and areas of flexibility for schools. Have a broad group of
stakeholders review the draft guidance to ensure that it is user-friendly and has no unintended
consequences. Address the high proportion of students found to have an emotional
disturbance at the high school level and its potential relationship to instruction/behavioral
supports. (See later sections of this report.) Also, include in SAT materials information on
Section 504 as a follow-up option. When finalized, post the guidance on the district’s MTSS
webpage with links to more detailed materials, forms, and information publicly available on
the internet.
e. Differentiated Professional Learning. Incorporate the MTSS framework, its implementation,
and written guidance into the district’s professional development program or plan. Ensure that
critical audiences, i.e., general/special educators, related-services personnel,
paraprofessionals, and parents have access to the training. Provide at least four to five days of
training each year, if possible, for school-based MTSS leadership teams over the next two
years. Base training on the Learning Forward Standards for Professional Learning. Consider
how it will be funded, e.g., through stipends, funds for substitute coverage, incentives for
after-school and Saturday training, or summer training. Also, consider how training will be
differentiated and sustained. In addition –
• Access to Differentiated Learning. Ensure that professional learning is engaging and
differentiated based on individual skills, experience, and need. Have professional learning
and technical assistance continue for new personnel and those needing additional support.
• Multiple Formats. Use multiple formats (e.g., videos, webinars, and narrative text) and
presentation approaches (e.g., school-based, small groups).
• Coaching/Modeling. Develop a plan to provide coaching and technical assistance to
principals and school-based leadership teams on practices covered in training sessions and
materials.
• Cross-Functional Teams. Cross-train individuals from all departments working with
schools to ensure a common language and understanding of MTSS. This will help align

and support schools as they work on implementation. Provide direct support, mentoring,
coaching, and technical assistance to principals and teachers on implementation.
• High-Quality Trainers. Identify staff members at all levels who are knowledgeable about
and experienced in the components of MTSS and deploy them as professional developers.
Supplement these staff members with experts from outside the school district.
f. Data Analysis and Reports. Review current data collection, analyses, and reports and
supplement them with indicators or metrics that would be useful in determining whether
schools use MTSS practices and their relationship to student achievement, e.g., growth based
on appropriate instruction and intensive interventions.
g. Monitoring and Accountability. Evaluate the implementation, effectiveness, and results of
MTSS, and include the following–
• Baseline Data and Fidelity Assessments. Use the Self-Assessment of MTSS (SAM) or
other similar protocols for schools to self-assess their MTSS practices. Have network and
districtwide leadership teams periodically review these self-assessments for reliability.
Incorporate SAM results into the school review process to assess fidelity to the framework.
• Data Checks. Using data and charts such as those provided in this report, have the
superintendent, deputy superintendent, and other leaders host regular data conversations
with departments, zone superintendents, and principals to discuss results, anomalies,
needed supports, follow-up activities, and outcomes.
• Timely Communication and Feedback. Assign responsibility for communicating the
MTSS work to stakeholders via multiple channels, e.g., website, television, radio, social
media, etc. Design feedback loops with central office, school personnel, parents, and the
community to assess problems and successes on the ground. Use this feedback to provide
regular and timely information to the district MTSS leadership team on where and how
schools require additional assistance. Consider presenting a bi-annual report to the board
on MTSS to emphasize buy-in and ensure that the highest levels of the district understand
what the system is doing to address its many special education challenges.
Recommendations to improve the district’s identification of students with disabilities are

included in Section II below, Disability Demographics.

II. Disability Demographics

This section presents demographic data on APS students with disabilities who have
individualized education programs (IEPs).32 When available, APS data are compared with students
at state and national levels and with other urban school districts across the country.
In addition, data were analyzed by grade, race/ethnicity, and English learner (ELs) status,
so readers can fully understand the context in which APS services are provided. This section also
provides information on special education evaluations and the timeliness of IEPs and placements.
District Prevalence Rates

In this subsection, the percentage of APS students receiving special education services are
compared to urban school districts across the country and to the nation. Also, incidence data are
disaggregated on early childhood and kindergarten children, and school-age students by disability
area, grade, race/ethnicity, and English learner status.33
Comparison of APS, Urban Districts, National, and State Special Education Rates
APS enrolls 15,890 students with IEPs in elementary, middle, and high schools. This
number comprises 19.4 percent of 81,895 students enrolled across these grade levels. This figure
is higher than the average of 13.1 percent across 76 urban school districts on which we have data.34
Among these urban districts, APS ranks 67th in the percentage of students with IEPs, which ranged
from 8 percent to 21 percent.35 The district’s special education rate is also higher than the 15.6
percent state rate and the 13.3 percent national figure, which has decreased since 2004-05 when it
was 13.8 percent.36 (See exhibit 2a.)
Exhibit 2a. Special Education Percentages for the District, Surveyed Districts, Nation, and State
25%
20%
15%
10%
5%
0%
District State Urban Districts Nation
Percentage 19.4% 15.6% 13.1% 13.3%
32
Students with disabilities who have IEPs and receive special education services are also referred to as students
with IEPs. These data are limited to students with a disability under the IDEA and does not include students with
Section 504 plans. Also, the data does not include students who are gifted.
33
Unless otherwise stated, all APS data were provided by the district to the Council team and are for the 2017-18
school year.
34
Most data were provided by school districts that responded to a survey conducted by the Urban Special Education
Leadership Collaborative; the Council team or a member of the team obtained the remaining data during district
reviews. The rates by district are provided in Appendix A. Incidence Rates and Staffing Survey Results.
35
The data cover several years, but in most cases, ratios do not change dramatically from year to year.
36
U.S. Department of Education, Part B Child Count data based on students 3 through 21 years of age (2016-17).
ttps://www2.ed.gov/programs/osepidea/618-data/static-tables/index.html#partb-cc

Rates by Disability Areas for District, State and Nation

Data in exhibit 2b show the percentage of students in the district, state, and nation by the
most common disability areas. These disability areas include specific learning disability (SLD),
speech/language impairment (S/L), other health impairment (OHI), autism, developmental delay
(DD), and emotional disturbance (ED). Less prevalent disabilities are combined as “other.”
Similarities and differences are described below.
• APS Similar to State and Nation. APS data are like state and national data in the areas of
autism (8 percent, 6 percent, and 10 percent, respectively) and “other” (4 percent each).
• APS Similar to State. APS data are like the state in the areas of OHI (7 percent and 9 percent,
respectively) and ED (3 percent and 4 percent, respectively). However, the rates for both
categories are much smaller than the nation’s 14 percent for OHI and 6 percent for ED.
• APS Different from Nation. APS is significantly different from the nation in the following
areas: SLD (58 percent and 34 percent, respectively); S/L (10 percent and 20 percent,
respectively); OHI (7 percent and 14 percent); and ED (3 percent and 6 percent).
• APS Different from State. In the area of ID, APS’s 4 percent rate is much smaller than the
state’s 10 percent rate but more like the nation’s 6 percent rate.
Exhibit 2b. Percentage of Students with IEPs by District, State, and Nation 37
60%
50%
40%
30%
20%
10%
0%
SLD S/L OHI Autism DD ED ID Other
APS 58% 10% 7% 8% 7% 3% 4% 4%
State 46% 18% 9% 6% 4% 4% 10% 4%
National 34% 20% 14% 10% 5% 6% 6% 4%
Specific Learning Disability

In the area of SLD, the 9,063 identified students constitute more than half of all APS
students with IEPs. Notably, the appropriate evaluation and diagnosis of SLD relies heavily on a
student’s receipt of high-quality instruction and intervention (e.g., RtI) and SAT implementation.
Rather than an APS special education procedural manual, the district relies on the NM
TEAM (Special Education) Manual. 38 As explained in the Manual, New Mexico has established
37
National and state data are based on the U.S. Department of Education’s 2014 IDEA Part B Child Count and
Educational Environment database, (2016-17). Retrieved from https://www2.ed.gov/programs/osepidea/618-
data/static-tables/index.html#partb-cc. Unless otherwise stated, all APS data were provided by the district to the
Council’s team.
38
Retrieved from https://intranet.aps.edu/departments/curriculum-instruction/sat/sat-manuals/nm-team-2017-
1.pdf/view.

two SLD eligibility models: severe discrepancy and dual discrepancy. 39 Eligibility determination
teams must use the dual discrepancy model for students in kindergarten through third grades. The
model is optional for students in fourth through sixth grades,
Dual Discrepancy Model

Unlike the severe discrepancy model, the New Mexico TEAM Manual explains that the
dual discrepancy analysis is dependent upon frequent (at least bi-weekly but ideally weekly or
semi-weekly), reliable, and appropriate progress-monitoring data, and a comprehensive RtI
system.
According to New Mexico’s webpage, RtI Framework and Specific Learning Disabilities
(SLD), the dual discrepancy model gives educators a broader view of how the student learns
compared to the snapshot obtained from utilizing a single discrepancy model. 40 The model utilizes
progress-monitoring embedded in the RtI framework to yield data on instructional design and
delivery. In this way, educators can better distinguish a student who truly has a learning disability
from one whose learning difficulties could be addressed with scientifically based, general
education interventions.
Dual discrepancy requires two factors to be met in addition to standard criteria required for
SLD: (1) level of achievement; and (2) slope of improvement.
• Factor 1, Level of Achievement: The student demonstrates a pattern of performance that is (a)
consistent with at least one SLD area (e.g., basic reading skills) and (b) documented using a
1.5 standard deviation.
• Factor 2a, Rate of Improvement (Growth). Data are analyzed to determine if the student is
making adequate progress to meet age or state approved grade-level standards directly related
to at least one SLD area. Using frequent (at least bi-weekly but ideally weekly or semi-weekly)
progress-monitoring assessment data (collected at least bi-weekly but ideally weekly or semi-
weekly), insufficient progress is based on a difference of 1.5 standard deviations between the
student’s assessment growth (slope) and the rate of improvement of same-grade peers within
APS. If the student does not meet Factor 2a or if the data are unavailable due to the school’s
and/or district’s procedures, EDTs may consider Factor 2b: Patterns of Strengths and
Weaknesses.
• Factor 2b, Pattern of Strengths and Weaknesses. This pattern is evidenced by multiple data
points from a variety of sources. The pattern may be present in the child’s performance,
achievement, and/or cognitive abilities relative to age or state-approved grade level standards.
Severe Discrepancy Model
Simply stated, under this model students must demonstrate a severe discrepancy between
his/her predicted achievement level and actual achievement in the area(s) of concern based on
standardized assessment scores. Although the model does not include the production or review of
39
Additional criteria that are fully described in New Mexico also apply to the determination of SLD eligibility.
40
New Mexico Criteria for Identifying Students with Perceived Learning Disabilities: Subsection C of 6.31.2.10
NMAC, retrieved at https://webnew.ped.state.nm.us/bureaus/safe-healthy-schools/response-to-intervention-
rti/special-education-resources/.

progress-monitoring data produced through the RtI framework, eligibility-determination teams

may use the pattern of strengths and weaknesses summarized above.
Implications for APS
Without a district special education procedural manual, each eligibility-determination team
must rely on state guidance on the use of the dual discrepancy model and use progress-monitoring
or strength/weakness patterns related to the discrepancy model. It would be useful for APS to have
locally written guidance and training for eligibility-determination teams to support their
determinations of SLD eligibility. This would be particularly useful in making eligibility
determinations in disability areas in which APS data are significantly different from state and/or
national rates.
APS Disability Rates by Grade Levels
The team also examined the percentage of APS students with disabilities by grade level.
The results show that percentages are comparable for elementary, middle, and high school levels
for the disability areas of SLD, OHI, and autism. (See Exhibit 2c.) As typical of school districts
across the country, a much higher percentage of students in APS are identified as S/L (86 percent)
at the elementary level than at the middle (8 percent) and high school (6 percent) levels. It is also
typical for students with ID to have a higher percentage at the high school level (51 percent)
compared to the elementary (23 percent) and middle school (25 percent) levels because some
students remain in school until the age of 21 years to receive transition services and activities.
The area of ED is notable because a much higher percentage of students is present at the
high school level (45 percent) than at the elementary (26 percent) and middle school (29 percent)
levels.41 Having almost half of all ED students at the high school level raises questions about the
district’s quality and effectiveness of behavior interventions for younger students and about the
integrity of evaluation/eligibility processes.
Exhibit 2c. Percentage of Students with IEPs by Disability and Grade Leve
100%
80%
60%
40%
20%
0%
SLD S/L OHI ED Autism ID
Elementary 34% 86% 36% 26% 33% 23%
Middle 33% 8% 29% 29% 29% 25%
High School 33% 6% 35% 45% 38% 51%
Disability Incidence by Race/Ethnicity

This subsection covers the extent to which APS students from each of the most common
racial/ethnic groups are proportionate to each other by disability. According to APS’s latest 2016-
17 State Performance Plan/Annual Performance Report (SPP/APR), which was published on
41
Unlike students with ID, students with ED do not remain in school to receive transition services until the age of 21
years

August 9, 2018,42 disproportionate representation begins with LEAs having an “n” size of greater
than 10 students in a racial/ethnic group/disability category and a risk ratio of 3.0 or above for
students aged 6 to 21 years of age.
Based on APS data, no racial/ethnic group of students with IEPs have a risk ratio close to
“2.” A risk ratio of two means that one racial/ethnic group of students would be twice as likely as
students from any other racial/ethnic group to have a disability. American Indian students have the
highest risk ratio (1.29) and Asian students have the lowest (0.4). Exhibit 2d shows race/ethnic
risk ratios on each disability area. White students were 2.08 times more likely to have autism
compared to students of any other racial/ethnic group. No other racial/ethnic group had a risk ratio
over 2.0, although black students had a relatively high 1.89 risk ratio in the area of ED. Two
racial/ethnic groups had risk ratios above 1.2 –
• Hispanics had a risk of 1.61 for specific learning disability, 1.78 for speech/language
impairment, and 1.28 for intellectual disability.
• American Indians had a risk ratio of 1.32 for specific learning disability.
Exhibit 2d. APS Risk Ratios Above 1.3 by Racial/Ethnic Group and Disability
2.50
2.00
1.50
1.00
0.50
0.00
SLD Autism S/L ED ID
Hispanic 1.61 1.78 1.28
White 2.08
American In 1.32
Black 1.89
English Learners and Disability

In this section data were analyzed for English learners with disabilities. Overall, 19.9
percent of all APS students had an IEP, while 24.9 percent of all ELs had IEPs. EL students were
1.74 more likely than non-ELs to have an IEP. Although this risk ratio was relatively high, it is not
significantly so.
Exhibit 2e. Number of APS English Learners with IEPs
30% 2
25% 1.5
20%
15% 1
10% 0.5
5%
0% 0
Percentages & Risk Ratio
% All Students w/IEPs 19.9%
% ELs of All Students 16.0%
% ELs w IEPs of all IEPs 24.9%
% ELs with IEPs of All ELs 28.0%
EL Risk Ratio 1.74
42
Retrieved at https://webnew.ped.state.nm.us/wp-content/uploads/2018/05/APR-FFY-2016-SYU-2016-2017-
Submitted-to-OSEP-April-2018.pdf.

Composition of All EL and Non-EL Students by Disability Area

Data in exhibit 2e show the percentage of all EL and non-EL students by disability area.
The areas of specific learning disability and intellectual disability had the largest disparities.
• Specific Learning Disability. Of all ELs with IEPs, 20 percent were categorized SLD
compared to 8 percent of non-ELs.
• Intellectual Disability. Of all ELs with IEPs, 1.83 percent were categorized as ID compared to
0.51 percent of non-ELs.
Exhibit 2e. Number of APS English Learners with IEPs by Grade
25%
20%
15%
10%
5%
0%
SLD S/L OHI Autism ED ID DD Other
All ELs 20% 1.5% 1.1% 1.4% 0.7% 1.83% 0.7% 0.9%
Not EL 8% 1.8% 1.3% 1.3% 0.6% 0.51% 1.4% 0.6%
EL Risk Ratios
As discussed above, EL students were represented in the areas of specific learning
disabilities and intellectual disabilities to a greater extent than were non-EL students. Using a risk
ratio measure, compared to non-EL students, ELs were 2.36 times more likely to have an SLD and
3.59 times more likely to have an ID (see exhibit 2f.). Although the disproportionality of ELs
compared to non-ELs was not a component of the federally required state performance plan, it is
an important area to address in identifying significant disparities. The presence of these disparities
justifies a review of the district’s RtI/SAT procedures and practices for English learners to ensure
that English language acquisition and cultural considerations are addressed appropriately.
According to APS representatives, new evaluation forms include consideration of language
acquisition.
Exhibit 2f. Risk Ratios for ELs Compared to Non-ELs by Disability Areas
20% 4
3.5
15% 3
2.5
10% 2
1.5
5% 1
0.5
0% 0
SLD ID
EL % 19.98% 1.83%
Not EL % 8.45% 0.51%
EL RR 2.36 3.59

Special Education Referral, Eligibility, and Timeliness

The Council team requested data for the 2017-18 school year on the number of students
initially referred for an evaluation, and the number of those referred who were determined to be
eligible. APS provided data only for the 2015-16 school year. That data shows that in 2015-16,
1,926 students were initially referred. Of the 1,843 of those students with complete evaluations,
82.8 percent were found to qualify for special education. The percentage of students found not
eligible could be improved with better screening activities to more effectively utilize valuable
assessment time and reduce unnecessary student testing.
Timeliness of Evaluations
According to APS, the district had a 100 percent compliance rate 43 for evaluations and IEPs
conducted by APS schools in 2017-18. The charter school rates were less than 100 percent;
however, APS representatives reported that the rates have improved.
Evaluation Data
Focus group participants indicated that evaluation-center instructional managers do not
have on-time access to evaluation data to regularly review eligibility and other relevant data.
Access to this type of information is necessary to monitor patterns and trends and to take follow-
up action as needed.
AREAS OF STRENGTH
The following are areas of strength for APS related to disability prevalence rates,
evaluation outcomes, and IEP timeliness.
• Disability Area Rates. APS’s identification rate in the area of autism is like state and national
rates, and rates for other health impairments and emotional disturbance are like state rates.
(Exhibit 2b)
• Disability Area Rates by Grade Level. Generally, disability rates by area are consistent across
elementary, middle, and high school levels.
• Disability Area Risk Ratios by Race/Ethnicity. APS students in any racial/ethnic group are
not any more likely to qualify for a disability category compared to students in any other
racial/ethnic group. (Exhibit 2d)
• English Learner Disability Risk Ratios. English learners are 1.74 times more likely than non-
ELs to have an IEP. Although this risk ratio is relatively high, it is not significantly so. (Exhibit
2e) New evaluation forms include the consideration of language acquisition.
• Evaluation Timeliness. APS personnel completed all district special education evaluations in
a timely manner. Although the charter school rate is slightly lower, the rates have improved
from prior years.
43
Team questioned this 100 percent evaluation rate since there were numerous comments and questions form
interviewees about the timeliness of diagnostician responsiveness to requests for evaluations through the centers.


The following areas provide opportunities for APS to address disparate prevalence rates,
evaluation outcomes, and IEP timeliness.
• Overall Disability Rate. Overall, 19.4 percent of APS students in elementary, middle, and
high schools had IEPs. This figure was higher than the 13.1 percent average across 76 urban
school districts on which we have data. Only nine districts had an IEP rate higher than APS’s.
The district’s special education rate was also higher than the 15.6 percent state rate and the
13.3 percent national figure. (Exhibit 2a)
• Disability Area Rates. APS rates were much different from national rates in the areas of
specific learning disability (58 percent and 34 percent, respectively); speech/language
impairment (10 percent and 20 percent, respectively); other health impairment (7 percent and
14 percent); and emotional disturbance (3 percent and 6 percent). The district’s 4 percent rate
for intellectual disability was much smaller than the state’s 10 percent rate. (Exhibit 2b)
• Specific Learning Disabilities. More than half (58 percent) of all elementary through high
school level students with IEPs had a specific learning disability. This figure was much higher
than rates for the state (46 percent) and nation (34 percent). Notably, the appropriate evaluation
and diagnosis of SLD relies heavily on a student’s receipt of high-quality instruction and
intervention (e.g., RtI) and SAT implementation. Various weaknesses in APS’s
implementation of the SAT/RtI processes, as described earlier, might easily be associated with
the district’s high SLD rate and overall identification rates.
• High School and ED. A much higher percentage of students were identified as having an
emotional disturbance at the high school level (45 percent) than at the elementary (26 percent)
and middle school (29 percent) levels. Having almost half of all ED students present at the
high school level raised questions about the district’s quality and effectiveness of behavior
interventions for younger students and the integrity of evaluation/eligibility processes. (Exhibit
2c)
• Disability Area Risk Ratios by Race/Ethnicity. Using a risk ratio methodology, white students
were 2.08 times more likely to have autism and black students were 1.89 times more likely to
have an emotional disturbance compared to students from other racial/ethnic groups. Although
these risk ratios may not be considered by the state to be significant, they would present cause
for concern in other districts. (Exhibit 2d)
• EL and Non-EL Disability Area Rates. In the areas of specific learning disabilities and
intellectual disabilities, ELs with IEPs were disproportionately represented compared to non-
ELs. ELs were 2.36 times more likely than non-ELs to have an SLD (20 percent of ELs
compared to 8 percent of non-ELs). Also, ELs were 3.59 times more likely than non-ELs to
have an ID compared to non-ELs (1.83 percent of ELs compared to 0.51 percent of non-ELs).
(Exhibits 2e and 2f)
• Monitoring Evaluation Referrals and Qualification Rates. Based on 2015-16 data, 82.8
percent of all students referred for an evaluation were found to be qualified. This percentage
might be improved with better screening activities to more effectively utilize valuable
assessment time and reduce unnecessary student testing. Furthermore, data for the two
subsequent school years should have been available for the Council team to review.

• Access to Evaluation Data. Evaluation-center instructional managers do not have real-time

access to evaluation data to regularly review eligibility and other relevant data. Access to this
type of information is necessary to monitor patterns and trends and to take follow-up action as
needed.
RECOMMENDATIONS
The following recommendations are offered to address APS’s unusual demographic
patterns concerning students with disabilities and the high rates of students suspected of needing
special education/related services.
Demographics, Referral and Identification of Disability. Improve the overall consistency and
appropriateness of special education referrals, assessments, and eligibility decisions.
a. Data Review. With multi-disciplinary representatives of the district’s MTSS leadership team,
review exhibits 2a through 2f. Include staff from curriculum/instruction, English learners, zone
superintendents, special education administrators, and principals in these reviews. (Coordinate
this activity with Recommendation 2b.) Have the team develop hypotheses about patterns in
the data presented in this section. In addition, examine data on the same variables by zone and
school.
b. Implementation Plan. Based on these data and staff member’s hypotheses about why the
patterns look like they do, embed in the MTSS implementation plan activities to improve the
SAT process for each disability area of concern. Also, ensure that evaluation center
instructional managers have real-time access to evaluation data to regularly review eligibility
and other relevant data, to monitor patterns and trends, and to allow them to take follow-up
action as needed. To support this process, consider hiring a short-term external consultant
with expertise in special education assessments for disability areas of concern. Review APS’s
current practices (including referral-review processes), configurations of assessment
personnel (educational diagnosticians/ psychologists), assessment quality, and assessment
centers. (Coordinate this activity with Recommendation 2c.)
c. Written Expectations. For each disability area of concern, review district processes, including
referrals, assessments, and eligibility, and amend them to provide more specific guidance. In
coordination with Recommendation 2e, develop schedules for ensuring that the child find
process is carried out within a reasonable period. Incorporate this guidance into a
comprehensive electronic special education manual. Make the manual publicly available. 44
Obtain feedback to the draft language to ensure it is clear and does not trigger unintended
consequences.
Ensure that issues raised in the Council team’s report are addressed, including –
• SAT Practices. Establish protocols for SATs, assessments, and IEP teams to use to support
special education decision-making. Specifically address processes connected with
disability areas where APS is an outlier, including specific learning disabilities, emotional
disturbance at the high school level, white students with autism and black students with
44
For example, see the Los Angeles Unified School District Electronic Policies and Procedures Manual, retrieved at
https://achieve.lausd.net/site/Default.aspx?PageID=14466.

emotional disturbance, and high proportion of English learners with a specific learning
disability or an intellectual disability. (Coordinate this activity with Recommendation 2c
and 2e.)
• English Learners. In coordination with language and cultural equity administrators,
incorporate in the procedural manual information on Els with disabilities.
• Lack of Progress. Provide guidance on evaluating whether students have made adequate
progress after being provided appropriate interventions that were implemented with
fidelity. Consider time lines for remedial actions if the SAT suspects a student needs special
education but documentation is incomplete because of missing information or appropriate
interventions were not implemented with fidelity. APS might consider creating a portal
that would store and share vital SAT elements with teachers and stakeholders to ensure
interventions are provided.
• Exiting Special Education. Establish guidelines for determining when and under what
circumstances a student no longer needs special education to progress educationally. A
transition to services under Section 504 might be appropriate for such students.
d. Differentiated Professional Learning. Plan for and provide all relevant district stakeholders
with the professional development they need to implement activities listed in
Recommendation 3. (Coordinate this activity with Recommendation 2f.)
e. Data Analysis and Reports. Develop and provide regular user-friendly reports to district
leadership showing data like those in exhibits 2a through 2f. If possible, show initial data
related to disability determinations based on the students’ school at the time of eligibility to
determine whether eligibility was shaped by school-based factors. Share data by zone and by
schools within zones. (Coordinate this activity with 2g.)
f. Monitoring and Accountability. Develop a process for ongoing monitoring of expected
referrals, evaluations, and eligibility practices. Rather than using a traditional record-review
compliance model, review data with schools so that they are aware of problems, and they are
better prepared for follow-up action. Enable staff to observe best practices and receive
coaching that will improve their knowledge and skills. (Coordinate this activity with
Recommendation 2h.)

III. Teaching and Learning for Students with Disabilities

The U.S. Department of Education has moved from a compliance-only posture in special
education to a Results-Driven Accountability (RDA) model. This change is based on data showing
that the educational outcomes of America’s children and youth with disabilities had not improved
as expected, despite significant federal efforts to close achievement gaps. The accountability
system that existed prior to this shift placed substantial emphasis on procedural compliance, but it
often did not consider how that compliance affected the learning outcomes of students.45
The Education Department’s Office of Special Education Programs’ (OSEP) vision for
RDA involved having all accountability components supporting states aligned with improving
results for students with disabilities. This approach is consistent with IDEA, which requires that
the primary focus of the federal program be on improving educational results and functional
outcomes for students with disabilities, along with meeting IDEA requirements. RDA fulfills these
requirements by focusing on both outcomes for students with disabilities and on compliance with
the law.46 As part of its monitoring process, OSEP requires each state to develop a state systemic
improvement plan (SSIP) to improve student outcomes in priority areas of identified need. New
Mexico’s SSIP is being implemented as part of its program of New Mexico Real Results (NMRR),
which focuses on reading growth rates of students with disabilities particularly in school-wide
Title I programs.
This section of the report looks at results for students with disabilities and how APS is
supporting the teaching and learning of students with IEPs, including young children ages three to
five years. Subsections include data on achievement and influences on achievement (educational
settings, suspension, and absenteeism). In addition, subsections focus on instruction for students
in general education classes and in more segregated settings.
Education of Young Children Ages Three to Five Years

This subsection addresses educational settings and feedback from focus group participants
on the education of young children with disabilities.
Achievement of Young Children with Disabilities
One indicator on the State Performance Plan (SPP) involves the achievement of young
children with disabilities. The indicator has three components: appropriate behavior, acquisition
and use of knowledge and skills, and positive social/emotional skills. For each component,
calculations are made of the percentage of children in two areas:
• Substantially Increased Skills. Children who entered an early-childhood program below
developmental expectation for their age but who have substantially increased developmentally
by age six when they exit a program (substantially increased skills), and
• Functioning Within Age Expectations. Children functioning within expectations by age six
or who attained those expectations by the time they exited the program.
45
April 5, 2012, RDA Summary, U.S. Department of Education at www2.ed.gov/about/offices/list/osers/osep/rda-
summary.doc.
46
Ibid.

The state’s latest profile for APS (2016-17) shows that for the ‘substantially increased
skills’ category, outcomes ranged from 68.8 percent to 79.0 percent, and percentage points ranged
from 6.0 points above to 5.2 below state targets. (See Exhibit 3a.) In the ‘functioning within age
expectation’ category, outcome rates were somewhat lower (53.5 to 65.1 percent), and percentage
points ranged from 14.4 above to 0.5 below targets. (See Exhibit 3b.) For both sets of data, the
lowest areas of performance were in the acquisition and use of knowledge and skills.
Substantially Increased Skills
Among district children who entered early childhood programs below developmental
expectations for their age but who increased developmentally by age six when they exited the
program, Exhibit 3a compares the rates of APS students who met standards and the extent to which
the rates met state targets.
A. Positive Social/Emotional Skills. 77.1 percent met standards, which exceeded the state target
by 3.1 percentage points.
B. Acquisition/Use of Knowledge/Skills. 68.8 percent met standards, which fell below the state’s
target by 5.2 percentage points.
C. Appropriate Behavior to Meet Needs. 79.0 percent met standards, which exceeded the state’s
Exhibit 3a. Outcomes for District/State Targets (Substantially Increased Skills)
80%
78%
76%
74%
72%
70%
68%
66%
64%
62%
Positive Social/Emotional Acquisition/Use of
Appropriate Behavior
Skills Knowledge/Skills
District 77.1% 68.8% 79.0%
State Target 74.0% 74.0% 73.0%
Functioning Within Age Expectations

Among children functioning at age-level skill expectations by six years of age or who had
met those expectations by the time they exited the program, Exhibit 3b compares the APS rates of
students who met standards and the extent to which the rates met state targets.
• Positive Social/Emotional Skills. 60.4 percent met standards, which exceeded the state target
by 14.4 percentage points.
• Acquisition/Use of Knowledge/Skills. 53.5 percent met standards, which fell slightly below
the state target by 0.5 percentage points.
• Appropriate Behavior to Meet Needs. 65.1 percent met standards, which exceeded the state

Exhibit 3b. Outcomes for District/State Targets (Functioning Within Age Expectations)
70%
60%
50%
40%
30%
20%
10%
0%
Acquisition/Use of
Positive Social/Emotional Skills Appropriate Behavior
Knowledge/Skills
District 60.4% 53.5% 65.1%
State Target 46.0% 54.0% 64.0%
Educational Settings of Young Children Three to Five Years of Age

Studies have shown that when children with disabilities are included in regular classroom
settings, they demonstrate higher levels of social play, are more likely to initiate activities, and
show substantial gains in key skills—cognitive skills, motor skills, and self-help skills.
Participating in activities with typically developing peers allows children with disabilities to learn
through modeling, and this learning helps them prepare for the real world. Researchers have found
that typically developing children in inclusive classrooms are also better able to accept differences,
are more likely to see their classmates achieving despite their disabilities, and they are more aware
of the needs of others.47
The importance of inclusive settings is underscored by a federal requirement that state
performance-plan indicators include the extent to which young children (three to five years of age)
receive most of their services in regular early childhood programs or in separate settings.
Educational Setting Rates
Data in exhibit 3c show APS, state, and national percentages of three to five-year old
children with disabilities who were educated in various educational settings.48 These categories
are established by criteria set by the U.S. Department of Education for state performance plans in
this area.
• Majority of Time in Early Childhood. Overall, 8.3 percent of all APS children with IEPs were
educated most of the school day in a regular early childhood class. This figure is much lower
than state and national rates (41.6 percent and 45.2 percent, respectively). For 2017-18, New
Mexico’s target for this setting was 60 percent.
• Separate Class or School. Some 41 percent of all APS children were educated most of the day
in separate classes/schools apart from their typical peers. This figure was 2.8 percentage points
lower than the state’s rate, but 15.8 points higher than the nation’s 25.2 percentage. New
Mexico’s target for this educational setting for 2017-18 was 25 percent.
47
Ronnie W. Jeter, The Benefits of Inclusion in Early Childhood Programs at
http://www.turben.com/article/83/274/The-Benefits-of-Inclusion-in-Early-Childhood-Programs
48
APS data is from the 2017-18 school year, and state and national data are from the 2015-16 school year.

Exhibit 3c. Percentage of Young Children with IEPs (Ages 3 to 5) by Educational Setting
70%
60%
50%
40%
30%
20%
10%
0%
APS State State 2017-18 Target Nation
Gen Ed Majority of Time 8.3% 41.6% 60.0% 45.2%
Separate Sp. Ed. Class 41.0% 43.8% 25.0% 25.2%
Instruction at the Preschool Level

APS supports preschool instruction for children enrolled in Head Start or through Title I
programs that in New Mexico are limited to four-year-old children. With these limited
opportunities for inclusion, a small percentage of children with disabilities beginning at age three
are educated alongside their typical peers.
Currently, some seven preschool classrooms are located as hubs in elementary schools.
Reportedly, too often the classrooms are in portable units that make it more difficult to provide
opportunities for interaction with typical peers. APS made a strong effort this school year to
increase the number of students with IEPs in Title I pre-K classes. However, classes in one section
of the city were limited. Also, this year, APS was enabling typical peers to enroll in “peer model”
classes at no cost, but transportation was not provided for them.
New Mexico’s new governor made preschool access one of her priorities and is proposing
to fund its expansion over five years. This initiative would help increase opportunities for APS’s
children with disabilities to be educated in general education classes.
Academic Achievement for School-Aged Students

Beginning in 2015, the U.S. Department of Education included in its results driven
accountability measures an achievement matrix based on the following indicators for students with
disabilities:
• Fourth/eighth graders scoring at or above basic levels of proficiency in reading and math on
the National Assessment of Educational Progress (NAEP);
• Fourth/eighth graders participating in regular statewide assessments in reading and math;
• Fourth/eighth graders included in NAEP testing in reading and math;
• Students exiting school by graduating with a regular high school diploma; and

• Students exiting school by dropping out.49

This subsection presents APS achievement data on NAEP, as well as performance data for
district students with disabilities on statewide assessments. Data regarding graduation and dropout
rates are described further under the topic of postsecondary transitions for students with
disabilities.
NAEP Achievement Rates for Students with IEPs
NAEP is an assessment administered to a sample of students in each of the 50 states in
order to determine how much U.S. students know about various subjects. State-level results
determine where each state stands on the Nation’s Report Card, and they are used by education
groups to rank states’ public education systems on a national level.
In partnership with the National Assessment Governing Board and the Council of the Great
City Schools, the Trial Urban District Assessment (TUDA) was created in 2002 to support
improvements in student achievement in the nation’s largest urban school districts. In 2017, 27
urban school districts voluntarily participated in TUDA and can track achievement by subgroup
on a single comparable assessment.
Fortunately, APS participates in TUDA, so district achievement on NAEP can be compared
with state and national averages among students with disabilities and with other major city school
districts.50
Exhibits 3d through 3g show the percentage of students with disabilities in 2017 scoring
proficient/above in reading and math for TUDA’s large cities and the nation, and percentage point
differences between 2011 and 2017.51 High achieving districts are noted for reference.
Reading: Grade 4
In 2017, fourth grade reading results for students with disabilities showed that some 9
percent scored at or above proficient in all TUDA districts, an increase of 1 percentage point from
2011. Nationally, the 12 percent of students with disabilities scoring at this level also increased by
1 percentage point between 2011 and 2017. (See Appendix 3d.)
In APS, 4 percent of students with disabilities scored proficient/above, a decrease of 3
percentage points between 2011 and 2017. In 2017, TUDA proficient/above averages ranged from
18 percent to 1 percent. Of the large cities, the highest averages were posted by Miami-Dade
County (18 percent), Hillsborough County (15 percent), and Austin (14 percent). Miami-Dade
County’s and D.C.’s averages increased the most (10 points and 9 points, respectively).
49
For a full explanation of ED’s methodology, see “How the Department Made Determinations under Section
616(d) of the Individuals with Disabilities Education Act in 2015: Part B”
http://www2.ed.gov/fund/data/report/idea/partbspap/2015/2015-part-b-how-determinations-made.pdf
50
The Nation's Report Card, retrieved from http://www.nationsreportcard.gov/.
51
The exhibits do not include large cities that did not have scores published in both 2017 and 2011. TUDA scores
include students who are Section 504 qualified. TUDA 2017 results for reading were retrieved from
https://www.nationsreportcard.gov/reading_2017/files/2017_Results_Appendix_Reading_TUDA.pdf and math from
https://www.nationsreportcard.gov/reading_2017/files/2017_Results_Appendix_Math_TUDA.pdf.

Exhibit 3d. Reading Grade 4

20 15
10
15
5
10
0
5 -5
0 -10
U.S. Cit Alb Atl Aus Bos Cha Chi Cle Dal DC Fre Hil Hou Jef LA Mia Mil NYC Phi San
2017 12 9 4 11 14 7 8 4 1 5 11 6 15 7 12 4 18 4 8 2 10
Change: 2011 1 1 -3 3 -3 0 -2 -4 0 4 9 5 -5 2 1 1 10 2 1 0 5
Reading: Grade 8
Eighth grade reading results among students with disabilities showed that some 7 percent
scored at or above proficient in all TUDA districts, an increase of 2 percentage points between
2011 and 2017. Nationally, 9 percent of students with disabilities scored at this level, an increase
of 2 percentage points between 2011 and 2017. (See Appendix 3e.)
In APS, 4 percent of students with disabilities scored proficient/above in both 2017 and
2011. In 2017, TUDA proficient/above averages ranged from 14 percent to 1 percent. Of the large
cities, the highest averages were posted by Austin (14 percent), Hillsborough County, and Miami-
Dade County (each at 12 percent). Increases of more than 5 percentage points were earned by
Austin (8 points), D.C. (7 points), and New York City (6 points).
Exhibit 3e. Reading Grade 8
16 10
14 8
12 6
10 4
8 2
6 0
4 -2
2 -4
0 -6
U.S. Cit Alb Atl Aus Bos Cha Chi Cle DC Hil Hou Jef LA Mia Mil NYC Phi San
2017 9 7 4 8 14 8 7 3 1 9 12 7 7 4 12 2 9 2 7
Change: 2011 2 2 0 5 8 3 2 -4 0 7 -1 5 2 3 5 1 6 0 3
Math: Grade 4
Fourth grade math results for students with disabilities showed that some 10 percent scored
proficient/above in all TUDA districts, a decrease of 2 percentage points between 2011 and 2017.
Nationally, 16 percent of students with disabilities scored at this level, a decrease of 1 percentage
point between 2011 and 2017. (See Appendix 3f.)
In APS, 5 percent of students with disabilities scored proficient/above in 2017, a decrease
of 8 percentage points between 2011 and 2017. In 2017, TUDA proficient/above averages ranged
from 27 percent to 1 percent. Of the large cities, the highest averages were posted by Austin (22
percent) and Miami-Dade County (20 percent). Increases of more than 5 points were earned by
Miami-Dade County (9 points), Jefferson County (7 points), and Hillsborough County (6 points).

Exhibit 3f. Math Grade 4

30 10
8
25 6
20 4
2
15 0
-2
10 -4
5 -6
-8
0 -10
U.S. Cit Alb Atl Aus Bal Bos Cha Chi Cle Dal DC Fre Hil Hou Jef LA Mia Mil NYC Phi San
2017 16 10 5 11 22 1 9 15 7 3 9 10 3 27 9 16 9 20 4 6 3 12
Change: 2011 -1 -2 -8 2 1 -6 1 -6 -4 1 0 4 -1 6 -5 7 4 9 -1 -5 0 0
Math: Grade 8
Eighth grade math results for students with disabilities showed that some 6 percent scored
proficient/above in all TUDA districts, the same percentage as in 2011. Nationally, 8 percent of
students with disabilities scored at this level, a decrease of 1 percentage point between 2011 and
2017. (See Appendix 3g.)
In APS, 2 percent of students with disabilities scored proficient/above in 2017, a decrease

of 2 percentage point between 2011 and 2017. In 2017, TUDA proficient/above averages ranged
from 17 percent to 1 percent. Of the large cities, the highest averages were posted by Austin (17
percent), and Boston (11 percent). Increases of more than 5 percentage points were earned by
Austin (10 points), and Dallas and San Diego (both with 6 points).
Exhibit 3g. Math Grade 8
18 12
16 10
14 8
12 6
10 4
2
8 0
6 -2
4 -4
2 -6
0 -8
U.S. Cit Alb Atl Aus Bos Cha Chi Cle Dal DC Hil Hou LA Mia Mil NYC Phi San
2017 8 6 2 5 17 11 8 6 1 7 3 6 2 8 6 1 7 2 9
Change: 2011 -1 0 -2 1 10 4 -2 -1 0 6 1 -6 -4 2 0 0 2 1 6
Statewide Assessment Outcomes for Students with Disabilities

Since 2014-15, APS students have also been participating in the Partnership for
Assessment of Readiness for College and Careers (PARCC) assessments. English language arts
(ELA) and math proficient/above rates for APS students with disabilities in 2017-18 exceeded
state rates. Also, APS rates increased by about 1.1 percentage points between 2014-15 and 2017-
18, while state averages decreased. The small percentages of APS students with disabilities scoring
proficient/above (smaller than 5 percent) suggest a substantial need for improvement at both
district and state levels.

English Language Arts

Data in Exhibit 3h for 2017-18 show that APS students with disabilities earned higher ELA
proficient/above rates than state students (4.8 percent and 3.2 percent, respectively). APS’s 2017-
18 rate increased by 1.1 percentage points from its 2014-15’s rate of 3.7 percent. During the same
period, the state’s rate fell to 3.2 percent, a drop of 2.9 percentage points from 6.1 percent.
Exhibit 3h. ELA: Proficient/Above Percentages for APS Students with IEPs
8%
6%
4%
2%
0%
2014-15 2015-16 2016-17 2017-18
APS 3.7% 4.0% 4.0% 4.8%
NM 6.1% 3.3% 2.9% 3.2%
Math Assessments
In 2017-18, APS also had math proficient/above rates that were higher than state rates (4.5
percent and 2.5 percent, respectively). Exhibit 3i shows that APS’s 2017-18 rate increased by 1.1
percentage points from its 2014-15’s rate of 3.4 percent to 4.5 percent in 2017-18. During the same
period, the state’s rate fell to 2.5 percent, dropping by 0.9 percentage points from 3.4 percent.
Exhibit 3i. Math: Proficient/Above Percentages for APS Students with IEPs
5%
4%
3%
2%
1%
0%
2014-15 2015-16 2016-17 2017-18
APS 3.4% 4.0% 3.6% 4.5%
NM 3.4% 2.9% 2.3% 2.5%
Educational Settings for Students with Disabilities

Research has consistently shown a positive relationship between inclusive instruction and
better outcomes for students with disabilities, including higher academic performance, higher
likelihood of employment, higher participation rates in postsecondary education, and greater
integration into the community. The 10-year National Longitudinal Transition Study-2 (NLTS 2)
described the characteristics, experiences, and outcomes of a nationally representative sample of
more than 11,000 youth ages 13 through 16 who were receiving special education services in grade
seven or above when the study began in 2001. The study found that, while more time spent in
general education classrooms was associated with lower grades for students with disabilities
compared to their non-disabled peers, students who spent more time in general settings were closer
to grade level on standardized math and language tests than were students with disabilities who

spent more time in separate settings.52 Research also showed that including students with a range
of disabilities in general education classes did not affect the achievement of their non-disabled
peers.53
Similar results were found in a comprehensive study of school districts in Massachusetts.

There, students with disabilities who were in full-inclusion settings (80 percent or more of the
school day in general education classrooms) appeared to outperform similar students who were
not included to the same extent in general education classrooms with their non-disabled peers. On
average, these students earned higher scores on the statewide assessment (MCAS), graduated high
school at higher rates, and were more likely to remain in their local school districts longer than
students who were educated in substantially separate placements 40 percent or less of the day in a
general education classroom. These findings were consistent across elementary, middle, and high
school years, as well as across subject areas. 54
The SPP tracks students educated in one of three educational settings and sets targets for
each: (1) in general education 80 percent or more of the day, (2) in general education less than 40
percent of the day, i.e., in separate classes, and (3) separate schools. States are expected to collect
data on a fourth educational setting (in general education between 79 percent and 40 percent of the
time), but the SPP indicator does not monitor this setting.
Comparison of Rates for District, State, and Nation
Data in exhibit 3j show the rate of APS students with IEPs in the four educational settings
established by the U.S. Department of Education and collected by PED. Data include participation
rates in the three settings reported on the SPP with accompanying targets. Although the district
provided the Council team educational setting data that indicated no students attended separate
schools, APS has two separate “centers” attended only by students with disabilities. The team used
data provided for these centers/schools to establish a special school rate for the separate school
category.
• In General Education At least 80 Percent of the Time. The district’s 28 percent rate for
students in this setting is much lower than the state rate (50 percent), state target (60 percent),
and the national rate (63 percent).
• In General Education Between 40 and 79 percent of the Time. The district’s 40 percent rate
is more than twice as high as the nation’s 18 percent rate. There is no state target or data posted
for this environment.
• In General Education Less than 40 Percent of the Time. Generally considered to be a self-
contained special education class setting, the district’s 31 percent rate is much higher than the
52 Review of Special Education in the Houston Independent School District, Thomas Hehir & Associates Boston,
Massachusetts, page 25, retrieved at
http://www.houstonisd.org/cms/lib2/TX01001591/Centricity/Domain/7946/HISD__Special_Education_Report_201
1_Final.pdf.
53 See A. Kalambouka, P. Farrell, A. Dyson, & I. Kaplan. (2007, December). The impact of placing pupils with
special educational needs in mainstream schools on the achievement of their peers. Educational Research, 49(4),
365–382.
54
Thomas Hehir & Associates (2014, August) Review of Special Education in the Commonwealth of
Massachusetts: A Synthesis Report, Boston, Massachusetts, retrieved at http://www.doe.mass.edu/sped/hehir/2014-
09synthesis.pdf

state rate (19 percent), state target (15 percent), and national rate (13 percent).
• Separate Schools. The district’s 0.26 percent rate for separate schools is smaller than the state
and national rates (0.91 percent and 3 percent, respectively).
Exhibit 3j. Percentage of Students by Educational Setting
70%
60%
50%
40%
30%
20%
10%
0%
APS NM NM Target Nation
At Least 80% 28% 50% 60% 63%
40% - 79% 40% 18%
<40% 31% 19% 15% 13%
Separate Schools 0.26% 0.91% 0.90% 3%
Educational Setting Rates by Grade Level

Data in exhibit 3k show that a larger percentage of students were educated inclusively (in
general education at least 80 percent of the time) at the high school level compared to elementary
and middle school levels (32 percent, 28 percent, and 25 percent, respectively). A larger percentage
of students were educated in separate classes (in general education less than 40 percent of the time)
at the middle school level (36 percent) than at the elementary and high school levels (both at 28
percent). Special school rates were not included because of the small percentage of students in that
setting.
Exhibit 3k. Percentage of Students Educated in General Education by Amount of Time and Grade
50%
40%
30%
20%
10%
0%
80% or more 40% - 79% Less than 40%
Total 28% 40% 31%
Elementary 28% 44% 28%
Middle 25% 38% 36%
HS 32% 40% 28%
APS Educational Setting Rates by Disability Areas
Data in exhibit 3l show the percentages of district students with IEPs having one of six
major disabilities by time spent in general education settings.
• At Least 80 Percent in General Education. Students with a speech/language impairment had
the highest rate (60 percent) of schooling in general education classes at least 80 percent of the
time. Rates were lower for SLD and OHI (29 percent and 28 percent, respectively), and lower
still for ED (18 percent) and autism (16 percent). Rates were lowest for ID (2 percent).

• 79 Percent to 40 Percent in General Education. Students with SLD and OHI had the highest
rates of education in general education classes from 79 percent to 40 percent of the time (50
percent and 43 percent, respectively). Rates for students with S/L, ED, and autism ranged from
21 percent to 25 percent. Students with ID had the lowest rate for this setting (8 percent).
• Less Than 40 Percent. Of all students with ID, 90 percent were educated in general education
less than 40 percent of the time. The areas of ED and autism had the next highest rates (each
at 59 percent). Students with SLD and OHI had rates of 21 percent and 29 percent, respectively,
and students with S/L had the lowest rate of 15 percent.
Exhibit 3l. APS Educational Settings by Disability Area
100%
80%
60%
40%
20%
0%
S/L SLD OHI ED Autism ID
Less than 40% 15% 21% 29% 59% 59% 90%
79% to 40% 25% 50% 43% 23% 21% 8%
At Least 80% 60% 29% 28% 18% 16% 2%
District, State and National Educational Setting Rates

Exhibits 3m through 3o compare APS’s educational setting rates to state and national data
to provide a context for the district’s instruction of students with disabilities. These data show that
in each disability area APS educates students in far more restrictive settings compared to the state
and nation.
General Education At Least 80 Percent of the Time
In each disability area, a much smaller percentage of APS students spend time in general
education classes at least 80 percent of the day compared to students at state and national levels.
The largest differences were for OHI (59 percentage points) and SLD (42 percentage points)
• SLD. Twenty-nine percent of APS students with a specific learning disability were in this
setting compared to the state (49 percent) and nation (71 percent).
• S/L. Sixty percent of APS students with a speech/language impairment were in this setting
compared to the state (80 percent) and nation (87 percent).
• OHI. Twenty-eight percent of APS students with an other health impairment were in this
• Autism. Sixteen percent of APS students with autism were in this setting compared to the state
(31 percent) and nation (39 percent).
• ED. Eighteen percent of APS students with an emotional disturbance were in this setting
• ID. Two percent of APS students with an intellectual disability were in this setting compared
to the state (10 percent) and nation (17 percent).

Exhibit 3m. At Least 80% in General Education by Disability Area

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
SLD S/L OHI AU ED ID
APS 29% 60% 28% 16% 18% 2%
State 49% 80% 48% 31% 39% 10%
Nation 71% 87% 87% 39% 47% 17%
General Education 79 Percent to 40 Percent of the Time

Except in the area of intellectual disability, a larger percentage of APS students spend time
in general education classes from 79 percent to 40 percent of the day compared to students in the
state and nation.
• SLD. Fifty percent of APS students with a specific learning disability were in this setting
• S/L. Twenty-five percent of APS students with a speech/language impairment were in this
• OHI. Forty-three percent of APS students with an other health impairment were in this setting
• Autism. Twenty-one percent of APS students with autism were in this setting compared to the
state (20 percent) and nation (18 percent).
• ED. Twenty-three percent of APS students with an emotional disturbance were in this setting
• ID. Eight percent of APS students with an intellectual disability were in this setting compared
Exhibit 3n. 79% to 40% in General Education by Disability Area
60%
50%
40%
30%
20%
10%
0%
SLD S/L OHI Autism ED ID
APS 50% 25% 43% 21% 23% 8%
State 38% 14% 33% 20% 22% 19%
Nation 22% 5% 5% 18% 18% 26%

General Education Less than 40 of the Time

In all disability areas, a much larger percentage of APS students spend more time in
separate classes (i.e., general education classes less than 40 percent of the day) compared to
students in the state and nation. The areas of ED and ID had the largest gaps, with each area
exceeding national rates by 41percentage points.
• SLD. Twenty-one percent of APS students with a specific learning disability were in this
• S/L. Fifteen percent of APS students with a speech/language impairment were in this setting
compared to the state and nation (each 4 percent).
• OHI. Twenty-nine percent of APS students with an other health impairment were in this setting
• Autism. Fifty-nine percent of APS students with autism were in this setting compared to the
state (48 percent) and nation (33 percent).
• ED. Fifty-nine percent of APS students with an emotional disturbance were in this setting
• ID. Ninety percent of APS students with an intellectual disability were in this setting compared
Exhibit 3o. Less Than 40% in General Education by Disability Area
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
SLD S/L OHI Autism ED ID
APS 21% 15% 29% 59% 59% 90%
State 12% 4% 17% 48% 35% 70%
Nation 5% 4% 4% 33% 18% 49%
Educational Setting Risk Ratios by Race/Ethnicity and English Learner Status

Exhibit 3p shows data on the four educational settings using a risk ratio methodology for
race/ethnicity and English learner status.55 In all settings except for separate schools, it is not more
likely that any racial/ethnic or English learner group is over or under represented compared to
other racial/ethnic groups. White students, however, are three times more likely than students in
other racial/ethnic groups to be educated in a separate school. APS did not provide data by
race/ethnicity or English learner status by disability and educational setting.
55
Data is not provided for areas with cells having numbers too small for accurate measurement.

Exhibit 3p. Educational Setting Risk Ratios by Race/Ethnicity and English Learner Status
3.5
3
2.5
2
1.5
1
0.5
0
American
Hispanic White Black English Learner
Indian
At Least 80% 0.92 0.30 0.75 0.91 0.65
40% to 79% 1.09 0.87 1.10 0.97 1.11
<40% 0.97 0.99 1.06 1.11 1.18
Separate School 0.23 3.00
Suspension and Expulsion Rates

Another critical area that affects the achievement of students with disabilities is time out
of school due to suspensions. Indicator 4 of the state performance plan measures out-of-school
suspensions for more than 10 days, as well as suspensions of students with disabilities by
race/ethnicity. The information below summarizes data for students with IEPs having at least one
suspension. APS did not provide data showing suspensions over 10 days or ranges by number of
days of suspension.
Out-of-School Suspensions
While students with IEPs comprised some 19 percent of all APS students, they accounted
for 34 percent of all students suspended during the 2017-18 school year. Students with IEPs were
2.14 times more likely than students without IEPs to be suspended. By grade level, the IEP
suspension rate was highest in middle schools (36 percent), slightly lower in high schools (34
percent), and lowest in elementary schools (27 percent). (See Exhibit 3q.)
Exhibit 3q. APS Students with IEPs Suspended: Percentages and Risk Ratio
40% 2.5
35%
2
30%
25% 1.5
20%
15% 1
10%
0.5
5%
0% 0
All Students
All Students
w/IEPs Elementary Middle High IEP Risk Ratio
w/IEPs
Suspended
Percentage 34% 27% 36% 34% 18%
Risk Ratio 2.14

Suspensions by Race/Ethnicity
Data in exhibit 3r for 2017-18 show the percentages of students with/without IEPs with
suspensions and suspension risk ratios for students with IEPs. Of all racial/ethnic groups with IEPs,
black students with IEPs had the highest rate of suspensions (3.54 percent). Students with IEPs
were more than twice as likely as those without IEPs to be suspended from the following
racial/ethnic groups: black (2.90 risk ratio); white (2.83 risk ratio); and Hispanic (2.19 risk ratio).
Exhibit 3r. Race/Ethnic Suspension Risk Ratios for Students with IEPs
4.0% 3.0
2.5
3.0%
2.0
2.0% 1.5
1.0
1.0%
0.5
0.0% 0.0
Hispanic American Indian Black White
IEP 2.27% 1.53% 3.54% 1.60%
No IEP 1.03% 0.84% 1.22% 0.56%
Risk Ratio 2.19 1.83 2.90 2.83
Absenteeism
Although absenteeism is not a component of the state performance plan, excessive school
absences negatively impact student achievement, and it is important to monitor. Exhibit 3s shows
the percentage of all APS absences by number of days for students with disabilities. Exhibit 3t
shows the likelihood that students with disabilities are absent compared to students without
disabilities.
Disability Rate
Of all absent students (by range of days and by grade levels), middle school students with
IEPs had the highest proportion of absences, ranging from 22 percent (1 to 10 days) to 46 percent
(21 to 30 days). (See Exhibit 3s.)
Exhibit 3s. Percentages of Students with IEPs Absent by Days and Grade Level
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
1 to 10 11 to 20 21 to 30 Over 30
Total 17% 25% 30% 24%
Elementary 15% 20% 24% 26%
Middle School 22% 34% 46% 24%
High School 18% 26% 28% 24%
Risk Ratio
Using a risk ratio methodology, students with disabilities were 1.78 times more likely than
those without IEPs to be absent for 21 to 30 days. Disability risk ratios for the other absenteeism

ranges were smaller: 1 to 10 days (0.86 risk ratio); 11 to 20 days (1.38 risk ratio); and over 30 days
(1.32 risk ratio). (See Exhibit 3t.)
Exhibit 3t. Absenteeism Risk Ratios: Students with IEPs Compared to Those Without IEPs
2.0
1.5
1.0
0.5
0.0
1 to 10 11 to 20 21 to 30 Ovver 30
Risk Ratio 0.86 1.38 1.78 1.32
Academic Instruction, Intervention, and Supports

A fundamental goal of the common core state standards (CCSS) was to create a culture of
high expectations for all students. In a statement on the application of the common core to students
with disabilities, the CCSS website includes a visionary statement that reinforces this intent:
Students with disabilities … must be challenged to excel within the general
curriculum and be prepared for success in their post-school lives, including
college and/or careers.” These common standards provide historic opportunity to
improve access to rigorous academic content standards for students with
disabilities.56
The statement underscores the supports and accommodations that students with disabilities
need to meet high academic standards and fully demonstrate their conceptual and procedural
knowledge and skills in ELA (reading, writing, speaking, and listening) and mathematics. These
expectations for students with disabilities include the following elements:
• Instruction and related services designed to meet the unique needs of students with disabilities
and enable them to access the general education curriculum.
• Teachers and specialized instructional support personnel who are prepared and qualified to
deliver high-quality, evidence-based, and individualized instruction and support.
• Instructional supports for learning that are based on the principles of universal design for
learning (UDL), which foster student engagement by presenting information in multiple ways
and allowing diverse avenues of action and expression. 57
• Instructional accommodations that reflect changes in materials (e.g., assistive technology) or
56
Retrieved at http://www.corestandards.org/assets/application-to-students-with-disabilities.pdf.
57
UDL is defined as “a scientifically valid framework for guiding educational practice that (a) provides flexibility in
the ways information is presented, in the ways students respond or demonstrate knowledge and skills, and in the
ways students are engaged; and (b) reduces barriers in instruction, provides appropriate accommodations, supports,
and challenges, and maintains high achievement expectations for all students, including students with disabilities
and students who are limited English proficient.” by Higher Education Opportunity Act (PL 110-135). See the
National Center on Universal Design for Learning at http://www.udlcenter.org/.

procedures that do not change or dilute the standards but allow students to learn within the
CCSS framework.
The general education curriculum refers to the full range of courses, activities, lessons, and
materials routinely used by the general population of a school. Students with disabilities have
access to this curriculum when they are actively engaged in learning the content and skills that are
being taught to all students.
To participate with success in the general curriculum, a student with a disability may need
additional services, such as instructional supports, accommodations, scaffolding, assistive
technology, and other services. With a universal design for learning (UDL) approach, information
is presented in varied ways, allowing multiple avenues of learning and expression.
When special educators teach students from multiple grades in a single self-contained class,
it is difficult for them to focus on each grade’s content standards with any depth or effectiveness.
When schools are organized in an inclusive manner, on the other hand, they are better able to
support students with various disabilities and enable them to attend the school they would
otherwise attend if not disabled.
This model enables more students with disabilities to attend schools in their community;
supports a more natural distribution of students with disabilities at each school; and reduces
transportation time and costs. Still, general education instruction must be meaningful for students
with disabilities, and their presence in the classroom, alone, is insufficient to make it so.
Instruction and Specialized Support for Students in General Education Classes
As indicated above, APS educates 28 percent of its students with disabilities in general
education classes at least 80 percent of the time, a rate that is far lower than state and national rates
(50 percent and 63 percent, respectively). Rates are similarly discrepant when looking at students
in general education between 40 and 79 percent of the time. Here, APS’s 40 percent rate is more
than twice as high as the nation’s 18 percent rate. (See Exhibits 3i.)
Data are even more troubling when disaggregated by disability area. (See Exhibits 3k-3n.)
For example, 9,063 students (or 57 percent of all APS students) are qualified for special education
in the area of a significant learning disability. Only 29 percent of these students are educated in
general education classes at least 80 percent of the time, a rate that is less than half of the national
rate. Conversely, 21 percent of students with SLD are educated in separate classes more than 60
percent of the day. This rate is three times higher than the national rate. (See Exhibit 3u.)
Exhibit 3u. Percentage of Students with SLD Educated in General Education Classrooms
80%
60%
40%
20%
0%
At Least 80% in General Education Less than 40% in General Education
APS 29% 21%
State 49% 12%
Nation 71% 5%

Many other urban districts have similar rates or have acted to change this configuration of
services with co-teaching strategies, professional development, internal monitoring and technical
assistance, and other supports. For example, our data show that Hillsborough County, Duval
County,58 and Austin school districts have students with IEPS included in general education at
least 80 percent of time, 73 percent, 82 percent, and 64.4 percent, respectively. Their separate class
rates (less than 40 percent in general education) are 11 percent, 12 percent, and 11.5 percent,
respectively. The evidence is compelling that students in other urban school systems can be
educated in more inclusive settings if the will exists.
Focus Group Participants

The Council team discussed this issue with focus group participants to understand the
district’s context for this pattern, and how students with disabilities were supported within general
education or in short periods for pull out instruction. The team was not surprised to hear from
interviewees that there had not been much, if any, systemwide support from general and special
education administrators, principals, and others to pursue more inclusive and effective instruction.
APS representatives reported that any discussion of the issue often occurs at the initiation of an
individual principal or individual school staff members, but there is little systemwide effort to
address the issue. There was a perception that some schools think they are models for inclusivity,
but that one will see little evidence of inclusiveness or differentiated instruction when one looks
at general education classes across the district. This situation will obviously influence IEP teams
when they are deciding the extent to which students could or should be educated in general
education classes and the pattern will reinforce current practices and services.
Focus group discussions focused on the following practices in APS.
• Support for Inclusion/Co-teaching. Although professional development sponsored by the
special education department has been provided in the past to support co-teaching by general
and special educators, systemwide training has not occurred recently. A few teachers told the
team that they co-taught their classes, which they claimed worked well, but others indicated
that larger special education caseloads made the method unworkable without additional
supports or smaller caseloads. There was a sense that “extra funding” was needed to support a
master schedule that would facilitate more inclusive instruction. Most teachers indicated that
they “pull out” students for instruction.
The Council team noted that having the special education department be the sole sponsor for
professional development designed to promote effective inclusive instruction makes it much
more likely to be viewed as a department initiative and not a district initiative. Inclusive
instruction is the domain of general education as much as it is the responsibility of special
education, bilingual education, and other departments. All components of the system need to
be involved to plan, implement, and institutionalize inclusive instruction.
• Scheduling. Typically, schools do not schedule students with disabilities first when planning
their schedules. Instead their schedules must fit into schools’ pre-existing schedule.
• Instruction. There was a perception that students who are pulled out of general education
classrooms for as much as three hours per day for reading and math were not receiving the
instruction they needed to accelerate or support their achievement. There were concerns that
58
Duval County has 2017 NAEP rates that are best or among the best of TUDA districts in the disability category.

pull-out instruction does not supplement core curriculum for students participating in regular
statewide assessments. Furthermore, students who were pulled out and were not in specialized
programs did not receive the same curricular materials as those in general education, e.g., i-
Ready/Ready Reading and Math are different programs than being provided in general
education. This circumstance makes it more difficult for students with disabilities to be
prepared effectively in general education setting when they are being taught with differing
instructional materials.
• General Educator Preparedness. Only a small proportion of general educators interviewed by
the team indicated that they were equipped to educate students with disabilities in their
classrooms. These educators valued their co-teaching experience and credited their special
education peers with support in this area. Others without this experience felt less prepared.
• Speech/Language Services. APS educates an unusually high percentage of students receiving
speech/language services outside of general education classrooms more than 20 percent of the
time. APS’s rate of 40 percent is 5 times higher than the nation’s 9 percent and more than twice
as high as the state’s 18 percent. Focus group participants explained that they rely on
speech/language pathologists to recommend service models for these students.
• General/Special Educator Collaboration. General educators indicated that they often did not
know what instruction their students with disabilities were receiving in pullout classes and that
they did not have any scheduled time to collaborate with special educators teaching these
classes.
• Charter Schools. Charter school focus group representatives described their schools as “fully
inclusive.” The Council team did not receive from APS demographic data on charter school
students, so we were unable to conduct any comparative analysis or to verify this claim.
• Grade Span. As is typical among students in other districts who are pulled out of general
education classes for instruction, special classes in APS typically have grade spans that range
from kindergarten through fifth grade, ninth through twelfth grade, etc. Large grade spans
make it very difficult to address the learning needs of students with different developmental
and learning needs.
• Caseloads. There were different perceptions about the extent to which students with disabilities
(other than those having a speech/language impairment only) who were educated in general
education classroom for at least 80 percent of the day were counted as part of the general
educator’s class size. If not counted, then there appears to be an incentive to educate students
outside of the classroom.
• Universal Design for Learning Tools. The UDL team, which is housed in special education,
supports schools by providing instructional tools, e.g., text-to-audio, co-writer, etc. If UDL is
viewed only as a “special education” practice, the design is not likely to be viewed as
“universal.”
• IEP Information and Test Scores. There is little uniform expectation about the provision of
IEP-related information to general educators. Consequently, practices differ from school to
school. Similarly, special education resource teachers do not consistently receive statewide and
other test scores on their students.

Instruction for Students in Specialized Programs

School districts that operate without an MTSS framework often organize special education
predicated on a theory of “specialization” that students with common characteristics can be
matched to a specific program. Such programs often include students with a large range of
achievement and behavior, as well as students with characteristics that fall between program types.
Such specialization can sometimes perpetuate the myth that student needs can be addressed fully
with correct program matches based upon a prescribed set of characteristics. If a student is failing,
then it is presumed to be because he or she is simply in the wrong program, so a new one is sought
to provide a better fit. In such circumstances, there is pressure to create more specialized,
categorical programs rather than creating a broad framework for general-education instruction and
behavioral supports based on student needs.
Last year, APS’s special education department reconfigured and rebranded their
specialized programs from a disability-centered categorical approach to a needs-based three-
category approach, with each category having two or three service levels. While these delineations
might be clear to special education administrators and well-intended, the names for each category
were not self-explanatory and are probably confusing to parents and school staff unfamiliar with
the service descriptions. Furthermore, there were eight different specialized programs. Students
educated in separate classrooms who were not in one of these three main programs were instructed
using a cross categorical service model. This model was not described in APS informational
material.
APS’s description of its three service models are described below. The description of the
levels is not immediately clear in how they differ.
Social and Communication Support (SCS)
This service model, which generally supports students with autism, has three levels.
• Level 1. Emphasis on fluency, maintenance and generalization of skills in social/pragmatic
communication; social/emotional skills; and standard academics.
• Level 2. Emphasis on fluency/maintenance of skills in social/pragmatic communication;
sensory awareness; social/emotional skills; and standard academics.
• Level 3. Emphasis on acquisition/fluency of skills in communication; sensory awareness;
social/emotional skills; and functional academics.
Intensive Global Support (IGS)
This model, which supports students with cognitive and physical disabilities, has two
levels, including a primary and regular level 1.
• (Primary) Level 1. Emphasis on fluency, maintenance and generalization of skills in basic
communication; self-help/self-determination; practical life skills; social/emotional skills;
citizenship skills; and functional and/or vocational academics
• Level 2. Emphasis on acquisition/fluency skills in acquiring basic communication; self-
help/self-care; social/emotional skills; therapeutic responses; and basic conceptual skills/
functional academics.

Social Emotional Support Services

This model, which supports students in need of significant behavioral interventions, has
two levels and a BASE level.
• Level 1. Emphasis on acquisition, fluency and maintenance of social skills, emotional
strategies, self-advocacy and standard academics.
• Level 2. Emphasis on acquisition of skills in social skills, emotional strategies, self-advocacy
and standard academics.
• BASE. Emphasis on acquisition, fluency and maintenance of skills in social/organization,
social/emotional skills; and standard academics (high school level).
Number of Students in Specialized Programs by Program Type and Level
Data in exhibit 3v show the number of students placed in each of APS’s specialized
classroom programs by type and level. Overall, 1,858 students are educated in one of these settings.
These data do not include 2,813 other students who are educated 60 percent or more of their day
outside of general education through a cross-categorical or other service model. Together, these
4,671 students comprise 33 percent of all students with disabilities. In addition, a portion of the
4,671 students who are educated less than 60 percent of the day in separate classrooms are removed
from general education as much as 50 percent of the school day.
Exhibit 3v. Number of Students in Each of the Three Comprehensive Support Service Models
500
400
300
200
100
0
SCS1 PSCS2 SCS2 SCS3 IGS1 PIGS2 IGS2 SES1 SES2 BASE
All. Students 130 41 282 197 475 11 294 314 104 10
Curricular Materials
The special education department provides separate reading and math instructional
materials for students educated outside of general education. Exhibit 3w lists these materials and
identifies the programs and levels for which each is used.59 Generally, students who participate in
regular statewide assessments are instructed using one or more of the following materials: I-
Ready/Ready, Specialized Program Individualizing Reading Excellence (SPIRE), and Wilson
Reading Systems; and students participating in an alternate assessment are instructed using PCI
Reading and/or Unique Learning.
APS’s description of SPIRE and Wilson indicate that these programs are for students with
specific learning disabilities displaying characteristics of dyslexia. These students have significant
decoding and encoding deficits, lack fluency, and have poor vocabulary development resulting in
problems with comprehension. (Note: New York City since the early 2000s has used the Wilson
59
APS document entitled, “District Sponsored Reading and Math Interventions.”

program for students with and without disabilities.) Students with an IEP reading goal may practice
on the i-Ready/Ready computer-based program along with explicit instruction on grade-level
reading. Students with dyslexia-like characteristics may receive both types of instruction.
Exhibit 3w. Reading & Math Curriculum by Program Type
Cross Categorical Social/Communication Intensive Global Social Emotional
Support (SCS) Support (IGS) Support (SES)
I-Ready/Ready
X 1&2 X
Reading & Math
SPIRE X 1&2 X
Wilson X 1&2 X
PCI Reading 3 X
Unique Learning 3 X
Focus Group Participant Feedback

Focus group participants highlighted the following issues.
• Specialized Program Protocols. Protocols are in place for special education resource teachers
housed in the District Comprehensive Support Services (DCSS) unit to provide special
education classroom teachers with support. Prior to last year, these resource teachers were
assigned to programs with students matching their areas of expertise, e.g., autism. Resource
teachers visited/supported others on a regular basis according to established
schedules. Teachers of students educated in a cross-categorical model could request support
from personnel having special expertise in specific disabilities. Currently, all support requires
a specific request but the individual assigned may not always have the expertise and experience
to meet the targeted area of need. Reportedly, several experienced resource teachers left the
department because it no longer believed in their effectiveness.
• Reading Specialists. A special education team of 6.5 full time reading specialists provide
training to special educators in the reading programs used in their specialized classes, e.g.
SPIRE, Wilson, etc.
• Reading Curricular Materials. Because of the need for instructional materials aligned with
Common Core State Standards, the special education department purchased I-Ready and I-
Station prior to the curriculum/instruction department’s vetting process that resulted in the
purchase of Benchmark Advance. Moreover, general education reading materials were not
consistently ordered for students in specialized classes so teachers must sometimes find their
own. As a result, students with disabilities may receive instruction using different materials
than their nondisabled peers. This circumstance can negatively impact their ability to function
well in general education classes.
• Placement. A dedicated group of special education department staff members support the
placement of students in the three intensive specialized programs. Prior to IEP meetings, a staff
member would observe the student, and review interventions provided, and data collected. This
one- to two-month process was viewed as “gatekeeping,” delaying the placement process. This
practice applied to initial placements as well as changes in placements within specialized
programs. Complicating this picture was the inexperience of some program teachers who were

new to teaching or were alternatively licensed. Reportedly, they were sometimes given a list
of interventions to use with a student for at least six weeks, without further support or
modeling. In some cases, students exhibited aggressive behavior while the teacher was
expected to keep data and enter it into the district’s data system without any formal training on
the system’s use.
These circumstances were grounded in the district’s desire to establish and monitor protocols
that would address the high proportion of students educated in specialized and separate
classrooms. It was also designed to provide more appropriate interventions and prevent
unnecessary and more restrictive placements. However, such protocols can be ineffective and
harmful when teachers do not receive the mentoring, coaching, and training they require to be
successful.
• Class Size and Age Spans. Common to other urban school districts reviewed by the Council
team, classes may sometimes house as many as 16 to 17 students, and students may represent
as many as five (elementary) or four grades (high school). However, it is extremely difficult to
engage in positive teaching/learning on grade level under these circumstances.
• Interaction with Nondisabled Students. Some teachers have been told that the funding system
for specialized programs does not allow students to attend general education classes.
• Training. There was a perception among some interviewees that fewer opportunities for
professional development was available for teachers who work with students in specialized
programs. Although courses were listed in the professional development catalogue, including
those for teachers in specialized programs, the opportunity was not always apparent to some
teachers.
• Principal Leadership. Principal oversight of specialized classrooms is not consistent across
the district. In some schools, principals routinely visit and observe instruction; in other schools,
principals are not involved. In the latter case, instructional supervision is delegated to assistant
principals. As a related matter, instructional rounds do not always include visits to specialized
classrooms. Rather, special education department personnel conduct visits to these classrooms.
This practice devalues the importance of instructional supports for students educated in
specialized programs, and it reduces opportunities to consider how students in these classes
might participate to a greater extent in general education classes.
• Custodial Support. Reportedly, fewer custodians than in the past are available to address the
needs of students with disabilities with behavior that significantly affects school cleanliness,
because special education funds no longer pay for these positions. Custodial allocations do not
take into consideration these exceptional needs.
• Special Schools. As mentioned earlier, APS data does not include the district’s two centers
that enroll only students with disabilities as being special schools, a separate federal and state
category in the collection of educational settings data. Regardless of whether APS considers
these settings to be schools or centers, they each operate as separate schools.
Instructional Support for English Learners with Disabilities
Although APS’s supports for English learners with disabilities has improved,
administrators interviewed by the Council team believe there was room for improvement. Special
education and English learner administrators were working together to address how language

acquisition should be reviewed during special education evaluations and eligibility determinations.
In addition, administrators have been working together this school year to develop support
structures for ELs with disabilities in order to address both special education and language-
acquisition needs. In the past, English language acquisition instruction was sometimes not included
for Els who were also qualified for special education.
District administrators now recognize the need for additional bilingual special education
and related services personnel. Principals have received some professional development on the
importance of dual services, i.e., special education and language acquisition instruction. There is
also a greater recognition of the need for models that will schedule and provide general, special,
and English language acquisition instruction.
Support for Student Behavior

As previously indicated, focus group discussions concerning APS’s administrative
guidance on the development of functional behavior assessments (FBAs) and behavior
intervention plans (BIPs) took up disproportionately large amounts of time compared to
discussions on other issues.
The district’s response to PED requirements on student behavior and supports, and the
process the district followed to address these issues provides an informative case study that is
relevant to other district efforts at systemic change.
Relevant IDEA, State Law, and Professional Literature
To provide a context for this discussion, the information below summarizes IDEA and New
Mexico code provisions, and professional literature relevant to FBAs and BIPs.
IDEA Provisions
The term ‘functional behavioral assessment’ appears in IDEA in two circumstances
involving students with disabilities who violate a student conduct code and who are recommended
for removal from his/her current educational placement to an alternative educational setting for
more than ten school days. 60
• Behavior IS Manifestation of Disability. When it is determined that a student’s conduct was
a manifestation of his/her disability, the district must conduct an FBA and implement a BIP. 61
• Behavior NOT Manifestation of Disability. When a student’s conduct is not a manifestation
of his/her disability, the student must receive, as appropriate, an FBA, behavioral intervention
services, and modifications, that are designed to address the behavior violation, so it does not
recur.62
Also, IDEA addresses students having behavior that impedes his/her learning or that of
others. In such circumstances, IEP teams must consider, if appropriate, strategies to address the
60
20 U.S.C. § 1415(k)(1)(D) and (E).
61
A new FBA is not required when a prior FBA was conducted for the same behavior that triggered the disciplinary
removal. If a prior BIP is in place, the district is required to review and modify the BIP as necessary to address the
behavior in question.
62
20 U.S.C. § 1415(k)(1)(D).

behavior, including development of behavioral goals and objectives and the use of positive
behavioral interventions, strategies, and supports in pursuit of those goals and objectives. 63
As discussed below, APS requires an FBA/BIP whenever a student’s behavior adversely
affects the learning of the student/others, even though there may be other appropriate strategies to
address this behavior. Also, when this circumstance exists, APS requires the FBA/BIP processes
to be in place to support any provision of related services to address the behavior. In this way,
APS’s standard exceeds IDEA and New Mexico code requirements.
New Mexico Code
New Mexico law expands upon IDEA to strongly encourage (but not require) public
agencies to conduct FBAs and integrate BIPs into IEPs for students who exhibit problem behaviors
well before the behaviors result in disciplinary actions for which FBAs and BIPs are required under
federal regulations.64 This option allows for other behavior-related strategies, besides an FBA/BIP,
to be used when they are considered to be beneficial.
Professional Literature
Various urban school districts and the professional literature have developed varying
guidance to create evidence-based best practices that incorporate FBAs and BIPs within a
framework of positive behavior interventions and supports (PBIS). Researchers suggest that an
FBA should be initiated whenever a problem behavior is difficult to understand or when a behavior
intervention plan is needed to increase student success.65 For students who engage in challenging
behavior, the combined FBA, BIP and/or PBIS processes are aimed at replacing targeted problem
behavior with acceptable behavior so the student can make social and academic progress.
According to the PBIS Technical Assistance Center, FBAs can be divided into three broad
categories: indirect measures (e.g., interviews and rating scales); direct observation; and functional
analysis (where an experienced behavior analyst systemically manipulates environmental events
while monitoring target behaviors.) To be technically adequate, an FBA must be able to: (1)
produce a summary statement that operationally defines the student’s problem behaviors; (2)
describe the antecedents/consequences that predict/maintain the problem behaviors; and (3) state
under what conditions the behavior is more or less likely to occur.
The University of Kansas’s Special Connections webpage stresses that FBAs should not
be completed in the same way every time for every student, and the complexity of information
needed is variable. 66 In other words, information collection should be based on each student's
targeted behavior, strengths, and needs. For many students, teachers may conduct a simple and
time efficient FBA to better understand minor disruptive behaviors that nevertheless adversely
affects the learning of the student and others. However, students who engage in serious aggression
or self-injury at home, in school, and in the community may need higher levels of support from
his/her teacher, parents, and other important people in the student’s life. In such cases, an FBA
tool that is used to collect information on medications, sleeping patterns, social/interactional skills,
63
20 U.S.C. § 1414(d)(3)(B)(i)
64
6.31.2.11 F. NMAC.
65
When to Use FBA? Best Practice vs. Legal Guidance, retrieved from https://www.pbis.org/evaluation/evaluation-
briefs/when-to-use-fba.
66
Retrieved from http://www.specialconnections.ku.edu/?q=behavior_plans/functional_behavior_assessment.

etc., will require more time and energy to complete. Even though FBA tools and level of intensity
vary, the general process is the same, and FBAs are complete when they have documented the
following—
• A clear and measurable definition of the problem behavior;
• Events that predict when problem behaviors will occur and will not occur;
• Consequences that maintain problem behaviors;
• One or more hypotheses about the function maintaining problem behavior; and
• Direct observations supporting the hypotheses.
The PBIS Technical Assistance Center has developed training that discriminates between
two types of FBAs, those that are ‘practical’ and those that are ‘comprehensive.’67
• Practical FBAs are for students with mild to moderate problem behaviors, i.e., behaviors that
are not dangerous or occurring in multiple settings. These FBAs are relatively simple and
provide an efficient process to guide behavior-support planning. Practical FBAs are used for
students with and without disabilities. They are conducted by school-based personnel, such as
teachers, counselors, administrators, etc. Because school-based personnel conducting these
assessments typically are not trained for this purpose, PBIS’s PowerPoint training document
describes the following training parameters for the development of practical FBAs.
- Elementary Teams (principals, counselors, school psychologists, special education
teachers). Three half-day sessions followed by two 1.5-hour sessions (one week apart)
- K-12 Educators (general education teachers, special education teachers, title reading
teachers, classified employees). Five sessions, two hours each (two weeks apart)
- Middle/High School Administrators and Counselors. Four sessions, each 1.5 hours (two
weeks apart)
• Comprehensive FBAs are for students with moderate to severe behavioral problems, such as
those who may be dangerous and/or exhibit poor behavior in multiple settings. These FBAs
are based on a time-intensive process that involves an archival records review, family-centered
planning, and collaboration with agencies outside of school. They are conducted by
professionals trained to conduct functional assessments with students who have severe problem
behaviors. These professionals often include school psychologists and behavior specialists.
Background Relating to APS’s FBA/BIP Process Concerns

According to APS staff and focus group participants, one of the district’s major challenges
concerns student behavior. This circumstance is exacerbated by the major shortages of APS special
educators. The district’s main strategy for addressing behavioral problems has been focused on the
use of FBAs and BIPs. However, the absence of a comprehensive systemwide framework for
67
Retrieved from
https://r.search.yahoo.com/_ylt=AwrCwOJHvhdcL2sADY4PxQt.;_ylu=X3oDMTByNXM5bzY5BGNvbG8DYmY
xBHBvcwMzBHZ0aWQDBHNlYwNzcg--
/RV=2/RE=1545088711/RO=10/RU=https%3a%2f%2fwww.pbis.org%2fcommon%2fcms%2ffiles%2fForum12%2
fA6_Loman_Strickland.pptx/RK=2/RS=8Jcu6iAwVG4QhGivzmxB8YmsbXc-

positive behavior supports (including restorative justice) likely increases the number of students
with problematic behavior.
Many APS staff believe that the state’s 2010 handbook for ‘Addressing Student Behavior’
is out-of-date and that the district’s FBA/BIP tools do not sufficiently define and follow-up on
targeted student behavior. During the fall of 2017, working with the University of New Mexico’s
Center for Development and Disability, the district developed new FBA/BIP tools to assist
teachers in gathering and analyzing student information. As the FBA/BIP tools were distributed,
however, teachers began contacting ATF with mounting concerns about the new
paperwork/documentation requirements. Union concerns led to additional administrative guidance
and a question/answer document, but confusion has continued. Unfortunately, stakeholders, such
as special educators, social workers, etc., did not appear to be involved in the development and
rollout of the FBA/BIP guidance. This proved to be a major oversight.
Chronology of FBA/BIP Key Events and Description of Various Documents
The following chronology shows key events related to APS’s new FBA/BIP forms.
• Fall 2017 Initiation of New Forms. APS’s special education department released new
FBA/BIP forms on its Intranet. They were communicated to head teachers who were to provide
training to school-based personnel.
• January 2018 School Social Work Newsletter. Provided information to social workers on
FBA/BIP requirements.
• February 2018 Clarification. APS met with social workers to clarify social work and
FBA/BIP provisions.
• March 16, 2018 Administrative Bulletin. The special education department released an
administrative bulletin to clarify the new forms and further explain various related procedures.
• April 26, 2018 Question/Answer Document. In this document, the department answered
questions presented by school-based personnel.
• New Mexico Public Education Department (PED) Complaint Findings. On June 28, 2018,
PED issued its findings on a complaint filed against the district on several issues, including
APS’s procedures for use of FBA/BIPs.
More detailed information about these documents is provided below.
January 2018 Social Worker Newsletter

A January 2018 social worker newsletter stated that an FBA/BIP must be implemented
with fidelity for six to eight weeks prior to a student’s consideration for a social emotional
assessment.
• Assessment Referrals Without FBA/BIP. When an assessment referral is initiated without an
FBA/BIP, the team must amend the IEP and give parents prior written notice to remove the
referral request. In other words, data collected through an FBA/BIP is necessary to support the
social work assessment.
• Current Social Work Services Without FBA/BIPs. For a student who is receiving social work
services without an FBA/BIP, the social worker must work with the sponsoring teacher to

arrange for an FBA/BIP to be completed. If a BIP is not needed to address a student’s behavior,
the social worker must consider exiting the student from services.68
February 2018 APS Clarification of FBA/BIP Process
According to APS, “[i]n February 2018 it was discovered that one of the Special Education
Leadership Team members had misinterpreted a piece of the process. In turn, [district] social
workers were told that an FBA/BIP must be in place for a student to receive social work services.
This is not the District’s position nor was it ever intended to be the message or best practice.”
During a meeting on February 22, 2018, APS met with and clarified the district’s position to social
workers.69 The PED findings did not include any additional information on APS’s statement that
a “piece of the process” was misinterpreted.
March 16, 2018 Administrative Bulletin
APA’s administrative bulletin describes the process for determining services for students
with behavior that impedes learning. In part, the document describes procedures required when
more restrictive services and/or placements are needed for a student because of his/her behavior.
The document stated that more restrictive services incorporate ‘related services,’ including social
work. According to this document, the consideration of a least restrictive environment (LRE)
incorporates related services, including social work. Notable forms and requirements included the
following –
• Classroom Organization & Management Inventory (COMI). Must be completed (although it
may or may not lead to an FBA/BIP) any time school personnel begin considering additional
supports for a student demonstrating problematic behavior in an educational environment. The
bulletin indicates that for many students this process will reveal to school personnel that Tiers
1 and 2 modifications will correct the behavior in question and there will be no need to conduct
an FBA or provide additional services.
• New 3-page FBA Form. Must be completed for all students receiving special education and
related services who need of an FBA.
• Related FBA Forms. At a minimum, staff are expected by outside counsel and the special
education department to complete the mandatory three-page portion of the FBA form and
numerous other optional pages. Language related to the additional forms refers to users’
professional judgment and IDEA’s requirement for a “thorough” analysis of the concerning
behavior. It also requires that IEP teams must be able to demonstrate they engaged in the FBA
process with fidelity. The instructions then state that the FBA tools or forms are meant to assist
people in conducting a “thorough” FBA. The Council team finds that this information is
confusing, and it can be read as meaning that a thorough analysis requires the use of related
FBA forms. Also, the team’s review of IDEA did not identify the administrative bulletin’s
“thorough” reference.
• Behavior-Related Placement Changes. An FBA (and BIP as warranted)70 must be completed
when the IEP team has changed or is changing a student’s placement because of behavioral
68
Source: June 28, 2018 PED complaint findings.
69
Source: PED findings in response to the complaint filed about the district’s FBA/BIP guidance.
70
Subsequent to an FBA, BIPs are developed/reviewed and implemented, as warranted. When only a FBA is
discussed in this report, the need for an BIP, as warranted, is assumed even if not stated.

concerns.
• New Related Services, Such as Social Work. The development of an FBA/BIP is best practice
before restricting a student's placement due to behavior, including the provision of related
services, such as social work. However, the document limits this by stating—
- Exceptional Circumstances. Only under exceptional circumstances may the IEP team
provide for such restrictions (i.e., related services) prior to the completion of the FBA/BIP.
- Social Work Assessment Request. If the IEP team requests a social work assessment or
other related services for behavior prior to conducting an FBA, it must be conducted as
soon as possible to determine if the student will be successful with less restrictive
interventions.
• Current Social Work Services. For a student receiving social work services but
demonstrating progress with their behavior, a BIP must be updated or an FBA must be
completed (if one does not exist) and a BIP be completed to determine if lesser restrictive
interventions will allow the student to be successful in her/his natural educational environment.
The Council team is unsure about how the FBA itself will measure this if behavior is improving
due to social work services.
• April 26, 2018 Question/Answer Document
In part, APS’s question and answer document reinforced several aspects of the FBA/BIP
administrative guidance.
• Social Work Services. APS repeated its administrative guidance stating that it was best practice
for a student to receive an FBA/BIP before restricting his/her placement because of behavior
adversely affecting the learning of the student or others. Restrictive placements include the
provision of related services, such as social work. Under exceptional circumstances, a social
work (or other related services) assessment/service may be added to a student’s IEP without
an FBA/BIP in place. In such cases, the FBA must be conducted as soon as possible to consider
less restrictive options.
• Social Work Assessment. A social work assessment is required prior to an IEP team
determining whether social work services are needed.
• BIP. If a student’s needs can be met through a BIP, social work services may not be necessary
for the student to receive an appropriate education.
June 28, 2018 PED Complaint Findings
Generally, the complaint filed with PED alleged various procedural violations, including
the provision of IEP-required social work services and the district’s FBA/BIP process. PED
reviewed various documents related to five students. Although the agency found that APS
committed several procedural violations and failed to implement social work services for several
students, it also found that none of the students failed to receive social work services relating to
any FBA/BIP practices. PED noted, however, that its sample was small and did not provide
conclusive evidence of noncompliance.
APS contends that it corrected the misunderstanding that an FBA/BIP was required for the
provision of social work services or a social work assessment referral. PED found that information

was disseminated that an FBA/BIP, if not required, was strongly encouraged. The agency further
wrote:
• Neither IDEA nor PDE has any regulation connecting the provision of any related service or
evaluation with an FBA/BIP. The implications of such a policy, practice, or even informal
position would be far reaching.
• At no point did APS clarify that the FBA/BIP is not required if social work was recommended
for concerns not directly tied to student behavior.
PED “very highly encouraged” APS to issue guidance clarifying that there was no nexus
between any specific related services and FBA/BIP. The agency encouraged the district to include
the following language in its guidance: “an FBA or BIP is not a requirement or best practice for
providing social services or a social-emotional evaluation.” There is not necessarily a connection
between behavioral assessment (and possible intervention) and any one related service. In an
August 13, 2018, APS’s special education associate superintendent and executive director of
compliance wrote to PED to “lodge a formal objection” on the portion of the state’s findings
regarding their encouragement to issue clarifying guidance. In part, APS reinforced its position
that FBAs and BIPs (as warranted) were for students with behavior impeding learning and
provided various literature citations supporting the use of FBAs/BIPs as best practice. The Council
team does not have any responses from PED to this objection by the district.

As mentioned above, focus group participants spent considerable time providing feedback
on the district’s 2017-18 rollout and explanation of the FBA/BIP process. Common themes are
listed below.
• Initiation of New Process. During the fall of 2017, new forms for FBAs/BIPs were released
on the district’s website without prior notice or explanation. The field responded with anger,
frustration, and a sense of lack of respect for the professionalism and workload of teachers.
Training took place during a one-day meeting with head teachers. Criticisms included the
following:
- PowerPoint Not Available. The PowerPoint was not available to head teachers, reportedly
because it had not yet been “legally” vetted.
- Form Focused. The training was limited to the completion of forms and was not designed
to further understanding of why the additional detail and time-consuming effort was
necessary.
- Support of Leadership. Reportedly, APS leadership, e.g., associate superintendent,
principals, etc., was not present at the training to provide guidance, context, support, or to
signify the training’s importance.
- FBA/BIP Cafes. Although additional training was provided through after-school FBA/BIP
“cafes,” the availability of the training did not appear to be widely known.
• Confusing and Contradictory Guidance. Information provided by APS to the field has been
viewed as confusing, conflicting, and contradictory to district expectations. Interviewees
indicated that different messages were given by special education administrators to different
groups: head teachers, social workers, etc.

• Resource Intensive Process. The new forms have been viewed as data heavy, excessively
detailed, and requiring an extensive amount of time to complete. According to some
interviewees, forms for a single student would require about 25 hours to complete; 18 hours to
complete a BIP; and the entire process for completing a classroom observation management
inventory (COMI), FBA, and BIP would take from 30 to 60 days. Although the FBA template
is three pages, supplemental forms added as many as 40 pages. The district later added a
streamlined template for general education teachers but not for special education teachers.
• Technology Issues. As late as May 2018, the FBA templates continued to work erratically.
Forms could not be consistently saved after completion without extensive computer tinkering.
Personnel not technologically savvy lost hours of work, resorted to taking pictures of
completed documents with a phone, or rewriting hours of work. Many teachers gave up on the
process, and fewer FBAs were completed.
• Personnel. APS has relatively few human resources to support student behavior and emotional
well-being.
- Psychologists. As discussed further below, APS employs a relatively small number of
psychologists compared to other major urban school districts and instead relies to a greater
extent on educational diagnosticians. Psychologists, however, are specifically trained to
conduct FBAs and support the development of BIPs, and they are used in this manner in
urban districts across the country. This is not true for APS whose psychologists
predominantly provide assessments rather than direct services to students.
- Board Certified Behavior Analysts (BCBAs). APS has three BCBAs who are also
specifically trained to complete FBAs and support BIP development. Their role is limited
to consultation, training, and – to a lesser extent – direct services.
- Special Educators. Because so few supplementary personnel in APS have the expertise to
complete the FBA/BIP process, this task falls primarily to special educators who have not
received the training they need for this purpose.
APS Survey of Special Education Teachers and Staff
APS and ATF leadership jointly commissioned an independent survey to measure
employee satisfaction among special education teachers and staff. The survey included questions
about satisfaction with work environments, employee morale, and communications. According to
the survey report, respondents indicated that communication about priorities/policies, changes
affecting teachers’ work, and administrative decisions had not been clearly conveyed. More
specifically the survey showed the following –
• Decisions made by special education administrators were clearly communicated (22 percent
agree and 51 percent disagree)
• New policies and procedures were clearly documented and easy to understand (20 percent
agree and 56 percent disagree)
Respondents provided the following statements that reinforced various focus group
participant themes.
• There were issues relating to various recently required changes in the process for handling
students receiving social work services.

• FBA/BIP changes were not clearly communicated. There was no consistent communication.
The administration and special education department were hearing but not listening to social
services.
• It would be most useful if all policies and procedures were explained before being put into
practice. An example would be the FBA/BIP process. Expectations kept changing during the
year.
• Provide teachers with FBA/BIP training. Give training on how to complete the paperwork - no
explanation was provided, and teachers were left not knowing how to complete the paperwork.
Council Team’s Feedback

Based on our review of documents and discussions with focus group participants, the
Council team agrees that information about the FBA/BIP process was written in an overly
legalistic and unclear manner, and APS did not provide a common understanding of reasonable
requirements.
• Legal Foundation for FBAs. The Council for the Great City Schools successfully lobbied
during the drafting of IDEA to provide for the consideration of (but not the requirement of) an
FBA when a student was engaged in behavior adversely affecting learning. With APS’s
requirement of a higher standard, the district is unnecessarily expanding the circumstances for
which this complex process must be completed.
• Association of LRE and Related Services. Guidance for related services such as social work
should not be predicated solely on an LRE analysis. LRE under the law is based on various
principles, including: (1) students with disabilities must not be removed from general education
classes unless the nature/severity of their disability is such that general education – even with
the use of supplementary aids/services – cannot be achieved satisfactorily; and (2) students
with disabilities are educated with their nondisabled peers to the maximum extent appropriate.
In the Council team’s experience, the provision of social work services does not necessarily
require the removal of a student from general education classes or require services that
excludes nondisabled students. The nature of social work services outside of these parameters
is not an LRE issue.
• Complexity of FBA and Related Forms. Although APS developed a simpler FBA form, this
version is restricted to general education students. However, students with IEPs have varying
degrees of behavioral issues. As discussed earlier, PBIS’s technical assistance center provides
training for FBAs that are ‘practical’ in nature for students with mild to moderate problem
behaviors, which are neither dangerous nor reoccurring in multiple settings. These FBAs are
relatively simple and provide an efficient process to guide behavioral support. They can be
conducted by such school-based personnel as teachers. ‘Comprehensive’ FBAs, on the other
hand, that are more time-intensive are reserved for students with dangerous behavior and
behavior that is apparent in multiple settings. These FBAs are typically conducted by
specifically trained personnel, such as school psychologists and behavior specialists.
• Flexibility of FBA Parameters. Various APS personnel agree that there should be different
degrees of FBAs based on a student’s targeted behavior, but APS has a one-size fits all FBA
based solely on a student’s disability status.
• Personnel Expertise. APS has relatively few supplementary personnel with the expertise

needed to complete comprehensive FBAs, and this task currently falls primarily to special
educators.
• APS’s Response to PED Complaint. APS’s written response to the complaint filed with PED
stated that the revised FBA/BIP process “requires a deeper analysis than most staff are used
to, it takes more time to conduct properly. A few but vocal staff have resisted this effort by
administration to provide this training and guidance. Complainant is one of these staff.”
District leadership needs to acknowledge and understand that its FBA/BIP process and rollout
were flawed and it needs correction. As of the Council’s onsite visit, there was continued
frustration and significant confusion about the parameters of APS’s FBA process.
• Documenting Support for Social Work Services. There may be legitimate concerns about
overreliance on social workers to address the behavioral and social/emotional needs of
students, and guidance is needed to help determine when they are educationally justified.
However, without a foundation of PBIS practices this reliance is not likely to decrease. There
are various ways to justify social work and other related services to address student behavior
needs without having to conduct a “thorough” FBA.
Secondary Transition Services and Support

In New Mexico, school districts are to begin transition-planning for students with IEPs
when each student is 16 years old. The planning process includes age-appropriate transition
assessments, transition services, courses of study that will reasonably enable students to meet
postsecondary goals, and annual IEP goals related to students’ transitional needs. Transition
services and supports prepare students for employment and independent living through
coordinated activities that promote movement from school to post-school activities, including
postsecondary education, vocational education, integrated employment (including supported
employment), continuing and adult education, adult services, independent living, and community
participation.
The SPP includes four postsecondary transition indicators for youth with IEPs:
Indicator 1. Percentage graduating from high school with a regular diploma
Indicator 2. Percentage of students with IEPs dropping out of high school
Indicator 13. Percentage of students with IEPs with all required transition components
Indicator 14. Percentage of youth with IEPs who were within one year of leaving high school:
• Enrolled in higher education;
• Same as above or competitively employed; and
• Same as above or in other postsecondary education or training program.
The sections below summarize APS’s progress on each of these indicators and the district’s
support for postsecondary transitional activities and services, including community-based work
experiences.

Graduation Rates
Data in exhibit 3x show four years’ worth of data (2013-14 to 2016-17) on the percentages
of students with IEPs who graduated from school after four years, and the percentage point gaps
with all other students. The data show that between 2013-14 and 2016-17 the graduation rate for
students with disabilities increased by 7.8 percentage points (from 54.8 percent to 62.6 percent).
Also, the graduation rate for students with disabilities grew closer to the rate for all students
(from a 7.9 to a 5.3 percentage point gap). No data were available for students with IEPs who
dropped out of school.
Exhibit 3x. Four Year Graduation Rates
70% 10
60%
8
50%
40% 6
30% 4
20%
2
10%
0% 0
2016-17 2015-16 2014-15 2013-14
Students with IEPs 62.6% 62.0% 59.6% 54.8%
Students Without/With IEP Gap 5.3 4.8 2.1 7.9
IEP Compliance and Post School Experience

Two additional indicators measure postsecondary transitions. The first concerns IEP
requirements, and the second measures postsecondary activities one year after high school.
IEP Compliance
PED data show that APS’s latest 2016-17 rate was 98 percent71 for SPP indicator 13, which
measures IEP compliance with legal requirements. The state compliance requirement on this
indicator is 100 percent. This indicator measures IEP compliance on the:
• Percent of youth aged 16 and above with IEPs having appropriate and measurable
postsecondary goals, which are annually updated and based on an age-appropriate transition
assessment.
• Transition services, including courses of study, that will reasonably enable the student to meet
their postsecondary goals.
• Annual IEP goals related to student transition service needs. There also must be documentation
that students are invited to IEP team meetings where transition services will be discussed; and
documentation that, if appropriate, a representative of a participating agency was invited to the
IEP team meeting with prior consent of the parent or student who has reached majority age.
71
Source of data for IEP compliance rate and exhibit 3v: PED’s APS Profile, last updated May 2018.

Activities One Year After Leaving High School

SPP indicator 14 has targets for the percentage of students with IEPs engaging in various
activities within one year of leaving high school. Exhibit 3y shows APS performance and targets
for these activities.
• Enrolled in Higher Education. Some 48.2 percent of former district students with IEPs met
this indicator, just short of the 49.0 percent SPP target.
• Enrolled in Higher Education or Competitively Employed. Some 78.4 percent of former
district students with IEPs met this indicator, exceeding the 76.0 percent SPP target.
• Enrolled in Higher Education, Competitively Employed, or Engaged in Other
Postsecondary Education or Training Program. Some 84.0 percent of former district
students with IEPs met this indicator, also exceeding the state’s 80.0 percent SPP target.
Exhibit 3y. Percent of Students Engaged in Various Activities One Year after Leaving High School
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
A. Enrolled in higher education C. Same as B or in some other
B. Same as A or competitvely
wtihin one year of leaving high postsecondary education or
employed
school training program
District 48.2% 78.4% 84.0%
SPP Targets 49.0% 76.0% 80.0%
Professional Learning
The professional learning association, Learning Forward, has developed its third version
of its Standards for Professional Learning, outlining features of professional learning that result
in effective teaching practices, supportive leadership, and improved student results. The standards
are based on seven elements listed in exhibit 3y.72
Exhibit 3z. Standards for Professional Learning
Standards for Professional Learning
Learning Communities. Occurs within learning communities committed to continuous
improvement, collective responsibility, and goal alignment.
Resources. Requires prioritizing, monitoring, and coordinating resources for educator learning.
Learning Designs. Integrates theories, research, and models of human learning to achieve its
intended outcomes.
Outcomes. Aligns its outcomes with educator performance and student curriculum standards.
72
As a trainee, however, students may meet state requirements and be paid less than the minimum wage. Retrieved
from https://www.learningforward.org/standards#.UMvVD7Yt0kU.

Leadership. Requires skillful leaders who develop capacity, advocate, and create support systems for
professional learning.
Data. Uses a variety of sources and types of student, educator, and system data to plan, assess, and
evaluate professional learning.
Implementation. Applies research on change and sustains support for implementation of
professional learning for long-term change.

Generally, APS’s data-design team supports professional development for principals.
Associate superintendents and principal support specialists oversee the data-design team. The team
has representatives from school administration, language and cultural equity, and special
education.
Multiple stakeholder groups expressed to the Council team the need for more high-quality
special education professional development. Major areas of concern focused on the following.
• Webpage Usability. Although professional development classes were advertised on APS’s
webpage, the site is not user friendly for special education. The specific targeted audience for
the professional development was also not always clear.
• Availability. Training was offered only during the school day and teachers can attend only if
their principals agree to provide a substitute teacher. Classes are not offered after
school/Saturdays, because funding is not available for stipends. Also, classes fill up quickly,
especially at the beginning of the school year.
• Compliance Focus. Training is needed that goes beyond compliance, special education law,
and IEP development. Specific areas of need include instruction for students with autism,
positive behavior support, co-teaching, and information for general educators.
• Head Teacher Follow-up. Although special education head teachers receive regular training
and are expected to share this information at the school level, personnel attendance is not
mandated, and small numbers routinely attend since there is little accountability for
participation.
• Educational Assistants. EAs are required to attend crisis intervention training for certification
that must be renewed annually. And they are required to attend training on blood borne
pathogens. Other than some union and district training options, particularly on specific
curricular materials, EAs receive little formal training. Additional access to training was
welcomed by EAs in interviews, because it enables them to move up the career ladder. A major
concern was that EAs were never asked about the type of training they would like to receive.
Typically, training available at the school level is not designed to meet the needs of EA’s
students. For example, although EAs are expected to collect progress-monitoring data, they are
not trained to do so.

Parent and Community Involvement

A large body of research demonstrates the positive effects of parent-professional
collaboration on outcomes for students with disabilities73 Effective collaboration is often grounded
in strong staff-parent relationships and the combined expertise of parents and professionals in
helping students with disabilities meet their goals. Many parents want to participate fully in
planning for their child(ren) and support changes in services. Nonetheless, collaboration tends to
be more difficult when parents are new to the country, when language differences present barriers,
and when parents come from poor or low socioeconomic environments.
SPP indicator 8 measures the percentage of parents with a child receiving special education
services who report that schools facilitate parental involvement as a means of improving services
and results for children with disabilities. Data published by PED in May 2018 for the 2016-17
school year showed that 79.2 percent of parents received such services, which was somewhat
below the state’s 84.0 percent target.
Focus Group Participants
There was considerable support for APS’s new on-line registration process that enables
parents to more easily access teacher-contact information. Also, the district sponsors special
education parent advisory committees that meet in each zone and are facilitated by principal
support administrators. Focus group participants provided feedback on the functioning of these
committees.
• Meeting Frequency. The committees meet three times each year, the minimum state law
requirement. The meetings are always held on the same night in each zone, which makes it
difficult for parents having children attending schools in different zones to attend all meetings.
• Meeting Agendas. Although identified as parent advisory committees, parents are not
empowered to set committee agendas. Instead, agendas are set by principal administrators who
also facilitate the meetings. There was a perception that more parents would attend meetings
if agendas more fully met their needs.
• Meeting Notices. Parents reported that they received notices of meetings with very short
notices, e.g., Friday afternoon for a Monday night meeting. Such short notifications do not
allow parents enough time to set up child care, etc.
• Leadership Support. There were concerns that the special education associate superintendent
had not often attended advisory council meetings and there was a desire for her to be more
visible and accessible.
73
A.T. Henderson, & K. L. Mapp. (2002). A new wave of evidence: The impact of school, family, and community
connections on student achievement. Southwest Education Development Laboratory. Cited in Fostering Parent and
Professional Collaboration Research Brief, Technical Assistance ALLIANCE for Parent Centers, National Parent
Technical Assistance Center at
http://wsm.ezsitedesigner.com/share/scrapbook/47/472535/1.7_Fostering_Parent_and_Professional_Collaboration.p
df.

AREAS OF STRENGTH
The following are areas of strength for APS in teaching and learning for students with
disabilities.
• Early Childhood Disability Achievement. Based on the state’s latest profile of the district
(2016-17), APS children entering or exiting early childhood programs almost met or exceeded
state achievement targets in all but one area. For the ‘substantially increased skills’ category,
outcomes ranged from 68.8 percent to 79.0 percent and percentage points ranged from 6.0
above to 5.2 below state targets. (Exhibit 3a.) In the ‘functioning within age expectation’
category, outcome rates were somewhat lower (53.5 to 65.1 percent), and percentage points
ranged from 14.4 above to 0.5 below targets. (Exhibit 3b.) For both sets of data, the lowest
areas of performance were in the acquisition/use of knowledge and skills.
• Graduation Rate. Data from 2013-14 to 2016-17 show that the graduation rate for students
with disabilities increased by 7.8 percentage points from 54.8 percent to 62.6 percent. Also,
the graduation rate for students with disabilities grew closer to the rate of all students (7.9 to
5.3 percentage point gap). (Exhibit 3x)
• Separate Schools. For APS students attending a separate center that enrolls only students with
disabilities, the district’s rate (0.26 percent) is smaller than the state’s 0.9 percent target, as
well as state and national rates (0.91 and 3 percent, respectively). (Exhibit 3j)
• Educational Environments by Race/Ethnicity. No students from any racial/ethnic group are
any more likely than those from any other racial/ethnic groups to be educated in one of three
educational environments that measure time in general education classes or in separate settings.
In addition, English learners were as likely as non-ELs to be educated in a general educational
environment or in a separate school/center. (Exhibit 3p)
• Charter Schools. Charter school focus group participants viewed their schools as being “fully
inclusive.”74
• Specialized Program Names. Last year, APS’s special education department reconfigured and
rebranded their specialized programs, moving from a disability-named categorical approach to
a needs-based approach. The programs are based on three categories, each having two to three
service levels.
• Specialized Program Protocols. Protocols are in place for special education department
resource teachers [working within the District Comprehensive Support Services (DCSS)] to
support special educators working in specialized program classrooms.
• Reading Specialists. A special education team of 6.5 full time reading specialists provide
training to special educators on reading programs used in specialized classes.
• English Learners with Disabilities. Special education/English learner administrators are
working together to address how language acquisition should be handled in special education
evaluations and eligibility determinations. Also, administrators have been working together to
develop support structures for ELs with disabilities to address both special education and
74
The Council team did not receive from APS any demographic data for charter school students so we were unable
to provide any comparative analysis.

language acquisition needs.

• Postsecondary Transition. Some 98 percent of students who were 16 years and above in 2016-
17 had IEPs with required components for postsecondary transition. Although the compliance
requirement is 100 percent, the district came close to meeting its compliance standard.
Furthermore, APS met or almost met state targets for students with IEPs engaged in various
activities within one year of leaving high school. (Exhibit 3y)
• Parent Involvement. APS’s new on-line registration process enables parents to more easily
access teacher-contact information. Also, the district’s special education parent advisory
committees meet in each zone and are facilitated by principal support administrators. In 2016-
17, 79.2 percent of parents reported that schools facilitated parental involvement as a means of
improving services for children with disabilities, which is only a few percentage points below
the state’s 84.0 percent target.

The following areas provide opportunities for APS to improve teaching and learning for
students with disabilities.
Early Childhood Achievement and Educational Environment

• Early Childhood Disability Achievement. Among APS children entering early childhood
programs below developmental expectations for their age but who increased developmentally
by age six when they exited the program, 68.8 percent met standards for acquisition/use of
knowledge/skills, which fell below the state’s target by 5.2 percentage points. (Exhibit 3b)
• Educational Environments. With a state target of 60 percent, a much smaller percentage of
APS children with IEPs were educated most of the day in a regular early childhood class
compared to state and national rates (8.3 percent, 41.6 percent and 45.2 percent, respectively).
With a 25 percent target, a much higher percentage of APS children were educated most of the
day in separate classes/schools apart from their typical peers compared to national rates (41.0
percent and 25.2 percent, respectively). With little state support for universal early childhood,
APS has limited opportunities to educate preschoolers inclusively. New Mexico’s new
governor has made preschool access one of her priorities and is proposing to fund its expansion
over five years. (Exhibit 3c)
Achievement, Dropout, Educational Environment, Suspension, and Absenteeism
• APS NAEP Disability 2017 Proficient/Above Rates. In reading, 4 percent of fourth and eighth
graders with disabilities scored proficient/above. Among fourth graders, this represented a
decrease of 3 percentage points from 2011. The rate was the same in both years among eighth
graders. In math, 5 percent of fourth graders with disabilities scored proficient/above, a
decrease of 1 percentage point from 2011. Some 2 percent of eighth graders with disabilities
were at least proficient, a decrease of 2 percentage points from 2011. (Exhibit 3d-g)
• PARCC. ELA and math proficient/above rates on PARCC among APS students with
disabilities in 2017-18 were higher than state rates. Also, APS rates increased by about 1.1
percentage point from 2014-15 to 2017-18 while state averages decreased. Given the very
small percentages of APS students with disabilities scoring proficient/above in reading and
math (smaller than 5 percent), there is considerable need for improvement at both district and

state levels. (Exhibits 3h-i)

• Dropout Rate. APS provided no data on students with IEPs who dropped out of school.
• Overall Educational Environment Rates. With a state target of 60 percent, 28 percent of APS
students with disabilities were educated in general education classes at least 80 percent of the
time, which is significantly lower than state and national rates (50 percent and 63 percent,
respectively). At the same time, a much higher proportion of APS students were educated in
separate classes at least 60 percent of the day compared to state and national rates (31 percent,
19 percent, and 13 percent, respectively). The state target was 15 percent. (Exhibit 3j)
• Grade Level Educational Environment Rates. A larger percentage of students were educated
inclusively (in general education at least 80 percent of the time) at the high school level than
at the elementary and middle school levels (32 percent, 28 percent, and 25 percent,
respectively). A higher percentage of students were educated in separate classes (in general
education less than 40 percent of the time) at the middle school level (36 percent) that at the
elementary and high school levels (both at 28 percent). (Exhibit 3k)
• Inclusive Educational Environment Rates. Overall, a much smaller percentage of APS
students spend time in general education classes at least 80 percent of the day compared to
students across the state and nation. The largest differences were for the areas of OHI (59
percentage points) and SLD (42 percentage points) (Exhibit 3n)
• Separate Educational Environment Rates. Overall, a much larger percentage of APS students
with disabilities spend more time in separate classes (i.e., general education classes less than
40 percent of the day) compared to state and national rates. Rates for the most common
disability areas were: SLD (21 percent, 12 percent, and 5 percent, respectively);
speech/language (15 percent and 4 percent for state/nation); other health impairment (29
percent, 17 percent, 4 percent, respectively); autism (59 percent, 48 percent, and 33 percent,
respectively); emotional disturbance (59 percent, 35 percent, and 18 percent, respectively);
intellectual disability (90 percent, 79 percent, and 49 percent, respectively). The areas of ED
and ID had the largest gaps with each area exceeding national rates by 41percentage points.
• Separate School/Center by Race/Ethnicity Risk Ratio. White students were three times more
likely than students in other racial/ethnic groups to be educated in a separate school/center.
(Exhibit 3o)
• IEP/No IEP Out-of-School Suspensions. While students with IEPs comprised some 19
percent of all APS students, they accounted for 34 percent of all students suspended during
2017-18. Students with IEPs were 2.14 times more likely than students without IEPs to be
suspended. The IEP suspension rate was highest at the middle school level (36 percent),
slightly lower at the high school level (34 percent), and lowest at the elementary school level
(27 percent). (Exhibit 3p)
• Race/Ethnicity Suspension Risk Ratios. Students with IEPs were more than twice as likely as
those without IEPs to be suspended from the following racial/ethnic groups: black (2.90 risk
ratio); white (2.83 risk ratio); and Hispanic (2.19 risk ratio). (Exhibit 3r)
• Absenteeism. Of all absent students (by range of days and grade levels), middle school students
with IEPs had the highest proportion of absenteeism, ranging from 22 percent (1 to 10 days)
to 46 percent (21 to 30 days). Students with disabilities were 1.78 times more likely than those
without IEPs to be absent for 21 to 30 days. (Exhibit 3t)

Support for Effective and Inclusive Education

General/special education administrators have not provided principals and school teams
with substantial support/training to reinforce the importance of more inclusive and effective
instruction. Most discussion occurs at the initiation of an individual principal or individual school
staff member. Little information was available on differentiated instruction and support for
students with disabilities in general education classes. These factors tend to influence IEP teams
when they are deciding the extent to which students should be educated in general education
classes, and it reinforces current practices rather than prompting the use of more successful
inclusive practices. Focus group participants reported to the team that there has been little
general/special education administrative support or training for:
• Improving and expanding high-quality co-teaching, including universal design for learning
strategies;
• Addressing master scheduling;
• Receiving or using standard curricular materials for all students receiving instruction aligned
with the Common Core State Standards;
• Pulling out students across grade spans for resource supports;
• Scheduling time for general/special education resource teachers to collaborate on common
students;
• “Counting” students with IEPs educated in general education for a significant amount of time
but less than 80 percent of the day;
• Having uniform expectations on providing IEP-related information to general educators; and
• Ensuring that special education resource teachers consistently receive statewide/other test
scores on their students.
Instruction for Students in Specialized Programs
APS’s specialized programs are defined around three student-needs categories, with each
category having several service levels. While these delineations may be clear to special education
administrators and are well-intended, the names for each category are not self-explanatory and
may be confusing to parents and school staff unfamiliar with their descriptions. Furthermore, when
looking at each service level, there were eight different specialized programs (in addition to cross-
categorical services), but their differences were not always clear. Focus group participants raised
concerns about the following:
• Program Support for Teacher Assignments. There were problematic systems for assigning
DCSS resource teachers and providing support to specialized program and cross-categorical
special educators. There was also unevenness in the placement of students in specialized
programs;
• Participation in General Education. APS’s school-based funding system negatively affects
the participation of students from specialized programs in general education classes.
• Placement. The process for considering changes in placements to more restrictive
environments can run one to two months and includes documentation of interventions
attempted that were not successful. These procedures are grounded in the district’s desire to

establish and monitor protocols to handle the high proportion of students educated in
specialized and separate classrooms and to prevent unnecessarily restrictive placements.
However, there were concerns that teachers do not receive the mentoring, coaching, and
training they need for students to succeed.
• Large class sizes and age spans in some settings;
• Inconsistent principal oversight of specialized programs and visits to specialized classrooms
during instructional rounds contributes to uneven program quality;
• Insufficient training for teachers with students in specialized classes and unclear descriptions
of targeted student populations in APS’s training catalogue;
• Custodial staff assignments that do not take into account disability-related school cleanliness
issues;
• APS Centers. Failure to consider the two APS centers that enroll only students with disabilities
as schools, which affects educational environment data and school oversight.
English Learners with Disabilities

Although APS support for English learners with disabilities has improved, administrators
believe there is room for improvement. Interviewees indicated that there is a need for additional
qualified bilingual special education/related services personnel. Principals received some
professional development on the importance of dual services, i.e., special education and language
acquisition instruction, but more is needed. There was also a recognition of the need for clearer
models to schedule and provide general, special, and English language acquisition instruction.
Support for Student Behavior
According to APS staff, one of the district’s major challenges concerns student behavior.
This situation is exacerbated by the large number of noncertified APS special educators and the
small number of related service personnel who provide direct services. The district’s primarily
strategy for addressing this issue has been focused on the use of FBAs and BIPs. However, the
absence of a comprehensive systemwide framework for positive behavior supports (including
restorative justice) increases the number of students with problematic behavior. As the FBA/BIP
tools were distributed, teachers began to contact the ATF with their concerns about new
paperwork/documentation requirements. Union efforts led to additional administrative guidance
and a question/answer document, but confusion has continued. Focus group discussions about this
topic absorbed a disproportionately large amount of time compared to other issues discussed
during the Council team’s visit. Following are major concerns associated with the FBA/BIP
guidance and implementation.
• Clear and Timely Guidance. Lack of clear, unambiguous, and user-friendly written guidance
with follow-up training. Information was released without prior notice or substantial
explanation;
• Contradictory information given on the need to conduct FBAs prior to any social work
services or continuation of services absent an FBA (and BIP if needed); 75
75
Future references to the completion of FBAs imply the need to develop/review and implement BIPs, as warranted.

• Overly Strict Construction. Overly strict correlation of related services (such as social work)
with the least restrictive environment (LRE) principle. Overly strict language that correlates
the FBA mandate for students with behavior adversely affecting learning that exceeds IDEA
and New Mexico requirements.
• Complexity. Unduly burdensome, complex and time-consuming FBA documentation for
students with disabilities does not vary based on the degree to which a student’s behavior
adversely impacts learning.
• Technology. Faulty technology related to FBA templates;
• Personnel Expertise. Expectations for special educators to complete comprehensive FBAs that
the literature describes as the domain of such specialists as school psychologists, behavior
specialists, and social workers, etc.; and
• Survey. High agreement by APS/ATF survey respondents on problems associated with the
communication of special education policies and procedures.
Professional Learning
Multiple stakeholder groups agreed that there was considerable need for more high-quality
special education professional development. Major areas of concern included:
• Training Notice. APS’s training webpage does not always have a clear indication of targeted
audiences for special education professional development;
• Access to Classes. Training (with classes that fill quickly) offered only during the school day
and attendance is based on principal approval and substitute availability and no after
school/Saturday training because stipends are not available;
• Instruction Related. There is considerable need for training beyond compliance that would
include instruction for students with autism, positive behavior supports, co-teaching, and
information for general educators;
• Head Teachers. Special education head teachers have difficulty sharing lessons learned from
their professional development with general school personnel, because attendance is not
mandated;
• Educational Assistants. Other than some required annual training, EAs have limited access to
training appropriate for their students, including training on progress-monitoring data they are
asked to collect.
Parent and Community Involvement
Attendance at special education parent advisory committee meetings is negatively affected
by the following:
• Parents do not set committee agendas;
• Meetings are held on the same night in all zones, making it difficult for parents with children
attending schools in different zones to attend;
• Short notice of meeting dates, e.g., Friday afternoon for a Monday night meeting, leaves little
time to set up child care, etc.; and

• Nonattendance by the associate superintendent.
RECOMMENDATIONS
The following recommendations are offered to improve APS’s provision of special
education instruction and related services.
5. Expansion of Inclusive and High-Quality Instruction and Supports for Students with
Disabilities. Begin increasing the provision of effective and inclusive special education
services. To expedite this process, consider using an experienced consultant who has had
successful outcomes in this area to help facilitate planning and implementation.
a. Inclusive Education Vision and Board Policy
• Retreat. Have the district’s MTSS leadership team plan a day-long retreat for stakeholders
(including the ATF) on establishing a vision of inclusivity and quality instruction for
Discussions should include but not be limited to:
- School culture for ALL students (including those in specialized classes and centers);
growth mindset; people first language; etc. Have discussions around the prevalent
perception that “special education” will solve academic and behavioral issues, and
what’s needed to mitigate the “remove them from my class” mentality.
- Address the interaction between IEP decision-making for student placement and
school-based models for effective instruction. Until such models and training on them
are in place, IEP teams will be unlikely to consider inclusive settings to be realistic for
students who are otherwise being educated for a substantial period in separate
classrooms.
- Identify and involve exemplar schools that are practicing this inclusive culture to share
their frameworks, practices, results etc.
• Board Policy. Establish a school board policy stating a clear and defined vision for APS
on the value of inclusivity that reinforces the district’s commitment to improving
academic achievement and social/emotional well-being for students with disabilities.
- Highlight the importance of collective central office and zone support, and principal
leadership in providing students with IEPs the differentiated and scaffolded
instruction they need to learn in general education settings.
- Expect that students will receive rigorous core instruction that is linguistically
appropriate and culturally relevant. These expectations should be within reach when
school personnel are provided the resources they need and as teachers become more
familiar with instruction based on the principles of UDL.
- Ensure the district’s vision emphasizes the importance of evidence-based academic
and positive behavior interventions/supports.
b. Implementation Plan. With staff from the multidisciplinary team assembled pursuant to
Recommendation 2b, develop a written multi-year action plan that calls for written
expectations, professional learning, data analytics, and accountability.

• To the extent reasonable, link components in the MTSS implementation plan referenced
in Recommendation 2c. Incorporate the data review proposed in Recommendation 4.
Once the plan is complete, establish ways for school-based teams to embed local
implementation activities into their school improvement plans, e.g., 90-day plans.
• Volunteer School Cadre. Identify a volunteer cadre of schools to lead in planning and
implementing inclusive service models. Provide each school a small grant with a template
for action planning.
• Phase in this process over about five years to include all schools.
• Identify general and special education personnel who schools can contact to support their
implementation efforts to better meet the needs of students with IEPs.
• Support planning and implementation with professional development based on
information that becomes available in implementing Recommendation 5.
Collaboration with Higher Education. To the maximum extent possible, collaborate with
current/new higher education and other partners to involve them in this process and strengthen
district capacity. Encourage partners to offer training through their own programs or other
mechanisms as APS engages in this endeavor.
Feedback. Collect feedback on the draft improvement plan from stakeholders at varying grade
levels and from special/general education administrators, principals, general/special
education teachers, related-service providers, teacher assistants, parents, and community-
based organizations. Continue this feedback loop as the plan is implemented in order to
identify and address concerns.
Communication. When finalized, post the implementation plan on the district’s website,
along with relevant links to district information and publicly available resources.
Communicate the plan widely to all internal and external stakeholders, including parents who
are English learners, and share the purposes and expected outcomes of the plan.
Components. When developing the implementation plan, have activities that include but are
not limited to the following—
• Early Childhood. Increase the number of children educated inclusively in regular
preschool classes--with no more than 50 percent and close to 30 percent of classes
composed of children with disabilities. The Council team can provide APS with names of
other school districts that have done this effectively. When more children are successful
in inclusive classrooms, there will be higher expectations for continuing these
opportunities in kindergarten, and spur high-quality education for students with
disabilities.
• Differentiated Instruction. Provide for linguistically appropriate and culturally
competent instruction aligned with core standards, differentiated for students with reading
and math performance significantly below those of their classroom peers.
• Effective Instruction Based on Core Curricular Standards. Improve instruction aligned
to core curricular standards and expand increasingly intensive interventions, especially in
literacy and math, to reinforce standards-based instruction. Reconcile the different
instructional materials currently used by general and special educators.

• Supplemental Interventions. As addressed in Recommendation 2c, ensure that students

with disabilities can access Tier 1 and 2 interventions along with Tier 3 interventions
whenever they are appropriate to meet their needs.
• Planned Collaboration. Set expectations that general/special educators,
paraprofessionals, and related service personnel will collaborate in providing instruction
and interventions for students they have in common.
• Positive Support for Behavior. Enhance supports for teachers who work with students
with challenging behavior to increase their time engaged in teaching and learning.
- Identify and expand the number of personnel available to observe classrooms, model
effective practices, and coach in schools with no other internal expertise.
- Address the numerous issues associated with APS’s process for requiring FBAs/BIPs;
have the APS/ATF facilitator address FBA/BIP issues of concerns, including those
described in this report; and identify a group of stakeholders to work with the facilitator.
- Ensure that personnel who have expertise or knowledge of issues associated with
students whose behavior adversely impacts learning are integrally involved in the
reform process, e.g., BCBAs, redirectors, social workers, psychologists,
general/special educators, EAs, etc.
• Criteria/Guidance. Revise criteria and guidance for when FBA/BIPs are required and
when they are to be considered. Ensure the guidance and forms are user-friendly, effective,
and workable.76 Align requirements with those established under IDEA and New Mexico
code. Identify best practices in FBA implementation, and build them into guidance along
with explanations.
- Social Work. Remove the requirement for an FBA/BIP to initiate/maintain social
work services through an IEP. The Council team is aware of no federal or state
requirement for this standard in APS or anywhere else. The district could easily be
using either formal or informal procedures, such as classroom observations, social
work assessments, or outside evaluations rather than FBAs to demonstrate a student’s
need for this service. In addition, do not link a social work assessment to “least
restrictive environment (LRE).”
- Placement. Consider an FBA when determining if a student requires a more restrictive
placement. Various protocols are used by Council member districts in making this
determination, and they can be provided upon request.
— Various Formats. Establish various FBA/BIP formats that can be used based on the
intensity of student needs, e.g., practical versus comprehensive. 77 The provision of a
practical FBA should not be based on a student’s disability status and should be
available to assess students with/without IEPs.
— Technology. Ensure that FBA/BIP electronic templates are working properly.
76
Upon request, the Council team will seek and share models of FBA/BIPs and guidance that have been user
friendly/legally sufficient in other districts for consideration.
77
For example, see the PBIS website discussing ‘practical’ and ‘comprehensive’ FBAs, retrieved from
https://www.pbis.org/common/cms/files/Forum12/A6_Loman_Strickland.pptx.

— Personnel. To the maximum extent possible, rely on individuals who have graduate
training in the development of FBAs to guide or engage in comprehensive FBA
assessments.
• English Learners with IEPs. Bring together personnel from the English learner and special
education departments, along with others with instructional expertise, to develop
intervention models for ELs with disabilities. Based on a review of current models, identify
best practices in the implementation of special education and language acquisition
strategies.
• Flexible Service Delivery Models. Identify effective approaches for supporting students in
general education classes using flexible service models. Such models should 1) improve
teaching/learning of students in general education classes using a flexible service delivery
model; 2) expand options for students who would otherwise attend specialized programs
to receive instruction in general education classes; and 3) support English learners with
IEPs to address their language acquisition needs as well as their instructional needs related
to their disabilities. To support implementation of these models, address the following –
— Improving and expanding high-quality co-teaching, including using UDL strategies;
— Providing effective supplemental interventions inside or outside of general education
classes with flexible groupings of students with common intervention needs, and
adjusting the groups based on changing in student needs.
— Explaining how to “count” students with IEPs educated in general education for a
significant amount of time but less than 80 percent of the day;
— Improving master schedules by sharing models that schedule activities for students
with disabilities first, using schools that have been successful in this area.
— Scheduling common planning time for special and general educators who work with
the same students.
• Specialized Program Configurations, Instruction and Support. Review APS’s
specialized program offerings to assess whether the district needs eight different
specialized programs (in addition to cross-categorical services). 78 Also, address issues
raised during the Council team’s review, including those listed below.
— Ensure that various service models have names that are user-friendly.
— Ensure curricular materials and instructional practices are sufficiently rigorous and
meaningful, and strategies are in place that result in students progressing academically.
Ensure students receiving instruction based on alternate standards are using appropriate
materials, e.g., Unique Learning Systems, rather than materials designed for instruction
aligned with Common Core State Standards, e.g., Ready/I-Ready.
— Address APS’s funding methodology for special and general education to remove any
barriers for students in specialized programs to access general education classes; 79
78
See for example, the Chicago Public Schools’ configuration of services at
https://www.cps.edu/odlss/Pages/ServicesandPrograms.aspx.
79
If necessary, consider implications of state funding and any need to lobby for changes to promote inclusive
instruction.

— Review custodial staff assignments to ensure they consider disability-related school

cleanliness issues;
• Class Composition and Age Rages. Establish thresholds for the maximum number of
students with IEPs (excluding those with speech/language services only) in general
education classes, maximum class sizes for specialized programs, and maximum age
ranges for specialized classrooms. Identify schools that have classrooms exceeding these
thresholds. Based on these data, have associate superintendents and principal support
administrators (general/special) work with principals to problem-solve and make changes.
• APS Centers. Within a reasonably short period, establish the two APS centers that enroll
only students with disabilities as schools. Consider the fiscal/programmatic efficiency of
having two principals for a small number of classes and students and the possibility of
having one principal overseeing both schools. Have the principal(s) directly report to one
(or two) zone associate superintendent(s) with continued support from and interaction with
the special education department.
c. Written Expectations. As part of the implementation plan from Recommendation 5b, develop
written expectations on each plan component. (Coordinate and link with Recommendation 2e.)
Prior to finalizing any written expectations/guidance and forms, establish a reasonable period
to obtain and take into consideration feedback from stakeholders, including the ATF. Also,
pilot guidance/forms prior to finalization with volunteer personnel to eliminate any unintended
consequences.
d. Differentiated Professional Learning and Parent Training. Embed in the professional
development curriculum content needed to carry out Recommendation 5. (Coordinate and link
with Recommendations 2f and 3e.) Embed into instructional rounds indicators on
implementing plan components. With multi-disciplinary representatives on the district’s
MTSS leadership team (Recommendation 5b), map out the professional development
curriculum and specify which stakeholders are the main audiences for the professional
development. Consider an annual conference to showcase exemplary school practices,
information, etc. Planning needs to include but not be limited to the following –
• How training will be provided using a multidisciplinary and interdepartmental approach,
so that professional learning to promote inclusive education is not viewed solely as a
“special education” initiative;
• The provision of compliance information through an instructional practice lens;
• Content, mode of delivery, time/frequency, communication of training, follow-up
activities, etc. To the extent possible, have training provided at the school level through
professional learning communities, and through blended learning;
• Written materials that support training and follow-up via web-based postings;
• How all stakeholder groups will be included, e.g., principals, general and special educators,
clinicians, EAs, parents, etc., and how training information will be relevant and
differentiated for specified personnel;
• How and when all personnel will be trained in each critical area, and any need for

substitutes and/or stipends for out-of-school time;

• How key information will be communicated effectively, including the use of on-line
training for compliance issues that are more routine in nature;
• What additional modeling, coaching and supports may be needed;
• Principal leadership training necessary to maximize and leverage inclusive and high-
quality instruction and supports, including training on flexible uses of school-based
budgets to expand inclusive education;
• Ongoing training needs for new personnel;
• Involvement of ATF, higher education partners, and parents, etc.80
In addition, keep in mind issues raised by focus group participants, including the need for the
training webpage to provide accurate information for targeted audiences; classes filling up
quickly during the school day and variability of principal approval; reliance on a “train the
trainer” model when principals cannot afford trainers to inform school-based personnel; etc.
e. Data Analysis and Reports. With the multidisciplinary team assembled in Recommendation
5b, identify data and charts such as those included in this report as well as others that are
necessary for district, zone, and school personnel to problem-solve, strategize, and proactively
carry out their responsibilities. 81 Based on these data, develop standard user-friendly reports
that inform progress at various levels of the district. In addition to activities proposed in
Recommendation 2g and 3e, embed in the 90-day plans the types of data needed to better target
patterns and areas of concern. Use risk ratios to better understand district practices and their
effects.
f. Monitoring and Accountability. Expect all principals to oversee special education in their
buildings and hold them explicitly accountable for such. Articulate how cohort principal
leaders will work with their principals and how they will ensure principals are serving students
with disabilities. Embed the following activities into the monitoring and accountability systems
described in Recommendations 2h and 3f.
• Data Checks. Include information on students with disabilities in data discussions to
inform follow-up actions and track outcomes. Ensure that data includes all SPP indicators.
• Fidelity Assessments and Instructional Rounds. Review tools used for instructional
rounds and revise them as needed to monitor instruction/interventions being provided to
students with disabilities in general education classes, resource classes, specialized
program and cross-categorical classes, and centers. Initiate technical assistance,
professional development, coaching, and mentoring to improve practices based on the
results of rounds.
• Timely Communication and Feedback. Establish a process for timely feedback to the
80
For parents, see Recommendation 6a.
81
See, e.g., achievement data (exhibits 3a-I,3x); suspension data (3p, 3r); educational environments (3j-o, 3p);
attendance (3t), special program configurations (3p-u, 3w, 3z, and 3bb), percentages of students with IEPs by
school; and other relevant data, such as average and outlying class sizes and age ranges, total days students are
suspended, and dropout rates for students with/without IEPs.

district’s MTSS leadership team on barriers to effective inclusive education.

6. Parent Support & Engagement. Improve APS’s engagement with parents/families of children
with disabilities to expand their involvement in schools and support of their children’s
education.
• District Parent Advisory Council. Work with a broad range of parent representatives from
all zones and various community-based organizations to design an effective districtwide
advisory council, hosted by the special education associate superintendent, to collaborate
with the special education leadership on various aspects of zone-based parent advisory
committee meetings. Have the parent council include representatives from each of the
zones and ensure they reflect a variety of student/parent needs. Have the parent council
address the manner in which APS meets state requirements and can reach out most
effectively around the frequency and timing of zone meetings; the content of meetings;
processes for addressing parent questions; zone meeting notices; and their attention to
parents who are English learners or who have sensory disabilities; child care; refreshments;
time of day, etc. Furthermore, have the parent council review the professional development
curriculum described in Recommendation 5d and give feedback on topics of interest to
parents.
• Parent Conferences. Consider having one or two districtwide parent conferences during
the year.
• Presence of Associate Superintendent. At regular intervals, have the special education
associate superintendent attend the zone-based parent advisory committee meetings to have
a visible presence and address parent concerns.

IV. Support for Teaching and Learning for Students with Disabilities
This section summarizes APS’s supports for teaching and learning for students with
disabilities. The section covers interdepartmental collaboration, administration and operation of
special education, compliance issues, fiscal issues, and accountability.
Interdepartmental Communication and Collaboration

To leverage district resources to enhance the achievement and social/emotional wellbeing
of all students (including those with disabilities, English learners, and ELs with disabilities) it is
essential that all central office and school leadership personnel collaborate effectively. In the
Council team’s experience, urban districts often strive to have collaborative staff structures but
tend to operate in silos. As discussed below, this applies to APS as well.
APS Organizational and Meeting Structures
The district has several structures that involve various members of the superintendent’s
cabinet and leadership team, design teams, and principals. Each one has its own meeting and
coordination demands.
• Cabinet. The superintendent’s 12-person cabinet meets for half days on a regular basis. In
addition to the special education associate superintendent and four leadership and learning
zone associate superintendents, the cabinet includes leaders of equity, instruction and support;
finance; information/strategy; operations; communications; human resources; legal; and board
services. It was reported to the Council team that the special education associate superintendent
is actively engaged and involved.
• Leadership Team. The superintendent also holds monthly meetings with her 20-person APS
leadership team, which includes the following personnel in addition to cabinet members:
technology; APS foundation leadership; maintenance/operations; innovation; Title I; school
police; the service center; and student, family and community supports.
• Design Team. An APS design team of about 30 people meets monthly to review and discuss
professional development needs. Participants include zone associate superintendents, and
special and general education support principals. Support principals lead the team on a rotating
basis. The team was told that special education’s role and participation in these meetings have
improved after discussions about the need for additional involvement.
• Principal Zone Meetings. Principals meet monthly by zone. The relevant special education
principal support administrators attend these meetings to address special education issues and
answer questions. Reportedly, the special education associate superintendent does not
regularly attend these meetings. Also, principals of APS’s specialized schools, e.g., Highland
Autism Complex, have not been invited to these meetings as the centers are not recognized as
schools. We were advised that their attendance was being planned.
• Emerging Principals. Emerging principals meet across zones with the zone associate
superintendents. Typically, special education personnel are invited as the need arises.
However, it is intended to have special education’s lead principal support administrator attend
monthly to answer questions.

Learning Zone Structure and Relationship with Special Education

Since the beginning of the 2017-18 school year, APS schools have been organized into
four geographical learning zones. Each zone is comprised of some 21,000 students in 35 or so
schools. Each zone is anchored by three high schools and their feeder middle/elementary schools,
except that zone 4 has four high schools. Each zone is led by a leadership/learning associate
superintendent and support staff.
Instructional Rounds
Each learning zone participates in monthly rounds at selected schools. The associate
superintendent leads each instructional round, which includes neighboring principals. This
structure is intended to promote dialogue and collaboration among feeder schools and provide
feedback about how to move schools forward.
Each zone’s special education administrators are invited to participate in instructional
rounds, along with administrators from other departments. According to focus group participants,
however, special education principal support administrators do not consistently participate in
instructional round teams. The perception is that special education administrators are too busy
“putting out compliance fires” to participate. However, rounds provide a unique opportunity for
special education administrators to address instructional issues affecting students with disabilities,
and they foster more effective and inclusive teaching and learning approaches.
Instructional rounds do not occur at APS’s specialized center, e.g., Highland Autism
Complex, which is not recognized as a school. Special education principal support administrators
conduct instructional rounds with special education assistant principals at schools with relatively
large numbers of specialized programs and classrooms.
Collaboration with Special Education
Zone associate superintendents and general/special education principal support
administrators do not routinely meet to discuss patterns of need in each zone. Special education
principal and program support administrators have varying relationships with their respective
associate superintendents, ranging from good to nearly nonexistent. Typically, they communicate
problems each sees. Further, other than to address critical compliance issues, there is not a strong
sense of collaboration between general and special education principal support administrators.
This circumstance is associated with focus group concerns about instructional issues that are seen
only as general education or as solely special education, each requiring a different set of personnel
and strategy.
Special Education and Equity, Instruction and Support Collaboration
Of the various equity, instruction and support department components, the extent to which
curriculum/instruction, early childhood development and charter schools operate in collaboration
with special education has implications for teaching/learning of students with disabilities.
According to focus group participants, although interdepartmental collaboration has
improved, there is room for more structured and intentional cross-departmental work. The
following feedback reflects this perspective, and it also provides positive examples of collaborative
work.

• Scheduled Interaction. Generally, there were no regularly scheduled meetings or formal

strategic planning sessions for special education and curriculum/instruction administrative
personnel. There was a perception that collaboration was sometimes negatively affected by
‘turf wars’ and an inability to transcend vested interests. This was especially apparent with the
rollout of different curriculum materials for students in general education and students in
specialized classrooms who participate in regular statewide assessments. There have been
some efforts to bridge transition specialists and counselors, especially in the implementation
of new graduation requirements and their impact on students with disabilities.
• Early Childhood. More collaboration between early childhood and special education
administrators would facilitate inclusive education in early childhood programming. Although
the two groups have met in the past, there have been differences of opinion about common
service parameters. These discussions are necessary as APS works with the state to explore
expansion of universal pre-kindergarten classes.
• Special Education and English Learners. There are strong working relationships between
special education and language/culture personnel to address identification of and support for
ELs with disabilities. In part, this relationship has been strengthened by the identification of a
special education principal support administrator who understands English language support
processes, and this work is now part of her job description. This collaboration is now an
instructional focus in both departments.
• Charter Schools. Charter school personnel expressed appreciation for the support they receive
from charter school and special education administrators for students with disabilities. For
example, reports show that the number of untimely evaluations and IEPs in charter schools
have been significantly reduced.
Overall Comments
Focus group participants expressed concern about the extent to which special education
and general education operate separately at the central office, zone, and school levels. Some
indicated that collaboration was made more difficult by the location of the two departments in
separate elevator columns in the district’s headquarters. There was also a perception that
personality differences create barriers to collaboration, effective working relationships, and
productivity.
Joint accountability for outcomes could help to transcend this difficulty. Similarly,
identifying issues that involve multi-department attention with joint work plans would be helpful
in producing positive results. For example, the Council team learned that special education and
human resources had not routinely met to address personnel recruitment issues.
In addition, the district did not appear to have established uniform guidance for inter-school
personnel transfers not governed by negotiated agreements, e.g., transfers requested by related-
service personnel. The joint expertise of personnel from both departments (i.e., special education
and human resources), along with shared data, joint progress monitoring, and shared
recommendations/implementation activities would help address the district’s significant special
education related-services issues and personnel shortages.
One final observation relevant to this topic involved the district’s response to the Council
team’s request for data and information for this review, which required attention from multiple

departments in addition to special education. Only after the Council team requested information
on multiple occasions did APS personnel understand that data would have to come from varying
departments and that staff would have to collaborate to obtain it. Staff then had to create a process
to gather the information. We appreciate the district’s perseverance in providing the Council team
with the data/documentation necessary for us to produce this report, but it probably should not
have taken such an effort.
Administration and Operation of Special Education

This section addresses the special education department’s organizational structure. It also
addresses focus group feedback on support administrators work with school-based personnel.
Generally, focus group participants indicated that special education department personnel had a
good understanding of the law and were trying to improve instruction and supports for students
with disabilities.
Reportedly, there was also a strong working relationship among special education
department personnel, and there was a high level of respect by the special education leadership
team for their associate superintendent. Also, special education teachers expressed a general
appreciation for the support they receive from various special education administrators.
Special Education Department Organizational Structure
The district’s website continues to post the special education department’s 2016-17
organizational chart that includes names and telephone numbers from September 2016. 82 APS
provided the Council team with the department’s most recent organization chart, which was dated
December 19, 2018. According to the 2018 chart, the following positions report directly to the
special education associate superintendent:
• Student achievement executive director;
• Lead principal support administrator;
• Evaluations and related services executive director;
• Compliance executive director; and
• Budget/data director.
The associate superintendent has full-day weekly meetings with her leadership team to
review data on a variety of issues. Based on the experience of Council team members, this appears
to be an excessive amount of time for leadership to be away from day-to-day requirements.
The department’s organizational chart generally describes these administrators’

responsibilities and personnel under their supervision. Exhibit 4a shows the organizational
structure of the department.
82
Retrieved from http://www.aps.edu/special-education/documents/special-education-org-chart.

Exhibit 4a. Special Education Department Organization

Special Education Associate Superintendent
Student Achievement Executive Director
Lead Special Education Principal Support Administrator
4 Administrators (Aztec Complex, Highland Complex, and Transition Services)
Principal Support for Special Education Administrator (Comprehensive Support
Services)
Principal Support Administrator (Nursing, cross-categorical programs, and PAC)
8 Principal Support for Special Education (Per zone, one each for elementary and
middle/high schools; supervise respective related services personnel, e.g.,
occupational/physical therapists, speech/language therapists, etc., and IEP specialists)
10 Support Assistant Principal (In schools with many specialized program classes)
Evaluations & Related Services Executive Director (Includes developmental preschool support)
3 Instructional Managers (Diagnostic Centers)
3 Diagnostic Technicians
Compliance Executive Director
1 Instructional Manager; 1 special education auditor
Budget/Data Director (Data/Budget Technicians)
Data/Budget Technicians

The executive director is responsible for assistive technology, math/reading curriculum;
educational technology (UDL), and gifted education. The organizational chart does not list the
names or titles of any administrative positions reporting directly to the executive director.
Lead Principal Support Administrator
In addition to overseeing the extended school year and student transfers, the administrator
is responsible for supervising 4 administrators; 1 special education principal support (SEPS)
administrator for community support services; 10 support assistant principals; and 8 zone-based
SEPSs. The lead principal support administrator appears to have oversight for more than 50 staff
members.
The positions reporting to the lead principal support administrator and associated
responsibilities include the following—
• One Special Education Principal Support. The administrator oversees support for APS’s
Comprehensive Support Services Program, which incorporates the specialized programs
described in Exhibit 3v. The administrator also supports the nonviolent crisis intervention
(NVCI) program, the resource team supervisor, “Review 360” (behavior data system), and
instruction for students with Tourette’s Syndrome. According to an excel file provided to the
Council team, some 31 individuals report to the administrator to support this work (20 resource
teachers, 1 psychologist and 10 social workers). In addition, reporting to the administrator is a
vacant principal support for special education position, which oversees nursing, principal
autism center (PAC), and cross-categorical programs. (See Exhibit 4b.)

• Ten Support Assistant Principals. These administrators each serve as an assistant principal in
a school having large numbers of students in specialized program classes (McCollum,
Chaparral, Dennis Chavez, Montezuma, Jimmy Carter, Mark Twain, Grant, Marie Hughes,
Sandia High School, and Valley High School.
• Eight Special Education Principal Support Administrators. Two administrators are assigned
to each learning zone, one for elementary schools and one for middle/high schools. According
to APS’s excel document and shown in Exhibit 4b, each special education principal support
administrator supervises 10 to 15 zone-based personnel, which include 23 occupational
therapists, 14 physical therapists, 25 IEP specialists, 24 adapted physical educators, 12 social
workers, and 1 speech/language pathologist. In addition to their supervision of these personnel,
the principal support liaison with each respective zone associate superintendents attends
instructional rounds, supports principals, generally supports all schools within their zoned
grade level, visits special education classrooms, and provides feedback about the instruction
they have observed.
Exhibit 4b. Principal Support Supervision by Zone and Grade Level
Zone 1 Zone 2 Zone 3 Zone 4
ES MS/HS ES MS/HS ES MS/HS ES MS/HS
Occupational Therapist (23) 7 1 7 2 1 1 4 2
Physical Therapist (14) 3 2 3 2 3 1
IEP Specialist (25) 7 6 5 7
Adapted Physical Educator (24) 2 4 4 3 4 2 5
Social Worker (12) 1 1 1 3 1 5
Speech/Language Pathologist (1) 1
- 25 IEP Specialists. Although focus group participants indicated that IEP specialists
support elementary schools, the excel report listed each as reporting to one of the
middle/high school principal support administrators. 83 APS explained that each IEP
specialist is assigned to a zone and is supervised by the zone support principals for special
education. The IEP specialists are responsible for facilitating the IEP process and serving
as the district representative on initial evaluations and IEPs, some annual IEPs, and changes
in eligibility/placement. The intent has been for IEP specialists to support school personnel
by understanding the SAT process (including interventions), special education
processes/rules, and relevant forms. (Head teachers perform this role at middle and high
schools.84)
The excel document lists 25 IEP specialists, including one vacant position. Based on this
figure, each IEP specialist supports an average of some 3.6 elementary schools, which
would enable each specialist to visit assigned schools slightly more than once each week.
Focus group participants had varying thoughts about the role of IEP specialists. For some,
these specialists can be more objective than school-based personnel because they ‘have no
particular agenda.’ Others had concerns that the specialists possessed varying levels of
expertise and were not always familiar with students because of the number of schools to
which they were assigned.
83
The IEP specialists are not listed on the special education department’s organizational chart.
84
Information about head teachers is provided further below.

• Two Special Education Complex Leaders. There is one administrator for the Highland
Complex and one administrator for the Aztec Complex. Both complexes educate only students
with significant disabilities. In addition, the Highland Complex administrator supports the
Project Search transition program; and the Aztec Complex administrator (with an assistant
principal) directs homebound, interim alternative education services, and coordinates with
residential treatment centers (RTCs).
• Two Transition Coordinators. Two administrators coordinate transition services, one for
community-based services and the other for school-based services.
Evaluations/Related Services Executive Director
The executive director is responsible for supporting developmental preschool, and related
service liaisons. Three instructional managers have positions reporting to the executive director.
Two each have oversight for a diagnostic center supervisor and associated audiologists,
educational diagnosticians, occupational therapists, school psychologists, and speech/language
pathologists. The third instructional manager supervises low incidence personnel (e.g., deaf, hard
of hearing, and vision impairment), interpreters, and records management.
Compliance Executive Director
The executive director oversees processes that include document review, EPSS, head
teacher liaisons, state performance plan indicators, management of state and federal complaints,
due process, procedural directives, IEP compliance, and private schools. An instructional manager
and special education auditor report to the executive director.
Budget/Data Director
The director oversees the special education budget and data. Data and budget technicians
report to the director to support this work. One of the director’s major tasks concerns the validation
of special educator caseloads, which drives state funding and extended contracts. While the IEP
system shows caseload data, the director independently validates time sheet information with head
teachers and principals who sign time sheets to confirm their contents. Special education personnel
send updated caseloads directly to the director to facilitate completion of four annual state reports.
The director engages in this lengthy process to address concerns about the accuracy of school-
based data entry. As an alternative, APS could hold school personnel accountable for providing
accurate data.
Focus group participants provided feedback on the support that special education
administrative personnel provide to schools, and about the department’s communications and
responsiveness.
• Principal Support Administrators. The principal support team reported that they worked well
as a team and appreciated that they sit near each other. However, administrators have no
consistent expectations for school visits and are not in schools on any regularly scheduled
basis. These personnel were generally not viewed as being as responsive as school-based staff
would like. As previously indicated, these administrators have zone-based responsibilities and
they do not consistently attend instructional rounds with zone associate superintendents.
Further, they do not appear to interact regularly with associate superintendents or collaborate

on issues common to elementary or middle/high schools in each zone.

A strong working relationship between these parties would be important. But there were varied
reports about the strength of these relationships, with some working well and others who rely
less on school visits and more on phone calls or emails from the central office.
• Special Education Assistant Principal Support Administrators. There were also concerns that
various assistant principals were assigned to schools having a significant proportion of students
educated in specialized programs but who do not have expertise in these areas of need.
• Board Certified Behavior Analysts (BCBAs). APS now has three BCBAs, a nod to the
growing recognition nationally to their value in supporting students and teachers around
positive student behavior. Currently, they report to the principal support administrator
overseeing specialized programs. APS aspires to have five BCBAs, one for each zone.
• Reporting Clarity. The new organizational chart more clearly shows reporting lines than the
previous chart. However, focus groups voiced concerns about the direct and multiple indirect
reporting lines in the structure that sometimes affected clear communications and the quality
of school support. For related services personnel, there is a supervisor, a liaison, and an
administrator for special programs, and various support assistance principals. It was not clear
which of these positions had the greatest authority in cases where there were disagreements.
Furthermore, it was reported that the organization chart changes frequently and the field does
not always know who to call for support.
• Contact Information. Typically, administrators prefer communicating through email (at least
initially) to avoid ‘phone tag’ and to have a record of discussions. The past and current special
education organizational chart contains telephone numbers but no email addresses, which may
make communications more difficult.
• Consistent Communication. Multiple stakeholders throughout the district reported that they
do not receive special education information that is consistent and reliable, regardless of the
information’s source. Generally, each personnel area is given information and directives from
different administrators. For example, principals, related services personnel, and specialized
program personnel are each presented information in separate meetings, and the information
is not universal and consistently backed up with a common set of written documents.
Reportedly, one could ask a question three times to the same or different persons and receive
different answers each time. In such circumstances, it is not surprising that information is
interpreted as having varying emphases and importance. These circumstances feed a
perception that the department is poorly managed.
• School-based Related Services Personnel. Some but not all related service areas have a liaison
to the special education department. There were concerns that supervision changed frequently,
and that professional development occurred less frequently than in prior years.85
• Centralized Special Education Records. APS maintains special education records centrally,
requiring school personnel to copy and send them, and central office personnel to receive,
store, and retrieve them. Many much larger urban school districts, such as the Chicago Public
Schools and the Los Angeles Unified School District, no longer store records centrally. Instead,
85
One reason given for this change is that logs documenting related services provided by personnel do not include
this activity. This issue is discussed further below.

they maintain them electronically and as necessary have paper backup at students’ schools.
APS Special Education Survey
As mentioned earlier in this report, APS and ATF commissioned an independent entity,
Research and Polling, Inc., to survey teachers and staff across the district to get their feedback on
the special education work environment. Of interest was its culture, communications,
management, and job satisfaction. Some 402 staff members responded to the survey. In addition,
78 percent of special educators responded. Many survey results and comments provided at the end
of the document reinforced themes contained in this report. Overall, the vast majority (85 percent)
of special education teachers and staff believed they had a meaningful job at APS and 74 percent
were satisfied with the type of work they do in their current positions. However, only 42 percent
would recommend APS as a good place to work. In addition –
• Communication. 30 percent agree (43 percent disagree) that communications about mandates
and priorities within their department are clear and accurate.
• Timely Communication. 27 percent agree (49 percent disagree) that they receive timely
communications about decisions and/or changes that affect their work.
• Receipt of Information. 25 percent agree (46 percent disagree) that they receive the
information they need from the APS special education unit to do their work well.
• Collaboration. 22 percent agree (50 percent disagree) that there is good collaboration between
the administration and special education employees on best practices.
Although the survey was not designed to produce a regression analysis, Research &
Polling, Inc. was able to use some survey responses to determine the biggest predictors of special
education department employees’ overall job satisfaction and morale. The major predictors in both
areas were:
• Opportunity to participate in decisions affecting work;
• Good collaboration between the administration and special education employees on best
practices;
• Appropriate workload;
• High quality training in curricula and instructional progress; and
• Constant changes in policies/procedures making it difficult to perform job effectively.
School-based Special Education Support

Principals have an important oversight role in special education. Other personnel represent
the district at IEP meetings also have critical roles in maintaining the integrity of the special
education process. In APS, this role is carried out by special education principal support
administrators, special education assistant principal support administrators, IEP specialists, and
head teachers. Only head teachers are employed at the school level.
Principal Leadership
Focus group participants expressed concern that a high proportion of principals do not have
adequate knowledge about their oversight roles in special education. Some are viewed as

preferring not to have students with some types of disabilities at their schools. There were also
concerns that some principals do not consistently view students with disabilities in specialized
programs as being an integral part of their schools. These perspectives negatively impact personnel
collaboration. And they affect personnel and instructional expectations for students with
disabilities and the ability to foster an inclusive and welcoming school environment for every
student and their families.
Head Teachers
Head teachers are special educators employed at elementary, middle and high schools.
Although, some head teachers at middle and high are fully released and have no teaching
caseloads, more typically they continue to have special education caseloads and receive an annual
stipend of $2,500. The compliance executive director supervises the head teacher liaison, which
underscores the compliance nature of their roles.
Focus group participants offered the following comments about the head teacher role and
the training they receive.
• Role. More responsibilities have been given to head teachers over time. They write IEPs,
facilitate/schedule IEP meetings, assign special educators to classes, act as a liaison between
special education administrators and teachers, etc.
• Release Time. It was not clear what criteria applies to releasing head teachers from some or
all of their teaching responsibilities. Reportedly, for two schools with similar demographics
one has a fully released head teacher and the other does not. In other schools there are varying
amounts of release time for head teachers.
• Training. Head teachers meet within their zones and grade levels for a full day every other
month. Training is required pursuant to APS’s negotiated agreement with ATF. These
meetings also include IEP specialists, which enables these personnel to receive the same
information and professional development on such topics as IEP development, hot topics, legal
compliance, etc.
• Collaboration with School Personnel. Discussions are taking place with principals to
encourage them to enable head teachers to have the time they need to talk with and collaborate
with teachers and staff.
Special Education-Related Staffing Ratios and Information

This subsection presents data on staff-to-student ratios in special education, i.e., special
educators, paraprofessionals, speech/language pathologists, psychologists, nurses, occupational
therapists (OTs), and physical therapists (PTs). APS ratios are compared to other urban school
districts on which we have data.86 (All districts did not report data in each area.) These data are
based on full time equivalent (FTE) staff members and not on the number of positions per se. Also,
the Council team presumes that FTE data included vacant positions.
86
Much of the data were provided by the school districts that responded to a survey conducted by the Urban Special
Education Leadership Collaborative; the Council team or members of the team collected the remaining data during
district reviews.

The data do not give precise comparisons, so results need to be used with caution. In
addition, district data are not consistently reported (e.g., some districts include contractual
personnel and others exclude them) and data are sometimes affected by varying placement types
used by school districts. The data may count all students with IEPs, including those placed in
charters, agencies, and nonpublic schools, while other districts do not count these students. Still,
these data are the best available and are useful as a rough guide to staffing ratios. Appendix A has
detailed data on each school district.
Overall School District Ranking
Exhibit 4c shows APS’s rankings compared to other responding districts in each of the
personnel areas. These figures must be viewed with caution and should not be used to make
personnel decisions.
Overall, in the areas of psychologists and social workers, 60 percent or more of the districts
had staffing ratios smaller than APS. The ratios for special educators, speech/language
pathologists, and physical therapists fell in the mid-range of districts. For education assistants and
occupational therapists, less than 39 percent of the districts had ratios smaller than APS’s.
• Special Educators. Of 76 responding districts, 35 districts (46 percent) had smaller student-
to-personnel ratios. In other words, the district had larger numbers of special educators than 35
other responding districts.
• Education Assistants. Of 76 responding districts, 27 (36 percent) had smaller student-to-
personnel ratios.
• Speech/Language Pathologists. Of 74 responding districts, 39 (53 percent) had smaller
student-to-personnel ratios.
• Psychologists/Educational Diagnosticians. Of 68 responding districts, 41 (60 percent) had
smaller student-to-personnel ratios. This data includes educational diagnosticians. Only two
other districts combine psychologists and educational diagnosticians: Houston Independent
School District and the Jackson County FL Public Schools. Separately, APS has only 16.4
school psychologists, with a ratio of 1,021 students to each psychologist. This ratio would rank
APS last, with the largest average student-to-staff ratio among the 68 district survey
respondents.
• Social Workers. Of 48 responding districts, 30 (63 percent) had smaller student-to-personnel
ratios.
• OTs. Of 72 responding districts, 28 (39 percent) had smaller student-to-personnel ratios.
• PTs. Of 72 responding districts, 30 (42 percent) had smaller student-to-personnel ratios.
APS did not provide data on school nurses so information for this personnel area is not
included in this analysis.

Exhibit 4c. APS Ranking and Number of District Survey Respondents

80
70
60
50
40
30
20
10
0
Special Psychol- Social
EAs SLPs OTs PTs
Educators ogists Workers
Total Districts 76 76 74 68 48 72 72
No. Districts with Smaller Student-to-
35 27 39 41 30 28 30
Personnel Ratios
Special Educators
The following are data on special education teacher ratios. This subsection also includes
information provided by the district and focus group participants.
Special Education Teacher Staffing Ratios
Exhibit 4d shows the district’s student-to-special education teacher ratios, compared to 76
other urban school districts. With 1,217 full-time-equivalent (FTE) special educators, APS has an
average of 13.8 students with IEPs (including those with speech/language impairments) for every
special educator. 87 This ratio is lower than the 14.2 teacher-student average among all districts on
which we have data and ranks APS as 36th among 76 reporting districts. In other words, APS has
somewhat more such staff than other districts but not by much. Note that the number of FTE special
educators includes those filled with substitute teachers.
Exhibit 4d. Average Number Students for Each Special Educator
Areas of Comparison Special Education Teachers
Number of APS Staff FTE 1,217
APS Student w/IEP-to-Staff Ratios 13.8:1
All District Average Ratios 14.2:1
Range of All District Ratios 7–37:1
APS Ranking Among Districts88 36th of 76 districts
Special Education Teacher Shortages

According to focus group participants, APS has more than 100 vacant special educator
positions that are being filled by long-term substitutes. One school alone had four special education
and education assistant (EA) vacancies. This issue disproportionately affects students educated in
specialized program classes, and it is aggravated by intra-district personnel transfers occurring
during the school year. Some of this also appears to be affected by an inadequate position
87
Although special educators for the most part do not instruct students with a speech/language impairment only,
since speech/language pathologists are the primary providers, these students were included as students with IEPs
among all surveyed districts.
88
Ranking begins with districts having a low average number of students per staff person.

management system. There were concerns that the district does not have a comprehensive strategy
to address these and other special education-related vacancy problems and no adequate approach
to improve retention.
Additional focus group feedback included the following major themes –

• Special Education Alternative Licensure Program. Many special educators are not fully
certified and are teaching under an alternative license while completing their educational
requirements. Resource teachers support some 130 to 200 alternatively licensed special
educators in their first and second year of teaching. These teachers lack the requisite knowledge
and experience but tend to have caseloads with students having the most challenging behavior.
• Personnel Mobility. As with other APS personnel, special educators and ancillary staff can
transfer to other APS schools for preferred positions during the school year. The
unpredictability of these movements, which also disproportionately affects specialized classes,
is disruptive to student learning. Personnel also leave APS for other school districts because of
relatively low salaries and no increases in the first five years of employment.
• Retention. The number of special educators (as well as EAs) that turnover regularly is
disconcerting. There does not appear to be any systemic strategy for improving retention rates.
For example, some 600 general educators were special education certified but apparently not
used for special education purposes.
• Human Resources Support. APS’s prior system of prescreening applicants is no longer in
effect. As a result, school principals interview nonqualified applicants according to
interviewees. Furthermore, funds are unavailable for districtwide recruitment efforts.
• Remedial Measure. In addition to an alternative licensure program, APS is attempting to
address special educator shortages with a new compensation schedule in schools with vacant
positions to help manage IEP development and meetings for non-caseload students. Although
this process addresses some compliance issues, it does not improve critical classroom teaching
and learning activities necessary to support student achievement and wellbeing. Also, EAs are
relied upon extensively to support specialized reading programs and technology.
• University Partners. To address concerns that the pipeline for teachers is too small, APS is
partnering with several universities and community colleges to establish various programs.
• New Teacher Support. APS does not have a centralized program for onboarding new teachers.
This void especially affects new special educators from the Philippines who have been
assigned to schools and are teaching without any onboarding support. Although APS had a
mentoring program for new special educators on the books, the program had not yet begun as
of mid-September 2018.
• Signing Bonus. APS was considering initiating a signing bonus for shortage area personnel.
The district was discussing options with union representatives.
Education Assistants
The following is information about EA ratios. The subsection also contains feedback from
focus group participants.

EA Staffing Ratios
Exhibit 4e shows the district’s student-to-EA ratios, compared to 75 other urban school
districts. With 1,290 FTE EA positions, APS had an average of 12.98 students with IEPs for every
EA. This ratio was lower than the 15.2 EA-student average among all districts on which we have
data and ranks APS as 28 out of 76 reporting districts. In other words, APS has more such staff
than other districts. Currently, 64 EA positions are vacant.
Exhibit 4e. Average Number Students for Each Paraeducator
Number of EA FTE 1,290
APS IEPs-to-Staff Ratios 12.98:1
All District Average Ratios 15.2:1
Range of All District Ratios 4.3–56:1
89 th
APS Ranking Among Districts 28 of 76 districts
Focus group participants provided the following feedback on the EAs. Overall, there was
a sense that special educators were generally supportive of EAs.
• EA Residency Program. APS was funding career pathways for EAs, although all EAs with
whom the Council team met were not aware of the program.
• Low Pay Scale. The low starting salary of $11 per hour makes it difficult to fill EA positions.
• Working Conditions. EAs reported the following issues that affected their ability to support
- Training. There was a need for more training for school personnel on the role of EAs and
how best to support them; and a need to clarify EA job parameters on activities normally
conducted by special educators.
- Access to Documents. EAs do not consistently receive students’ FBAs/BIPs or IEPs.
The Council team noted that the survey conducted by APS and ATF did not solicit
responses from EAs. This personnel group, which has a larger number of employees than special
educators, plays an important role in the education of students with disabilities.
Related Services Personnel
Related-services personnel ratios are summarized below and shown in Exhibit 4f.
• Psychologists/Educational Diagnosticians (ED). With 97.6 FTE psychologists and EDs, there
was one for every 171.5 students with IEPs, compared with the all-district average of 67.1
students. APS ranked 42 of 68 reporting districts in its number of personnel in this area. As
indicated above, only two other districts employed EDs and count this personnel area along
with psychologists.
• Speech/Language Pathologist (SLP). With 161.5 FTE speech/language pathologists (SLPs),
there was one SLP in APS for every 103.6 students with IEPs, compared with the all-district
89
Ranking begins with districts having a low average number of students to one staff person.

average of 119.2:1 students. APS ranked 40 of 74 districts reporting SLP data. APS’s data
includes some SLPs completing their clinical fellowships.
• Social Workers. With 98.5 FTE social workers, there was one social worker in APS for every
169.9 students with IEPs, compared with the all-district average of 247:1 student. APS ranked
18 of 47 districts reporting social worker data.
• OTs. With 65.3 FTE occupational therapists (OTs), there was one OT in APS for every 256
students with IEPs, compared with the all-district average of 361:1 student. APS ranked 29 of
72 districts reporting OT data.
• PTs. With 22.7 FTE physical therapists (PTs), there was one PT in APS for every 737 students
with IEPs, compared with the all-district average of 968 students. APS ranked 31 of 72 districts
reporting PT data.
Exhibit 4f. Average Number Students for Each Related Service Area
Related-Services Areas Psychologists SLPs Social Worker OT PT
Number of APS Staff FTE 97.6 161.5 98.5 65.3 22.7

APS Students w/IEPs-to- 169.9:1 256:1 737:1
171.5:1 103.6:1
Staff
All District Average Ratio 167.1:1 119.2:1 247:1 361:1 968:1
Range of All District 26-705:1 64-1685:1 128-2941:1
26–1,021:1 31–396:1
Ratios
APS Ranking 42nd of 68 40th of 74 18th of 47 29th of 72 31wt of 72
Focus group participants provided the following comments on the work of

psychologists/educational diagnosticians, speech/language pathologists, social workers. and
nurses.
Psychologists and Educational Diagnosticians
As discussed above, APS employed only 16.4 FTE school psychologists. Without
including educational diagnosticians (EDs), APS’s ratio of 1,021 students to 1 psychologist would
put APS last of all school districts, with the next highest district ratio of 396 students per
psychologist. Because of their attrition and small numbers, the psychologist role in APS is limited
to evaluations, which are conducted to support a determination of emotional disturbance, other
health impairment for attention deficit hyperactivity disorder (ADHD), autism (if discriminating
from ED), and developmental disability.
The relatively few school psychologists in APS are supplemented with 81.2 educational
diagnosticians. Only two states (Louisiana and Texas) employ educational diagnosticians. This
circumstance narrows New Mexico’s school psychologist pipeline and makes it more difficult for
APS to recruit personnel in this area.
APS uses centralized diagnostic centers to complete special education evaluations as a way
of maximizing its assessment capacity. As a result, school psychologists were removed from the
school setting and were not involved in any processes related to FBAs/BIPs, SATs, intervention
support, or health/wellness issues.
Speech/Language Pathologists

As discussed above, students diagnosed with a primary speech/language impairment are

educated outside general education classrooms at disproportionately high rates compared to the
state and nation. As shown in Exhibits 3n and 3o, 40 percent of APS students are educated in
general education less than 80 percent of the time, compared to 18 percent of New Mexico students
and 9 percent of students in the nation. Although focus group participants did not address this
issue, they did express concerns about the following:
• Collaboration. Speech/language pathologists no longer have monthly meetings to discuss
various service issues; they have been cancelled because this purpose is not included in service
logs according to interviewees.
• Caseloads. Some speech/language pathologist caseloads were reported to be as high as 90
students.
• Telepractice. Reportedly, APS is relying on telepractice (where students interact with
therapists via video conferencing) to provide students’ IEP-required services. According to the
American Speech-Language-Hearing Association (ASHA), the effectiveness of telepractice as
a service delivery model in schools is well documented and schools are currently the most
common setting where telepractice services are delivered. 90 This circumstance is due to a
number of factors, including shortages of clinicians in some school districts, distances between
schools in rural areas, and opportunities to offer greater specialization within a district.
However, ASHA warns that telepractice may not be appropriate in all circumstances or for all
clients, and an assessment of this practice should consider culture, education level, age, and
other characteristics. Furthermore, the provision of therapy in school setting requires
considerations of whether it makes sense to:
- Provide students the opportunity to receive traditional in-person services; and
- Provide on-site support for the telepractice sessions, including the assignment of an
individual to accompany the student to the session and provide support during the session.
Social Workers
Focus group participants commented on their role and support for students. Issues included
the following major themes.
• Limitation of Services. Much of the discussion focused on ways in which services of social
workers were limited.
- Numerous School Assignments. Social workers have few opportunities to collaborate with
other personnel in their schools according to interviewees. With social workers assigned
as many as five schools, there is little time for them to work together. Social workers are
often not available for emergencies, IEP meetings, and they have limited time to follow up
with students. Also, social workers have limited time to develop relationships with
principals, especially those who are new. With the small number of school-based
psychologists and so few board-certified behavior analysts (BCBAs), human capital to
address the needs of students with serious behavioral issues is limited.
- Support for Students Without Disabilities. A past PED audit showed that social workers
90
Telepractice, retrieved from
https://www.asha.org/PRPSpecificTopic.aspx?folderid=8589934956&section=Key_Issues.

funded through special education categorical funds were providing services to nondisabled
students. As a result, they were prohibited from participating in health/wellness meetings
unless the discussion was about a caseload student, or the discussion was about students in
the SAT process who were being considered for a special education evaluation referral. As
a result, social workers were working only—when the Council team visited--with students
having IEP required services. APS is considering how to supplement social work funding
with operational funds so that social workers could resume their supports for students
without disabilities.
- Logging Services. Interviewees reported that in the past, approximately a year ago, PED
required APS ancillary staff to log their daily functions in 15-minute increments, using a
state required template. District personnel report this process to be time consuming,
inefficient, tedious, and replete with technical glitches that required data to be reentered.
Furthermore, the log provided no capacity for recording such practices as driving between
schools, informal talking with teachers, etc. Some activities stopped merely because they
could not be logged. In addition, the system used to document Medicaid services and time
was not deemed sufficient to allow PED to gather the required information for these
services. Focus group participants reported that the stress related to the logs has been
tremendous. Because of issues with the state’s software, the activity was suspended but
there were concerns expressed to the Council team that the requirement could be reinstated.
Special Education leadership clarified that they never required 15-minute interval logs and
this practice is no longer in place.
• Specialized Programs. With one exception, specialized programs were not considered
routinely when calculating social worker caseloads, even though some students may require a
significant amount of support. The newly developed PACES program has a subsidy for social
workers supporting students with the most intensive behavioral needs, and social workers must
interview for these positions to demonstrate their expertise.
Nurses
Although APS did not provide the Council team with employment data on school nurses,
focus group participants reported that there were 127 FTE nurses, after five positions were cut last
school year. Based on this figure, APS had a ratio of 132 students per nurse. This ratio ranks APS
37 of 61 districts. Two years ago, 24 nurses reported to two schools, and this year 48 nurses are in
this situation. It was reported to the team that families with medical issues moved to the city,
causing the school district to have a higher number of students with medical issues than might
otherwise be expected.
APS and ATF Support for Special Education

The relationship between APS and the Albuquerque Teachers Federation (ATF) has been
inconsistent. Reportedly, a strong collaboration and problem-solving relationship has existed
between union leadership and curriculum/instruction administrators, which has allowed respectful
discussions and eventual agreements. Unfortunately, the same sense of collaboration does not exist
between ATF and APS’s special education department. This has been true both before and during
the tenure of the current special education associate superintendent. Each side has strong positions
and finding common ground has been difficult. Still, there is a desire to improve collaboration.
This section briefly describes some of the major issues presented to the Council team.

• Negotiation Discussions. To improve relations on special education matters between APS and
ATF, the lead district principal support administrator for special education has represented the
department in a series of negotiation sessions. Although this has yielded fruitful discussions,
the administrator does not have decision-making authority for the special education associate
superintendent or the special education leadership team. When there is a disagreement on
special education terms, the negotiating team must hold discussions with less confidence of
success and negative attitudes are reinforced.
• Vote of “No Confidence,” Survey and Professional Facilitator. During the Spring of 2018,
ATF’s concerns about the special education department’s communications surfaced over
issues that included but were not limited to FBA/BIP. Generally, the department was viewed
by ATF as having processes and directives that were overly legalistic and without clear
educational benefit. After a preliminary ATF council vote of “no confidence” and direct
discussions between the superintendent and the ATF president, the parties agreed to jointly
engage in the following activities.
- Survey. Commission a survey of special educator and related services personnel
concerning special education culture; communications; management and job satisfaction.
- Facilitator. Hire an external impartial professional facilitator to work with stakeholders to
address survey results and Council team recommendations. A document showing survey
results was dated July 2018.
• Prohibited Practices Complaint. As the above concerns were being addressed, on May 9,
2018, the ATF filed a prohibited-practices class complaint with APS that concerned
reimbursements for various assessment personnel. The complaint concerned information
provided verbally by an APS senior administrator to assessment personnel about summer
compensation rates that exceeded negotiated rates. The information spread from person-to-
person by word of mouth and led to a myriad of accusations without the benefit of all the
underlying facts. The situation was like a prior incident involving a special education
administrator’s informal communication about a shortened work year.
- Prohibited Practices Settlement. APS/ATF settled the complaint by agreeing to a written
directive and an August 2018 compliance guide, which was intended to help APS
employers/employees understand the rules guiding the collective bargaining relationship.
- Multidisciplinary Committee. During the fall of 2018, APS and ATF agreed to form a joint
multidisciplinary committee with general education, special educations and English learner
staff—and an impartial facilitator--to follow up on survey results. The goal was to begin
an APS/ATF dialogue about the issues and how the parties could build trust and move
forward.
• Financial Incentives/Payments for Special Education Personnel. Interviewees reported that
the ATF has disagreed with district proposals to incentivize special educators to apply for
vacant positions through the use of signing bonuses, which several neighboring districts have
done. The teacher organization also disagreed with APS about the use of incentives for special
educators to work on IEP development. Reportedly, the ATF would agree if all teachers
received the same treatment.

Compliance Activities
The absence of written information on the myriad of special education state and federal
requirements and procedures along with APS’s operating guidance contribute to noncompliance
and inconsistent practices. Factors that support compliance include access to reliable data; an
effective IEP system; high quality training; adequate staffing; and clear and consistent written
procedures.
Written Procedures
APS does not have written standard operating procedures for special education or Section
504. Typically, such standard operating procedure manuals would gather all relevant information
into one location for easy and uniform reference. This void promotes confusion among all
stakeholders. Based on the results of the jointly commissioned APS/ATF special education survey,
only 20 percentage of respondents agree (56 percent disagree) that new policies and procedures
are clearly documented and easy to understand. Although there were various guidance documents
on the district’s Intranet, these were neither transparent to all stakeholders nor user-friendly. While
some focus-group participants were concerned that more transparent procedures would lead to
increased litigation, the Council team strongly believes that clear and comprehensive procedures
that are widely available and comport with the law are necessary to build universal understanding
of special education processes, expectations, and accountability.
The APS and ATF commissioned survey produced several statements that reinforced the
need for better communication with stakeholders, including--
• Communications, accessibility, and distribution of policies and procedures/forms were not
uniform or current. This includes the Administrative Bulletins.
• There were no directives in writing and therefore teachers did not have any place to look up
information related to a specific procedure to know how to do it.
• Information either did not exist or was found in multiple places, such as the Special Ed Intranet,
Blackboard, Language and Cultural Equity, Transportation, Review 360, APS.EDU, Versafit
(Edvantage – Synergy), P Drive, Tienet.
• When teachers were asked to fill out a Language Usage Data (LUD) form for reevaluations,
the information and the form could not be found.
• All required forms need to be updated and made accessible. This was especially true for the
Language Usage Data (LUD) form, which was not easily accessible. Once found, the
information teachers needed to complete the form was not easily accessible.
• All information should be accessible on ONE Website outside of the firewall. Links to all
Special Ed related sites should be consolidated and listed in one place for easy reference.
Essential tools and reference sites need to be accessible from both inside and outside the APS
firewall.
Electronic IEP System

Focus group participants expressed numerous concerns about the electronic IEP system
used by APS. Concerns included lost student data when multiple personnel were entering

information on the same student; insufficient availability of auto-filling and migration of available
data; inclusion of forms that were redundant or out-of-date; necessary forms not available in the
system; etc. It appears there were minimal standards for district and school-based reports,
including those requiring data from multiple sources. This was apparent in APS’s response to the
Council team’s request for data reports in common use across the district. Furthermore, reporting
appeared to be complicated by fragmented data systems.
IDEA Annual Compliance Determination
As required by the U.S. Department of Education, each year PDE issues an IDEA
compliance determination to each state’s school districts based on standard federal and state
performance plan indicators. APS received its latest determination on October 13, 2018, which
specified a fourth year of “needs intervention.”
It is important to note that in 2018, APS had numerous SPP compliant indicators: no audit
findings; disproportionate suspensions/expulsion (4b); disproportionate representation (9 and 10);
60-day initial evaluations; infant/toddler transition (12); and secondary transition (13).
The special education department’s use of special education liaisons to support school-
based activities, however, has been reported as improving the district’s practices. By liaising with
some 29 schools each, these personnel are responsible for monitoring due dates, provide training,
visit schools, and give feedback.
The bases of APS’s 2017 and 2018 noncompliance determinations are listed below in Exhibit 4g.
Exhibit 4g. 2017 and 2018 Noncompliant IDEA State Performance Plan Indicators
Indicator Number & Type 2017 2018
11. 60-day Initial Evaluation Compliant 99.9%
13. Transition IEPs not submitted by local charter schools
98% Compliant
(missed since 2009-10 school year)
Untimely data due to not meeting 80th day timeline X X
Unreliable data due to incoming charters X X
Continued noncompliance for untimely data X X
APS representatives offered the following explanations for the 2018 findings of
noncompliance.
• 60-Day Initial Evaluation. One charter school with four or five noncompliant evaluations
accounted for the 99.9 percent 60-day initial-evaluation rate. (The federal compliance standard
is 100 percent.)
• 80th Day Timeline. It was difficult for the special education department to meet the 80th day
reporting requirement set by the PED’s special education bureau (SEB), because the date last
year fell a day or so after winter break. According to APS, this timeline did not provide the
district the time personnel needed to resolve student residences reported by APS and other
districts. The reporting deadline imposed by New Mexico’s Student Teacher Accountability
Reporting System (STARS) fell a few weeks after winter break. APS was able to complete its

data submission by the STARS deadline but not by the SEB deadline. Reportedly, APS efforts
to resolve this issue with SEB were unsuccessful.
Focus group participants expressed concerns about the PED priority to complete
reevaluations because of the corrective action it was requiring. Given the district’s personnel
shortages, this priority was negatively affecting other required activities, such as completion of
initial evaluations that were determined in part by the timing of SATs and the March/April referral
surge. Also, there was a concern that prior written notice forms were not consistently completed.
Due Process Hearings

Exhibits 4h and 4i provide information on the due process hearings requested by parents
in 2016-17 and 2017-18. As shown in Exhibit 4h, APS received 12 requests for due process
hearings in 2016-17 and 8 in 2017-18. Of the 12 requested in 2016-17, 10 were settled and 2
resulted in a hearing with mixed results for parents and APS. Four of the 12 filings produced
compensatory education for students. In 2017-18, fewer hearings were requested and none of the
eight resulted in a hearing. Four of the requests produced compensatory education action, and two
did not address this issue. At the time of the Council-team’s visit in late September 2018, there
was only one due process hearing request, which was resolved. For a district the size of APS, the
number of hearing requests (especially based on last year’s data) appeared to be reasonable.
Fees for APS Attorneys

The amount of funds spent for APS attorneys is disproportionately high compared to fees
APS has paid in parent attorney fees. In 2016-17, APS attorney fees were $260,582 while plaintiff
attorney fees of $134,768 were nearly half of that for APS’s attorneys. The amount paid in 2017-
18 ($79,978 for APS attorneys and $43,068 for plaintiff attorneys) was substantially smaller than
the previous year. Most notable was that in 2016-17 four cases resulted in APS attorney fees that
were more than twice as high as for plaintiff fees, and one of them was more than four times as
high. Last school year, APS fees were three and four times higher in two cases, twice as high in
one case, and another case resulted in fees of more than $6,000 for APS’s attorney.
Exhibit 4h. Due Process Hearing Data
Compensatory APS Attorney Plaintiff Attorney
Total Filed Settled DP Hearing
Education Fees Fees
2: mixed
2016-17 12 10 rulings for 4 $260,582 $134,768
parents/APS
4 (2 not yet
2017-18 8 8 N/A $79,978 $43,068
determined)
Exhibit 4i shows due process hearings requested in 2016-17 and 2017-18 and the number
of filings that alleged one or more of the following issues: failure to identify a student for special
education while the student was being educated in general education (failure to identify from
general education); failure to identify a student for an additional disability (failure to identify from
special education); and denial of a free appropriate public education (FAPE). In both school years,
more hearing requests alleged a failure to identify (counting both general and special education)
than a denial of FAPE.

• 2016-17. Of the 12 hearing requests, 8 concerned a failure to identify (2 from general education
and 6 from special education) and 7 concerned a denial of FAPE.
• 2017-18. Of the 8 hearing requests, 5 concerned a failure to identify (2 from general education
and 3 from special education) and 4 concerned a denial of FAPE.
Exhibit 4i. Due Process Hearing Request Issues
Failure to Identify Failure to Identify
FAPE
from General Ed from Special Ed
2016-17 2 6 7
2017-18 2 3 4
According to APS representatives, 18 due process hearings were requested during the year
prior to the current special education assistant superintendent’s tenure. The then-new department
leadership put together a multidisciplinary team to interview staff about issues that contributed to
the hearings and developed a strategic plan to reduce the number of requests. Also, training was
provided to increase knowledge about the issues.
Typically, urban school districts either have in-house counsel or one attorney that
represents the district in special education matters. Also, it is common for special education
administrative personnel to handle and resolve due process issues in cases when parents are not
represented by attorneys and they need assistance with routine settlement issues. At the time of the
Council team’s visit, the district used two different firms for special education issues. One of these
firms managed most cases and legal support. Focus group participants strongly perceived that
narrow and restrictive legal interpretations have unnecessarily driven educational practices and fed
a negative culture with practitioners and administrators.
Complaints Filed with PED
Based on documents provided by the district, PED issued corrective action statements in
five cases during the 2017-18 school year. Three of them involved findings related to child find,
and two related to IEP processes. One of the IEP-related cases involved transportation and the
other involved the provision of IEP-required social work services.
• IEP Meeting at Parent Request. One corrective action required convening an IEP meeting at
the parent’s request and involved transportation to an after-school community center program.
• IEP Process and Social Work Services. One corrective action required training for APS and
charter school personnel on IEP meeting processes, and the provision of IEP-required social
work services. In three cases, the corrective action involved the district’s procedures on the
identification of students for special education.
• Child Find. Three cases involved child find. Each addressed one of the following issues:
obtaining parental consent to education and beginning the evaluation within a reasonable time;
the right of parents to request an evaluation at any time, including while the student was
involved in the RtI process; and the SAT process and its relationship to the child-find process.
All cases required training for APS personnel, two required the provision of compensatory
education to students, and two required IEP teams to consider use of compensatory education.

Order of Manifestation Determination and Impartial Discipline Hearings

An APS flow chart showing the process for handling long-term disciplinary removals of
students from school calls for an impartial hearing to be held prior to a manifestation determination
meeting. This order of procedures is contrary to the Council team’s understanding of national
practice, which is to hold the manifestation determination meeting first. This would allow one to
ascertain whether a student’s alleged behavior constitutes a manifestation of the disability. At that
point, a better-informed decision can be made on the need to go forward with an impartial
disciplinary hearing. In such cases, unnecessary hearings that might have a negative effect on
student and family could be avoided. 91
Transportation
According to APS representatives, 50 percent of the transportation budget involves
students with disabilities. Currently, contractors will not support the transportation of these
students. As a result, the district operates 250 of 500 buses in use for APS students. To better
manage transportation routing and to support school placements closest to students’ homes, the
district has developed a protocol to help IEP teams improve transportation-related decisions. Also,
transportation representatives are involved in handling routing complications.
Focus group participants raised the following concerns about transportation services.
• Educational Assistants. There was a perception that IEP-required educational assistants were
not provided on buses because of inadequate funding.
• Delays. There were delays in setting up transportation for some students, especially in the
beginning of the school year.
• Electronic Support. The IEP system did not link to the transportation system. Double entry
errors slow down the process.
• Schedules. When students were dropped off early or picked up late, school personnel were not
always available for students.
Medicaid Reimbursement
APS monitors services with personnel providing Medicaid eligible services to students.
Also, the district supports families who enroll in Medicaid through various events held during the
year and with information provided by APS personnel.
• Medicaid Documentation. While social workers and other personnel must document Medicaid
services on the MaxCapture software, which is more difficult to use than the district’s Synergy
system, nurses document services on the easier Synergy system. This system, however, does
not have fields to track services other than nursing as the MaxCapture software is the tool
intended to be the primary software utilized for documenting hours of service and billing of
Medicaid.
• Service Tracking. Only one APS charter school documents Medicaid services. The school
91
Note: for behaviors related to special circumstances (use of a weapon, drugs, or infliction of serious bodily
injury), the impartial disciplinary hearing would proceed regardless of any manifestation determination.

hired its own vender to bill and collect reimbursement. The school did not return the revenue
to APS after the district’s initial funding of the services. District representatives believe that
charter school Medicaid reimbursements, even if more schools participated, would not be
worth the effort.
Accountability
In the fall of 2011, the Council of the Great City Schools published a report Pieces of the
Puzzle: Factors in the Improvement of Urban School Districts on the National Assessment of
Educational Progress. 92 The report summarized research the Council conducted with the
American Institutes for Research (AIR) on characteristics of urban school districts that made the
greatest academic improvements and had the highest overall performance on the National
Assessment of Educational Progress (NAEP). The first characteristic involved a district’s clear
statement of goals and districtwide accountability for results. These factors helped create a culture
of shared responsibility for student achievement.
Other research has found similar results and clarified barriers to effective teaching and
learning.93 School districts that effectively support school leadership often demonstrate the ability
to facilitate learning, address barriers, and govern and manage the district in ways that prioritize
good instruction. In pursuing these goals, districts showing improvement have mechanisms for
systemic planning, program implementation, evaluation, and accountability.
Accountability in APS
The district’s accountability and reporting office is responsible for assessment, strategic
analysis and program research, student information systems, and school accountability support.
• The strategic analysis and program research (SAPR) department is responsible for strategic
data analysis and program evaluation. The department’s website includes user-friendly
visualizations of districtwide and school-level data on relevant demographics and
achievement.
• The student accountability support department uses the Harvard University-developed Data
Wise school improvement process to help schools use data-based actions to improve teaching
and learning and coordinate guidance on the implementation of PED’s 90-day plan. Focus
group participants expressed concern that schools do not consistently address the needs of
students with disabilities in their 90-day plans.
In addition, the district’s Academic Master Plan has three goals, which include early
learning; college and career readiness; and developing the whole child. A performance framework
includes metrics for measuring school/district successes and providing support when and where
needed. Metrics are collected in four categories: school culture/climate; student
growth/achievement; student engagement; and parent/community involvement. Sixteen indicators
92
Available at
http://www.cgcs.org/cms/lib/DC00001581/Centricity/Domain/4/Pieces%20of%20the%20Puzzle_FullReport.pdf
93
Toward a School District Infrastructure that More Effectively Addresses Barriers to Learning and Teaching, A
Center Policy & Practice Brief, Center for Mental Health in Schools at UCLA. November 2011, at
http://smhp.psych.ucla.edu/pdfdocs/briefs/toward%20a%20school%20district%20infrastructure.pdf.

measure progress within these categories. The website does not provide information showing how
data on these indicators are disaggregated by student group, e.g., disability. 94
AREAS OF STRENGTH
The following are APS areas of strength related to teaching/learning supports for students
with disabilities.
• Scheduled Interaction. Various regularly scheduled meetings occur at the APS senior
leadership and principal levels to discuss pressing issues and engage in planning. The special
education associate superintendent is actively engaged and involved in the superintendent’s
cabinet.
• Special Education and English Learners. There is a strong working relationship between
special education and multilingual personnel to identify and support ELs with disabilities.
• APS/Charter School Collaboration. Charter school personnel expressed appreciation for the
support they received from charter school and special education administrators for students
with disabilities.
• Special Education Department Organization. There are eight special education principal
support administrators. One was assigned to support elementary schools and one was assigned
to support middle/high schools in each zone.
• Head Teacher/IEP Specialist Training. Pursuant to APS’s negotiated agreement with the
ATF, head teachers meet with their learning zone and grade level for a full day every other
month. These meetings also include IEP specialists, which enables these personnel to receive
the same information and professional development as other staff.
• Remedial Measure for Special Educator Shortages. The district has an alternative licensure
program to alleviate personnel shortages and is initiating a new compensation schedule for
special educators in schools with vacant positions to better manage IEP development and
meetings on non-caseload students.
• University Partners. Amid concerns about a narrow pipeline of prospective teachers, APS is
partnering with several universities and community colleges to establish effective programs.
• Education Assistants. Overall, reports indicated that special educators are generally supportive
of their EAs.
• Social Work Support. The newly developed PACES program has a subsidy for social workers
supporting students with the most intensive behavioral needs. Social workers must interview
for these positions to demonstrate their expertise.
• APS/ATF Collaboration. A jointly commissioned survey of special educator and related
services personnel produced a wealth of information about special education culture,
communications, management, and job satisfaction. The APS/ATF also agreed to form a
multidisciplinary committee with assistance from an external facilitator and work with
stakeholders to address survey results and Council-team recommendations. The goal is to begin
a dialogue about issues that have been/will be raised and how the parties can work together to
94
http://www.aps.edu/academics/academic-master-plan/a-clear-vision-emerges

build trust and move forward.

• Due Process Hearing Requests. APS’s number of due process hearing requests has decreased
from 12 in 2016-17 to 8 in 2017-18. Also, the amount of APS/plaintiff attorney fees was more
than three times smaller in 2017-18 ($123,046) than in 2016-17 ($395,350).
• Transportation. To better manage transportation routing and support school placements
closest to students’ homes, a protocol was developed to help IEP team members improve
transportation-related decisions. Also, transportation staff are involved to consider routing
complications.
• Medicaid. APS monitors service by personnel providing Medicaid-eligible services to
students. Also, the district supports families in enrolling in Medicaid through various events
held during the year and information provided by APS personnel.
• Accountability. The strategic analysis and program research (SAPR) department oversees data
analysis and program evaluation. The department’s website includes user-friendly
visualizations of data on relevant districtwide and school-level demographics and
achievement.

The following areas provide opportunities for APS to improve its support for teaching and
learning for students with disabilities.
Interdepartmental Collaboration
General education, special education, and operational departments at the central office,
zone, and school levels do not consistently collaborate to leverage human, material, and fiscal
resources necessary to support and improve teaching/learning for students with disabilities.
• Principal Zone Meetings. Although special education principal support administrators 95
attend principal meetings held at the zone level, interviewees reported that the associate
superintendent has not attended in the past. Furthermore, the leaders of APS’s two centers that
operate as schools for students with disabilities have not attended nor been invited to these
meetings, although reportedly their future attendance is being planned.
• Instructional Rounds. Neither special education principal support nor program support
administrators consistently attend instructional rounds. Furthermore, instructional rounds do
not occur at the two special education centers.
• Zone Level Collaboration. Associate superintendents and general/special education principal
support administrators do not routinely meet to discuss and address patterns of need within
each zone. Special education principal administrators have relationships with their respective
associate superintendents that range from good to non-existent. Reportedly, there is also not
strong collaboration between general and special education principal support administrators
unless it is around issues of compliance. This circumstance is associated with staff concerns
about instructional issues that are seen only as relating to general education or special
95
Special education principal support administrators are assigned at the zone level, based on their experience in
elementary or secondary levels.

education, each requiring a different set of personnel.

• Special Education and Equity, Instruction and Support Departments Collaboration.
Although interdepartmental collaboration has improved, there is room for more structured and
intentional cross-departmental, cross-functional work, which includes:
- Scheduled Interaction. Regularly scheduled meetings/formal strategic planning sessions
for special education and curriculum/instruction administrative personnel; and
- Early Childhood. More collaboration between early childhood and special education
administrators to increase inclusive education for children in early childhood programs.
• Special Education and Human Resources. Special education and human resources units have
not routinely met to address personnel recruitment issues, nor have they established uniform
guidance for inter-school personnel transfers not governed by negotiated agreements, e.g.,
transfers requested by related service personnel.
• Data Coordination. It was difficult for APS to provide requested information to the Council
because it required the involvement of more than the special education department. Multiple
requests were made before the responses were appropriately coordinated and information was
provided.
Administration and Operation of Special Education
Focus group participants and the jointly commissioned APS/ATF special education survey
uncovered concerns about the special education department’s operations in terms of clear,
accurate, and timely communications and collaboration with school-based personnel. Multiple
stakeholders throughout the district reported that they do not receive information from the special
education department that was consistent and reliable.
• Special Education Department Organization Chart. APS’s website continues to post the
special education department’s 2016-17 organizational chart, although it has been updated
several times since. The new chart more clearly shows reporting lines than in the past, but there
continues to be multiple indirect reporting relations that affect clear communications, e.g.
related services personnel must navigate a supervisor, a liaison, an administrator for special
programs, and assistance principals. Also, the chart and other available information does not
clearly show who to contact (with emails) with concerns. (Exhibit 4a)
• Weekly Meetings. The associate superintendent has weekly meetings with her leadership team.
Half-day is spent on administrative issues and half day to review data, website, directives etc.
This appears to be an excessive amount of time for leadership to be away from day-to-day
requirements. Meetings do not take place when staff is participating in mediation or due
process hearing matters.
• Center School Administration. Administrators for APS’s two centers report to the lead
principal support administrator rather than to a zone associate superintendent.
• Lead Principal Support Administrator. This position has a very large span of control and
oversight responsibility for more than 50 personnel, including eight special education principal
support administrators.
• Principal Support Administrators. Although principal support administrators work well
together, they do not consistently attend instructional rounds with zone associate

superintendents. Also, administrators do not regularly interact with associate superintendents

to address common issues in each zone, to design systemic strategies, and plan professional
development.
• Program Support Personnel. Given the current allocation of program support personnel, staff
do not consistently have expertise in areas relevant to the specialized programs they are
expected to support. Program support personnel also do not routinely respond to calls for
assistance from teachers in cross-categorical programs, according to interviewees.
• IEP Specialists. Although the IEP specialists support elementary schools, these personnel are
supervised by one of school principal support administrators that supervise K-12; some cover
elementary and some secondary based on their experience. The intent was for IEP specialists
to support school personnel by having expertise in the SAT process (including interventions),
special education processes/rules, and relevant forms. With 25 IEP specialists (including one
vacant position) and an average of 3.6 elementary schools each, specialists should be able to
visit assigned schools slightly more than once each week. Although some perceive that the IEP
specialists are more objective than school-based personnel,96 there were concerns that these
personnel have uneven expertise and were not familiar with students because of the number of
schools they were assigned.
• Support Assistant Principals. Ten administrators each serve as an assistant principal in a
school having many students in specialized program classes. The administrators report directly
to the lead principal support administrator and not to their respective school principals.
• Board Certified Behavior Analysts (BCBAs). With only three BCBAs, the special education
department would like to hire two more so that one can be assigned to each zone.
• Budget/Data Director. To address concerns about the validity of special educator caseloads,
which drives state funding and contracts, the budget director independently confirms time
sheets with head teachers and principals who also sign time sheets to confirm the contents.
Special education personnel send updated caseloads directly to the director to facilitate
completion of four annual state reports. The director engages in this lengthy process to
compensate for concerns about the accuracy of school-based data entry. Instead, APS could
hold school personnel accountable for accurately providing these data.
• School-based Related Services Personnel. Some but not all related service areas have a liaison
to the special education department. There were concerns that changes in the supervision of
related-services personnel occur frequently, and that professional development for various staff
groups occurs less frequently than in prior years.
• Centralized Special Education Records. APS maintains special education records centrally,
requiring school personnel to copy and send them, and central office personnel to receive,
store, and retrieve them.
School-based Special Education Support
• Principal Leadership. There were concerns that all principals were not fully familiar with their
special education oversight roles and do not consistently view students with disabilities in
96
We note that this concern was not raised about the objectivity of head teachers who support middle/high schools.
More information about head teachers is provided below.

specialized programs as being an integral part of their schools.

• Head Teachers. Special educators employed at middle/high schools serve as head teachers and
receive an annual $2,500 stipend. The compliance executive director supervises the head
teacher liaison who supports head teachers. More responsibilities have been given to head
teachers over time, but there is little if any guidance for providing or funding release time for
them to perform their duties. Discussions are taking place with principals to encourage them
to enable head teachers to have additional time to collaborate with teachers and staff.
• Special Education Related Personnel Student to Staff Ratios. Based on staffing data collected
by the Council team on paraprofessionals and occupational therapists, fewer than 39 percent
of districts had smaller ratios than APS. For psychologists/educational diagnosticians, social
workers, and nurses, 60 percent or more of the responding districts had staffing ratios that were
smaller (more generous) than APS ratios. Special educators, speech/language pathologists, and
physical therapists in APS fell in the mid-range of all districts. (Exhibit 4b)
• School Psychologists. ASP had only 16.4 school psychologists--a ratio of 1,021 students to
each psychologist. Excluding the two other districts from the Council team’s data that employ
educational diagnosticians, ASP’s ratio of students to psychologists ranks ASP last, i.e., having
the largest ratio of 68 responding districts. With APS’s use of centralized diagnostic centers
for special education evaluations, psychologists are removed from school settings and are not
involved in processes such as those related to FBAs/BIPs, SATs, interventions, and
health/wellness issues.
• Speech/Language Pathologists (SLPs). APS students with a primary diagnosis of a
speech/language impairment are educated outside of general education classrooms more than
20 percent of the day at disproportionately high rates compared to state and national rates (40
percent, 18 percent, and 9 percent, respectively) (Exhibit 3n and 3o) This circumstance may
be due to very high SPL caseloads (i.e., as many as 90 students). 97 SLPs no longer have
monthly meetings to discuss service issues, because this purpose is not included in service
logs. Although the American Speech-Language-Hearing Association (ASHA) approves of
SLP telepractice, there were concerns that APS practices do not always meet ASHA’s
guidelines on students selected for this practice.98
• Nurses. Twice as many nurses now report to two schools than one, which was the case two
years ago. This raised concerns about the support of children with medical issues.
• Special Education Teacher Shortages. APS has more than 100 vacant special educator
positions that are being filled by long-term substitutes. One school alone had four special
education vacancies in addition to EA vacancies. This problem disproportionately affects
students educated in specialized program classes, and it is aggravated by intra-district
personnel transfers occurring throughout the school year. An inadequate position management
system also contributes to the problem. The following circumstances exacerbate the issues.
- Comprehensive Strategy. There was no comprehensive strategy or urgency to address
personnel shortages; improve retention of current personnel; or incentivize any of APS’s
97
By comparison, Illinois regulations cap SPL caseloads at 60 students.
98

600 general educators to teach using their special education certificates.

- Special Education Alternative Licensure Program. Large numbers of special educators
are not fully certified or are teaching under an alternative license while completing their
educational requirements. These teachers often lack the expertise to have caseloads with
students having the most challenging behavior.
- Personnel Mobility. Personnel transfers during the school year to other APS schools
disrupt teaching and disproportionately affect specialized classes; and personnel exit from
APS because of relatively low salaries and no increases for their first five years of
employment.
- Human Resources Support. There is little pre-screening of applicants by the human
resources department.
- New Teacher Support. There was no centralized onboarding supports for new teachers,
which particularly affects new special educators from the Philippines. APS’s mentoring
program for new special educators had not begun as of mid-September 2018.
APS and ATF are having discussions about various options to provide signing bonuses for
shortage area personnel.
• Education Assistants. The low starting salary for EAs makes it difficult to fill these positions.
School personnel need training on EA roles and responsibilities and how best to support them;
EA roles in activities normally conducted by special educators; and facilitating access to
students’ FBAs/BIPs and IEPs. Although APS was funding career pathways for EAs, all EAs
with whom the Council team met were not aware of the program. APS and ATF did not include
EAs in their special education survey.
• Logging Time. PED restrictions exclude related-service personnel logging time for meetings
or discussions about students not on their caseloads, driving time between schools, and
informal discussions with teachers. It was not certain whether PED will reinstate these logging
restrictions.
• Services for Students Off Caseloads. PED restricts the use of special education funds for
personnel supporting students with disabilities who are not on their caseloads. APS was
planning to prorate social work positions with non-special education funds so they could
support students without IEPs. There were no plans to prorate SLP positions.
APS and ATF Support for Special Education
For a variety of reasons, it has been difficult for APS and ATF to collectively address the
many special education issues of mutual concern.
• Negotiating Team. The APS negotiating team does not include the special education associate
superintendent. This process has resulted in special education leadership second guessing
tentatively agreed-upon terms reached by the special education associate superintendent’s
designee.
• Prohibited Practices. A special education administrator’s verbal communication about related
service providers resulted in a prohibited practices complaint from ATF, the sharing of
unreliable information among members, and a myriad of false accusations. The complaint was
settled after agreeing to provide relevant training to APS employees.

• Financial Incentives/Payments for Special Education Personnel. The AFT has disagreed
with district proposals to incentivize special educators’ applications to fill vacant positions by
using signing bonuses and stipends for special educators developing IEPs.
Compliance Activities
• Factors Leading to Noncompliant Practices. The absence of easy-to-access and user-friendly
information on the myriad of special education state/federal requirements and procedures along
with APS operating guidance contributes to noncompliance and inconsistent practices. Other
issues that affect compliance include reliable data; an effective IEP system; training; and staff
shortages.
• IDEA Annual Compliance Determination. On October 13, 2018, PED notified APS of the
district’s fourth year of “needs intervention” status. This status was based on several factors
that relied on untimely or unreliable data, and a 60-day initial evaluation rate of 99.9 percent,
which just missed the federal 100 percent compliance requirement. APS expressed concern to
PED that the agency’s date for providing 80th day data falls a day or so after winter break.
Because the district must resolve residency issues involving students who are reported by APS
and other districts, this time frame was difficult to meet.
• Due Process Hearing Requests. The amount of funds spent for APS attorneys on due process
cases is disproportionately high when compared to plaintiff attorney fees in both 2016-17 and
2017-18. (Exhibit 4e.) Generally, hearing request settlements are equally divided between
child find (failure to identify) issues and FAPE issues.
• APS Special Education Legal Representation. At the time of the Council team’s visit, the
district used two different firms to handle special education legal matters. One firm managed
most cases and legal support. Focus group participants strongly perceived that narrow and
restrictive legal interpretations have unnecessarily driven educational practices and fed a
negative culture with practitioners and administrators.
• Complaints filed with PED. PED issued corrective action requirements in five cases filed
during the 2017-18 school year. Three involved findings related to child find and two to IEP
processes (one involved transportation and the other involved the provision of IEP-required
social work services). The Council team notes that although the goal is to have zero complaints
filed with a state educational agency, the number of APS complaints does not appear to be
excessive for a district this size.
• Order of Manifestation Determination and Impartial Discipline Hearings. APS holds
impartial disciplinary hearings prior to determining whether a student’s alleged behavior is a
manifestation of his/her disability. This procedure requires a student with behavior
subsequently found to be a manifestation of his/her disability to unnecessarily sit through a
disciplinary hearing (unless the behavior related to the use of a weapon, drugs, or infliction of
serious bodily injury).
Transportation
Because independent contractors will not support the transportation of students with
disabilities, APS operates 250 of 500 buses in use. Concerns included funding availability for IEP-
required EAs on buses; delays in setting up transportation (particularly at the beginning of the

school year); no electronic linkage between the IEP and transportation systems; and the lack of
student supervision for early drop-offs and late pick-ups.
Medicaid
• Medicaid Documentation. While social workers and other personnel must document Medicaid
services on MaxCapture software, which is more difficult to use than the Synergy system,
nurses are able to document services on Synergy. This system, however, does not have fields
to track services other than nursing.
• Service Tracking. Only one APS charter school documents Medicaid services, and the school
retains its revenue. District representatives believe that the benefits of pursuing charter school
Medicaid reimbursements are not worth APS’s effort.
Accountability
• 90-Day Plans. There were concerns that schools’ 90-day plans do not consistently address the
needs of students with disabilities.
• Academic Master Plan. It is not clear how Academic Master Plan indicators report
disaggregated data on various student subgroups, e.g., disability.
RECOMMENDATIONS
The following recommendations are offered to improve APS’s teaching and learning
support of students with disabilities.
6. Parent Support & Engagement. Improve APS’s engagement with parents/families to expand
their involvement with schools and support for their children’s education.
• District Parent Advisory Council. Work with a broad range of parents from all zones and
community-based organizations to design an effective districtwide advisory council,
hosted by the special education associate superintendent. Collaborate with the group to
redesign zone-based parent advisory committee meetings. Have the council include diverse
representatives from each zone and reflect a variety of student/parent needs. Have the
council take up the way in which APS meets state requirements and reaches out to parents.
Consider the frequency and timing of zone meetings; the content of meeting; how parents
can provide input on meeting agendas; the best processes for handling parent questions;
the timing of zone meeting notices; communications with parents of English learners and
students with sensory disabilities; child care; refreshments; time of day, etc. Furthermore,
have the council review the professional development described in Recommendation 5d to
give feedback on topics of interest to parents.
• Parent Conferences. Consider having one or two districtwide parent conferences each
year.
• Presence of Associate Superintendent. At regular intervals, have the special education
associate superintendent attend the zone-based parent advisory committee meetings to
provide a visible presence and address parent concerns.
7. Interdepartmental Collaboration. Specifically charge senior staff in all central office
departments with collaborating with each other to support teaching and learning for students

with disabilities. Hold them accountable for that collaboration. In addition--

a. Collaborative/Inclusive Discussions and Deliverables. Ensure all central office, zone, and
school decision-making affecting teaching and learning includes special education/related
services personnel. Have department representatives from special education and the English
learner unit meet regularly to address responsibilities for English learners who have
disabilities. Charge staff with developing and implementing models of effective instruction
and supports for English learners with IEPs. (Coordinate with Recommendation 5b.)
Planned Interaction. Have the deputy superintendent establish a master schedule for all
departments involved in supporting instruction/behavior to meet regularly and facilitate
agendas and act on common concerns and issues, e.g., early childhood, curriculum,
instruction, supports, etc. Develop a template that would identify and guide administrators
on such issues as the discussion of curriculum materials. Plan for regular meetings between
the following department representatives:
• Early Childhood. General/special education administrators to discuss early childhood
curriculum, instructional practices, and expansion of inclusive educational models;
• Personnel Recruitment. Special education, English learners, and human resource
administrators to address personnel recruitment and retention issues (including bilingual
special education/related services personnel) and establish uniform guidance on inter-
school personnel transfers not governed by negotiated agreements, e.g., transfers requested
by related service personnel.
b. Zone Level Collaboration. Have the deputy superintendent meet with zone associate
superintendents, their respective staff members, and departmental personnel who liaise with
zone associate superintendents and their supervisors. Special education personnel would
include special education associate superintendent, special education school and program
support executive directors, 99 and special education principal support administrators. Have
them discuss better collaboration on regularly scheduled interactions and strategies to improve
teaching/learning for students with disabilities.
Zone Associate Superintendent Administrative Meetings. Have the special education
principal support administrators who regularly attend zone associate superintendent’s
meetings to acknowledge positive trends and leverage resources needed to address patterns
of concern. Prioritize--
— Reviewing school data on issues delineated in this report and other areas relevant to
teaching and learning for students with disabilities (as well as MTSS);
— Developing strategic actions with principals having common issues and individual
principals having unique issues. Use data to inform issues.
— Developing professional learning for cohort personnel based on Recommendation 5d
(as well as 2f and 3d).
— With a standard protocol, monitor the cohort schools based on Recommendation 5f
(as well as 2h and 3f).
99
See Recommendation 8 for recommended school and program support directors.

Expected Practices. Have the special education associate superintendent and zone
associate superintendents jointly establish expectations for special education
administrative practices and do the following –
— Zone Principal Meetings. Expect regular special education principal support
administrator and periodic associate superintendent attendance at principal zone
meetings and expect attendance by center principal(s).
— School Visits. Establish schedules for special education personnel (e.g., principal
support administrators, program support administrators, etc.) to routinely visit assigned
schools. Expectations for these schedules need to be realistic, given the number of
assigned schools.
— Instructional Rounds. Expect principal support administrator participation in
instructional rounds. As part of this process, ensure instructional round protocols
include observations of specialized classes.
c. Cross-Functional Training. Conduct cross-training of personnel from different departments
to ensure that essential information is provided to all principals, leadership teams, and teachers.
As more general educators are expected to demonstrate differentiated instruction and other
strategies normally reserved for special education, then special education administrative
personnel can support activities requiring a higher level of expertise.
8. Special Education Department Organization and School Support. The following
recommendations are designed to enable special education department personnel to more
effectively assist principal leaders and school personnel to support teaching/learning.
a. Student Achievement Executive Director Oversight. The following changes are offered for
APS’s consideration. The Council team believes that these changes--with additional input from
special education leadership—could make reporting lines clearer and easier for central office,
zone, and school-based personnel to understand. These changes apply to the student
achievement executive director’s direct reports. (See Exhibit 4j.)
Have three directors 100 report to the student achievement executive director, one each
responsible for school support, program support, and related services support. This would
require one more administrative supervisory position. Have each administrator be responsible
for the following –
• Principal Support Director. Have the eight principal support administrators oversee the
IEP specialists (with elementary administrators) and cross-categorical services. If possible,
hire two more BCBAs and assign one to each zone.
— Role. Have the principal support director with assistance from principal support
administrators support the zone associate superintendents and principals to improve
teaching/learning and promote effective inclusive instruction and behavioral support.
— Principal Support Administrators and Related Services. Remove from the principal
support administrators’ responsibilities the 10-to-15 related-services personnel each
supervises. This would give administrators more time for school visits; support for IEP
100
The term director is being used for descriptive purposes. APS may decide to use a different administrative level
for this position.

specialists and head teachers; and development of indicators on cross categorical

services with support aligned to these indicators.101 These changes would alleviate the
unreasonably large spans of control currently assigned to lead principal support
administrators and principal support administrators.
— Head Teacher Liaison. Have the head teacher liaison report to the principal support
administrator (instead of the compliance executive director) to reinforce the
instructional aspect of the head teachers’ role. Have the principal support director,
compliance executive director, and head teacher liaison collaborate in their support of
head teachers.
• Program Support Director. Have this position supervise personnel who support
specialized programs, along with transition programs, extended school-year, and
homebound initiatives. Currently, 10 program support personnel are used to engage APS’s
specialized programs. Determine whether this number is sufficient to visit school
programs, develop indicators for high quality instruction, and support instruction aligned
with these indicators. Have program support personnel with relevant expertise support the
programs to which they are assigned.
• Related Services Support Director. Have three liaisons report to the director – one each
for psychologists/social workers; occupational therapy, physical therapy, adapted physical
education; and nursing.
— Role. Coordinate with the evaluation/related services executive director102 on the hiring
and development of liaison role/ responsibilities and authority.
— Oversight. Establish relationships between liaisons and principal support
administrators to provide additional support for related services personnel assigned to
schools within their zones. However, have the related-services support director in
combination with their liaisons be primarily responsible for supervision of related-
service providers in the field. Establish administrative positions for the liaisons to meet
personnel evaluation requirements—if necessary.
— Regular Meetings. Have liaisons meet regularly with their respective service providers
in interdisciplinary settings to provide opportunities for cross-talk, discussions of
relevant issues, and training. Initiate discussions with PED representatives to ensure
that any logging requirements do not interfere with meetings, discussions, and other
activities involving non-caseload matters.
— Review of Centralized Evaluation Centers. Consider whether the special education
evaluation process could be returned to schools and operate in compliance with
required evaluation-time frames. Although the centralized process is generally
effective, it has resulted in the removal of personnel from schools. Consider hiring an
outside consultant knowledgeable of the evaluation process to review APS’s model and
develop other options.
101
See Related Services Support Director for supervision of related services personnel.
102
Have the executive director continue to oversee assessments at centralized evaluation centers.

Exhibit 4j. Current and Proposed Special Education Department Organizational Changes
Special Education Associate Superintendent
Lead Sp Ed Principal Support Administrator School Support Director
8 Principal Support for Special Education
4 Administrators (Aztec Complex, Highland
(IEP Specialists; cross categorical services)
Complex, and Transition Services)
Head Teacher Liaison
Program Support Director
Principal Support for Special Education
10 Program Support Personnel
Administrator & Comprehensive Support
(Comprehensive Support Services, 2 transition
Services
administrators, extended school year,
homebound)
- Principal Support Administrator (Nursing,
cross-categorical programs & PAC; 10 Related Services Support Director
program support personnel
8 Principal Support for Special Education Liaisons for psychologists/social workers, OT-
(Related services personnel & IEP specialists) PT-APE, and nursing)
10 Support Assistant Principal (In schools
with many specialized program classes)
Indirect Report to Program Support Director
• Have 10 Support Assistant Principals report
to assigned school principal
• Change complexes to schools with principal(s)
reporting to zone associate superintendent (s)
• Removal from Executive Director’s Oversight. To align administrative work more closely
with school-based operations and normal principal reporting lines, remove the following
reports from the student achievement executive director’s oversight:
— Support Assistant Principals. Have the 10 support assistant principal positions
currently assigned to schools with large numbers of specialized-program classes report
instead to the principal at each respective school. Have indirect reporting relationships
with the program support administrator to provide feedback about programmatic needs.
Have each principal make the hiring decision on his/her support assistant principal,
with input from the student achievement executive director.
— Special School Principal(s). As discussed above, establish the Aztec and Highland
complexes as schools with one or two principals who would report to one or two zone
associate superintendents. This would enable school administrators to discuss with
peers and zone associate superintendents issues related to school management,
instruction, etc. Expect principals and program support administrators to collaborate
and continue the special education department’s current level of support for specialized
schools.
• Related Operational Activities
— Feedback/Communication. Review and obtain feedback about the proposed special
education department recommendations with zone associate superintendents and other

stakeholders. Upon finalization of changes, post the organization chart on the special
education and district website.
— Functional Directory. Develop a functional directory of the new organization that
clearly describes who to call/email for information based on subject areas of interest or
need. Base the directory on a pyramid of support, starting at the school level, moving
to the zone, and then to the central office. (Include general education resources that
may also be available.) Update this information as personnel change. Until changes are
made, post the organization chart currently in use on the special education webpage.
When finalized, post the functional directory on the district’s website and other venues,
and distribute it broadly to stakeholders.
— Clear Lines of Oversight. Have a clear written roadmap to show how information is
expected to be communicated consistently from special education to the field. Include
direct supervisory lines and explain how they interface with indirect reporting lines.
This product should communicate decision-making authority within the special
education department, and to zones and school personnel.
b. Operational Changes.
• Caseload Entry. Have the human resources department and the finance and special
education offices review the current process to validate school-based services and the FTE
data submitted by schools for the state. Determine whether this degree of centralized
review is necessary. Instead, consider additional training and monitoring of schools that
have had relatively low-quality data entry, and hold schools accountable for the entry of
reliable data. This change would free up the director from entering these data and allow the
director to address other pressing issues.
• Full-Day Special Education Leadership Meetings. Have the superintendent meet with the
special education associate superintendent to review the content of the associate
superintendent’s weekly day-long meetings with staff to discuss its purpose, deliverables,
utility, etc. Consider ways in which a weekly two- to three-hour meeting could address
essential activities. Have the associate superintendent delegate more decision-making to
her leadership team and hold them accountable.
9. School-based Special Education Support. Strengthen principal leadership and oversight

of special education. Add new personnel support for special education administration and
operations if necessary.
a. Principal Leadership. Have the deputy superintendent facilitate a team to develop principal
leadership training that would focus on their oversight of special education and inclusive
instruction/behavioral support. Consider having principal professional learning communities
handle this subject. Identify the knowledge principals need that should be incorporated into
additional training opportunities.
b. IEP Specialists, Head Teachers, and Special Education Assistant Principals. Although
principals have primary oversight for the operation and administration of special education,
they also need to delegate much of that responsibility. To succeed, personnel should have the
training and time necessary to carry out their responsibilities. These responsibilities include
but are not limited to ensuring the timely flow of processes related to the SAT, child find,
eligibility and IEP team meetings, development of high-quality IEPs, support for more

inclusive and effective instruction, compliance, meeting with school personnel, parent support,
complaint/due process coordination, coordination between special education department
personnel and principals, etc. These activities affect teaching and learning for students with
disabilities and district adherence to multiple federal, state, and local requirements.
With stakeholders, including principals, head teachers, IEP specialists, special education
administrators working with head teachers and IEP specialists, along with ATF leadership,
consider the following recommendations to improve critical school-based positions.
• Head Teacher for All School Levels. Establish a head teacher role or position for all grade
levels to provide for a common set of expectations, training, and support.
— Role and Responsibilities. Establish clear written expectations for head teachers’
roles/responsibilities and principal’s support and engagement with head teachers.
— Criteria for Position Options. Consider the various options below for head teachers.
Establish criteria for options, and base them on such factors as number of students with
IEPs, instructional/behavior needs of students, specialized programs, etc. Possible
future options include:
o Full time position
o Annual stipend
o Reduced caseload
o Clerical support (perhaps with a stipend for current school clerks or hiring of
part-time clerks)
• Rationale for Change to IEP Specialist Position. Effective special education
administration/operation requires personnel who are housed at each school. This enables
personnel to know school staff, students, and parents, and generally be available to address
critical issues. The funds from the IEP specialist positions and IEP liaison position can be
applied to the head teacher options listed above. This change could help address the number
of APS’s special education teacher vacancies.
• Special Education Assistant Principals. As discussed above, hire or deploy assistant
principals to support the administration/operation of special education.
c. Student-Staff Ratios. Have the deputy superintendent, senior special education executive
director, and finance personnel review staffing ratios summarized in this report (see Appendix
A) and other caseload data. NOTE: Relatively low or high student-to-personnel ratios in
Appendix A do not necessarily mean that an area is staffed inappropriately. However, outlier
ratios should prompt further review. Review caseloads to ensure that adequate numbers of
special education and related-services personnel are at each school to carry out their expected
responsibilities. Based on a full review, consider changes needed short and long term. In
addition, have the group collect data showing caseloads and workloads for special educators
and ancillary staff to identify those exceeding the norm and monitor.
d. Miscellaneous Related Service Personnel Issues
• Nonspecial Education Funds. Expedite the use of operational funds for social workers,
speech/language pathologists, school psychologists, and other personnel areas so they can
be used to support students.
• School Psychologists. The low FTE numbers of school psychologists raises concerns.

Even though their role is supplemented by educational diagnosticians, these professionals

are assigned to centralized evaluation centers. School psychologists have unique graduate
training that would provide value to school personnel, such as support for students with
significant behavioral issues, SAT processes, FBA/BIPs, etc. Consider options for
increasing the number of school psychologists, including those who are bilingual.
• Allocation to Schools. Take specialized program demographics into consideration when
allocating social workers and other ancillary staff.
• Telepractice. Take steps to ensure that students receive speech/language pathology
services through telepractice in accordance with guidelines of the American Speech-
Language-Hearing Association (ASHA).103
• Logging Services. Confirm with PED its directive for logging ancillary services (every 15
minutes), whether it is currently in effect or will be in effect in the future. Advocate for
elimination of the requirement.
• Special Education EAs. Consider commissioning with ATF a survey of EAs to more fully
understand barriers to their effectiveness. Act on the findings.
e. Special Education Related Shortages. Create a sense of urgency with the human resources
department, ATF, the special education unit, bilingual personnel, and finance staff around the
need to develop and implement a more aggressive and coherent personnel recruitment and
retention strategy for the district. Meet regularly to review data on identified shortage areas.
Explore external resources that could help fill hard-to-find special education-related vacancies.
Also address the following by--
• Expanding recruitment options and additional funding for recruitment purposes;
• Improving APS’s position management system;
• Having human resources resume prescreening of applicants to facilitate principal review
and selection;
• Prioritizing the filling of vacancies in programs having students placed by the district, i.e.,
in highly intensive/specialized classes;
• Communicating better with EAs about the career pathways program;
• Stopping intra-APS transfer practices during the school year, which would require
discussions and negotiations with ATF;
• Increasing salaries in personnel areas with compensation significantly below neighboring
districts (particularly for EAs) to discourage transfers to other districts. Establish signing
bonuses to encourage new hires in high shortage areas. These options would require
• Addressing retention practices, including initiation of new-teacher mentoring, that includes
special educators, ancillary personnel, and educational assistants;
103

• Establishing incentives for general educators who hold special education certifications to
become special educators. This would require discussions and negotiations with ATF;
• Having centralized onboarding support for new teachers, including support for new special
educators from the Philippines.
• Ensuring program support teachers assist special educators teaching under the alternative
licensure program have the capacity and time to be effective;
10. General Compliance Support, and Data and Fiscal issues. Consider the following actions
to improve compliance; address data issues; and enhance revenue.
a. Compliance Support. Increase support for activities that include the following –
• Special Education and Section 504 Standard Operating Procedures Manuals. Expedite
the development of electronic manuals on special education and Section 504. Include
written expectations associated with Recommendations 3c and 5c. Incorporate information
on the FBA/BIP process. Establish the manuals as webpages with user-friendly summaries
with links to more detailed information and public resources. Collaborate with stakeholders,
including parents, to identify useful publicly available resources and links. Ensure staff
members are available to update information regularly. Provide training to stakeholders
and parents to boost their understanding of core elements of special education and Section
504. Place this information on the webpages. Ensure training is accessible to parents with
diverse linguistic needs and sensory limitations. 104
• Legal Support. Strengthen compliance by taking actions like the following –
— Unified Representation. Have a single legal firm or in-house counsel represent all
special education related legal assistance. Suggest counsel actively engage with the
Council of Great City Schools’ legal counsel meeting next October in Louisville.
— Collective Bargaining Training. Have an attorney regularly provide to all special
education department personnel information on the collective bargaining agreement
and their obligations under it. Hold staff accountable for adherence to the agreement.
Repeat this process with new staff and all staff with new issues as they arise. Record
webinars or videos and post them on the website.
— Order of Manifestation Determinations and Impartial Discipline Hearings. Have
legal counsel review the district’s flow chart on students with disabilities having long-
term disciplinary removals and consider holding manifestation determinations PRIOR
to any disciplinary expulsion hearing (unless the behavior related to the use of a
weapon, drugs, or infliction of serious bodily injury).
— APS Attorney Fees for Due Process Hearing Requests. With special education
leadership, legal staff, and finance personnel, review Exhibits 4d and 4e and examine
fees paid for APS legal representation in due process hearings compared to plaintiff
attorney fees. Develop actions to reduce the number of hearing requests and the
generation of attorney fees. Consider using special education personnel to manage due
process hearing requests that are not complex, are easily resolved, and may not involve
104
For example, see the Los Angeles Unified School District Electronic Policies and Procedures Manual, retrieved
at https://achieve.lausd.net/site/Default.aspx?PageID=14466.

a parent or district attorney.

• IDEA Annual Compliance Determination
— 80th Day Data to PED. As part of APS’s special education discussions with PED,
address the agency’s decision to obtain from school districts 80th day data that requires
attention a day or so after winter break. 105
— Other Activities. Have the joint APS/ATF external consultant discuss issues related
APS’s designation by PED as “needs intervention” for the fourth time. Include
discussions of delayed evaluations and untimely/inaccurate data. Consider current
actions and what the district could be doing to improve compliance.
• Professional Learning. In implementing Recommendations 3d and 5d, incorporate into
training the necessary steps to address compliance issues on PED complaints, due process,
Office for Civil Rights complaints, and IDEA annual compliance determinations.
b. Fiscal Issues. Pursue the following activities to enhance revenue and shift more funds to boost
high-quality education in both inclusive and separate classes.
• Medicaid Documentation. Expedite the use of Synergy for ancillary personnel like nurses
to track service delivery. Review potential revenue based on charter school Medicaid
billing to determine APS’s return on investment. If the return is beneficial, take actions
necessary to carry out this activity.
• Transportation. Ensure that students with IEP-required EAs receive this service and that
protocols are in place for such IEP decisions. Ensure that processes are in place for schools
to provide supervision of students during early drop off and late pick-ups. To the extent
feasible, link IEP and transportation systems to reduce transportation delays and make
routing more efficient.
c. Data Collection and Reporting. In coordination with Recommendations 2g, 3e, and 5e,
address the following on data collection and reporting –
• Data/Information Coordination. Have a protocol in place for coordinating data and
information collection from all involved departments and personnel.
• IEP System. Have special education leadership with zone, school, and technology
representatives review IEP systems available in the market place and compare them with
APS’s current system. Evaluate usability, data collection, ease of reporting, special
education management, and ability to migrate data to the student information system and
IEP system. Use this information to determine if the benefits of a new system outweigh
maintaining the current system.
• Special Education Records. Develop a plan for 2019-20 to have schools maintain their
own special education records. Address how schools can respond to record requests and
record transfers. The Council team can share contacts with other large urban school
districts that maintain school-site special education records.
d. Monitoring and Accountability. In coordination with Recommendations 2h, 3f, and 5f –
105
Because the district must resolve issues involving students who are mutually reported by APS and other districts,
this time frame is difficult if not impossible to meet.

• 90-Day Plans. Have processes in place to ensure that school-based 90-day plans
consistently address issues related to students with disabilities and that
achievement/behavior data are disaggregated by disability status.
• Academic Master Plan. Ensure that data associated with Academic Master Plan indicators
are disaggregated for students with disabilities and English learners with disabilities.
11. Internal Project Manager. Have an independent project manager assigned to the
superintendent monitor activities associated with the Council-team’s recommendations. Have
the project manager coordinate reports to the superintendent and cabinet, the status of
implementation, barriers to execution that require interdepartmental collaboration, and any
need to adjust planning and expectations.

CHAPTER 5. SUMMARY OF RECOMMENDATIONS
This chapter summarizes the recommendations made in Chapter 3 in two ways. The first
way lists the recommendations from the previous chapter and the functional categories into which
each one falls. The categories include accountability, planning, criteria/process, training,
data/reports, and cross-references. The second way lists all recommendations, so the reader can
see them in one place.
Recommendation Matrices
The matrix below shows five areas of recommendations and the various components that
are common to them in order to show how they interrelate.
Review of General
Demographics & Instruction
MTSS Data Re: Compliance
Child Find & Support
Instruction Support
Board Policy 2a 5a
Representative Stakeholder
2b 3a 4a 5b
Teams
Implementation Plan 2c 3b 5b
Written Guidance 2e 3c 5c
Professional Learning 2f 3d 5d 10a
Data Collection and Reporting 2g 3e 5e 10c
Monitoring & Accountability 2h 3f 5f 10d

The second matrix, which is below, lists recommendation headings from the previous
chapter by operational tasks.
Standards/Procedures
Accountability
Data/Repots
Recommendations
Planning
Training
Overall Support
1. Align Academic Support for All Students. Revise APS’s organizational structure to
align administrative support for teaching/learning to focus and leverage district
resources. Either have all associate superintendents report to a deputy superintendent
or chief education officer and promote the curriculum/instruction leadership position
to the associate superintendent level to reinforce the importance of this function. (For X X
these recommendations, the term deputy superintendent is used.) As part of this
leadership development, establish expectations for the inclusiveness of all decision-
making and implementation activities undertaken by the district through any
department.
Multi-tiered System of Supports
2. Multi-tiered System of Supports. Immediately build on its SAT and RtI practices to develop/implement a
framework of multi-system of supports (MTSS) for academic achievement, positive behavior, and
social/emotional growth (including enrichment) for all students. Consistent information is readily available
in the educational literature for this purpose. It is highly likely that state guidance will be founded on this
same literature, and upon PED’s issuance of its guidance APS will be able to review it and as needed adjust
its work.
a. Board Policy and Vision. Establish a school board policy in support of the district’s
MTSS framework (for academics and behavior). As part of this policy, emphasize
that when high-quality Tier 1 instruction is provided, fewer teachers struggle to
access and use evidence-base Tier 2 interventions. Charge the administration with
developing and implementing an MTSS framework and roll-out plan. Include
X X X
expectations that the framework will be used, and that it includes all grades and
students and supports linguistically appropriate/culturally competent instruction.
Require school-based strategic plans, e.g., 90-day plans, to develop local
implementation activities based on the MTSS framework and implementation plan
requirements.
b. District, Zone & School Leadership Teams. Establish leadership teams at the
district, zone, and school levels to support MTSS planning and oversee
implementation activities. These teams may be embedded in existing teams with X
current or additional/different participants that are able to absorb and carry out this
work.
c. Implementation Plan. With the districtwide MTSS team, develop a written multi-
year action plan that calls for written expectations, professional learning, data X X
analytics, and accountability. Identify an aggressive phased in time frame for
implementation with short and long-term objectives. Engage ATF representatives

during the framework development process to address concerns and maximize buy-
in.
d. Map Resources & Analyze/Address Gaps. Assess current human resources and
instructional materials provided by the district and funded by schools to ascertain X X
their effectiveness and return-on-investment in terms of improved student outcomes.
e. Written MTSS Guidance. Develop written guidance regarding the MTSS framework
that is sufficiently specific to develop universal understanding and expectation for X
core principles.
f. Differentiated Professional Learning. Based on the MTSS framework,

implementation plan, and written guidance, develop and put into place a professional X
development program to support it.
g. Data Analysis & Reports. Review current data collection, analyses, and reports and
supplement them with indicators or metrics that would be useful in determining
X
whether schools use MTSS practices and their relationship to student achievement,
e.g., growth based on appropriate instruction and intensive interventions.
h. Monitoring & Accountability. Evaluate the implementation, effectiveness, and

X X
results of MTSS.
Demographics, Referral & Identification of Disability
3. Demographics, Referral & Identification. Improve the overall consistency and appropriateness of special
education referrals, assessments, and eligibility decisions.
a. Data Review. With a multi-disciplinary representatives of the district MTSS
leadership team, review exhibits 2a through 2f. Include representatives from
curriculum/instruction, English learners, zone associate superintendents, X
representative special education administrators, principals, etc. (Coordinate this
activity with Recommendation 2b.)
b. Implementation Plan. Based on these data and staff member’s hypotheses about
why the patterns look like they do, embed in the MTSS implementation plan
activities relevant to the SAT process and disability areas of concern. Also, address
evaluation center instructional managers have real-time access to evaluation data to
regularly review eligibility and other relevant data to monitor patterns and trends and
to take follow-up action as needed. To support this process, consider hiring a short-
X X
term external consultant with expertise in special education assessments for the
disability areas of concern, as well as the collection/use of progress monitoring data
as part of the assessment process. Review APS’s current practices (including referral
review process), configuration of assessment personnel (educational diagnosticians/
psychologists), quality of assessments, and assessment centers, etc. (Coordinate this
activity with Recommendation 2c.)
c. Written Expectations. For each disability area identified by the multi-disciplinary
team as a concern, review district processes, including referrals, assessments, and
eligibility, and amend them to provide more specific guidance. In coordination with X
Recommendation 2e, develop time frames for ensuring that the child find process is
carried out within a reasonable period of time. Combine this guidance into a
comprehensive electronic special education manual that is publicly available. Obtain

feedback to the draft provisions to ensure they are clear and do not have unintended
consequences.
d. Differentiated Professional Learning. Plan for and provide all relevant district
stakeholders with the professional development they need to implement the activities X
included in Recommendation 3. (Coordinate this activity with Recommendation 2f.)
e. Data Analysis and Reports. Develop and provide regular user-friendly reports to
district leadership showing data like those in exhibits 2a through 2f. If possible, show
initial data related to disability determinations based on students’ schools at the time X
of eligibility to consider school-based factors. Share data by zone and by schools
within zones. (Coordinate this activity with 2g.)
f. Monitoring and Accountability. Develop a process for ongoing monitoring of
expected referrals, evaluations, and eligibility practices. Rather than using a
traditional record-review compliance model, review data with schools so that they
X
are aware of problems, and they are better prepared for follow-up action. Enable staff
to observe best practices and receive coaching that will improve their knowledge and
skills. (Coordinate this activity with Recommendation 2h.)
Improving Instruction & Supports for Students with Disabilities
5. Expansion of Inclusive & High-Quality Instruction/Supports. Begin a process for increasing the provision
of effective and inclusive special education services. To expedite this process, consider using an experienced
consultant who has had successful outcomes in this area to help facilitate planning and implementation.
a. Inclusive Education Vision & Board Policy. Have the district’s MTSS leadership
team plan a day-long retreat, along with representative stakeholders (including the
ATF), to establish a vision of inclusivity and quality instruction for students with
disabilities. Establish a school board policy stating a clear and defined vision for X
APS on the value of inclusivity and that reinforces the district’s commitment to
improving academic achievement and social/emotional well-being for students with
disabilities.
b. Implementation Plan. With representatives of the multidisciplinary team assembled
pursuant to Recommendation 2b, develop a written multi-year action plan that calls X X
for written expectations, professional learning, data analytics, and accountability
c. Written Expectations. As part of the implementation plan described in
Recommendation 5b, develop written expectations on each plan component. X X
(Coordinate and link with Recommendation 2e.)
d. Differentiated Professional Learning and Parent Training. Embed in the
professional development curriculum content needed to carry out Recommendation 5.
(Coordinate and link with Recommendations 2f and 3e.) Embed into current
instructional rounds indicators associated with implementation plan components. With
X
multi-disciplinary representatives of the district MTSS leadership team
(Recommendation 5b), map out the professional development curriculum and the
stakeholders relevant for each group. Consider an annual conference to showcase
exemplary school practices, information, etc.
e. Data Analysis and Reports. With representatives of the multidisciplinary team
assembled pursuant to Recommendation 5b, identify data and charts such as those
included in this report as well as others that are necessary for district, zone and X X
school personnel to problem-solve, strategize, and proactively carry out their
responsibilities. In addition to activities proposed in Recommendation 2g and 3e,

embed in 90-day plans, and other school performance/planning frameworks: the

types of data needed to better target patterns and areas of concern; the use of risk
ratios to better understand district practices and their effects; etc.
f. Monitoring and Accountability. Expect all principals to be responsible for
overseeing special education in their buildings and hold them explicitly accountable
for such. Articulate how cohort principal leaders will work with their principals and
X
how they will exercise their responsibilities to ensure principals are serving students
with disabilities. Embed activities into the monitoring and accountability systems
described in Recommendations 2h and 3f.
6. Parent Support & Engagement. Improve APS’s engagement with parents/families to expand their
involvement with schools and support for their children’s education.
a. District Parent Advisory Council. Work with a broad range of parent representatives
from all zones and community-based organizations to design an effective
districtwide advisory council, hosted by the special education associate X XX
superintendent, to collaborate with the special education leadership regarding various
aspects of zone-based parent advisory committee meetings.
b. Parent Conferences. Consider having one or two districtwide parent conferences

X X
during the year.
c. Presence of Associate Superintendent. At regular intervals, have the special

education associate superintendent attend the zone-based parent advisory committee X
meetings to have a visible presence and address parent concerns.
Organizational Support
7. Interdepartmental Collaboration. Specifically charge senior staff in all central office departments with
collaborating with each other to support teaching and learning for students with disabilities. In addition--
a. Collaborative/Inclusive Discussions and Deliverables. Ensure all central office,
zone, and school discussions affecting teaching and learning include special
education/related services personnel and others knowledgeable about students with
disabilities. Have department representatives from special education and English X
X
learners meet regularly to address mutual responsibilities for English learners who
have disabilities, and charge staff with developing and implementing models of
effective instruction and supports for English learners with IEPs. (Coordinate with
Recommendation 5b.)
b. Zone Level Collaboration. Have the deputy superintendent meet with the zone
associate superintendents, their respective staff members, and departmental personnel
who liaison with the zone associate superintendents and their supervisors. Facilitate a
discussion about the need and planning for collaboration and strategies for regularly X X
scheduled interactions and strategies to improve teaching/learning for students with
disabilities that transcend administrative support for general and special education as
separate entities.
c. Cross-Functional Training. Establish a structure for cross-training of personnel from
different departments to provide essential information for all principals, leadership
teams, and teachers. As more school support personnel outside of special education X
can support practices general educators are expected to demonstrate (e.g.,
differentiated instruction), special education (quasi) administrative personnel can

support activities requiring a higher level of expertise.

8. Special Education Department Organization and School Support. The following recommendations are
designed to enable special education department personnel to more effectively assist principal leaders, and
school personnel to support teaching/learning.
a. Student Achievement Executive Director Oversight. Various changes are offered for
APS’s consideration. These changes apply to the student achievement executive
director’s direct reports. (See Exhibit 4j.) Have three directors report to the student X
achievement executive director, one each responsible for school support, program
support, and related services support.
b. Operational Changes. Have human resources, fiscal, and special education
representatives review the current process used by the budget/data executive director
special education administrator to validate school-based level of services and FTE
data submitted by schools for the state, and whether this degree of centralized review
is necessary. Instead, consider additional training and monitoring of schools that have
had relatively low-quality data entry practices, and holding schools accountable for
X X X X X
the entry of reliable data. Also, have the superintendent meet with the special
education associate superintendent to review the content of the associate
superintendent’s weekly day-long meeting with staff to discuss its purpose,
deliverables, etc. Consider ways in which a weekly two- to three-hour weekly meeting
could instead address essential activities. Have the associate superintendent delegate
more decision-making to her leadership team and hold them accountable.
9. School-based Special Education Support. Strengthen principal leadership and oversight for special
education along with greater personnel support for special education administration and operation.
a. Principal Leadership. Have the deputy superintendent facilitate a team to develop
principal leadership training focusing on their oversight of special education and
effective inclusive instruction/behavioral support. Consider having principal X X X
professional learning communities on this subject.
b. IEP Specialists, Head Teachers, and Special Education Assistant Principals. With
representative stakeholders, including principals, head teachers, IEP specialists,
special education administrators working with head teachers and IEP specialists, and X
ATF leadership, consider having head teacher for all school levels; and reporting of
assistant special education principals to school principals.
c. Student-Staff Ratios. Have the deputy superintendent, senior special education
executive director, and finance personnel review staffing ratios summarized in this
report (see Appendix A) and other caseload data. NOTE: Relatively low or high
student-to-personnel ratios in Appendix A do not necessarily mean that an area is
staffed inappropriately; however, outlying ratios should prompt further review.
Review caseloads to ensure that adequate numbers of special education and related- X X X
services personnel are at each school to carry out their expected responsibilities.
Based on a full review, consider the changes needed short and long term. In addition,
have the group collect data showing caseloads and workloads for special educators
and ancillary staff to identify those exceeding expectations and to monitor follow-up
action.
d. Miscellaneous Related Service Personnel Issues. Proportionately fund related
services positions so personnel can also support students without disabilities;
consider low FTE number of school psychologists and their very high ratio to X X
students with disabilities; consider student demographics for related services
allocations and telepractice services for hard to staff areas; address service logging

requirements; and survey of EAs to more fully understand any barriers to their
effectiveness for follow-up action.
e. Special Education Related Shortages. Create a sense of urgency by immediately
having an interdepartmental/ATF team of human resources, special education and
finance personnel review current special education related vacancies (including for
bilingual personnel and EAs) and develop an urgent action plan to address shortages.
X X
Regularly meet to review data relevant to identified shortage areas. Explore external
resources (through a request for information, RFI) with expertise related to filling
hard to find school district special education related vacancies. Also address various
recruitment strategies.
10. General Compliance Support, and Data and Fiscal issues. Consider the following actions to improve
compliance; address data issues; and enhance revenue.
a. Compliance Support. Increase support for compliant activities with actions that
include expediting the drafting of special education and Section 504 standard
operating procedures manuals; and strengthening legal support by using a single
legal firm/counsel; addressing collective bargaining training; reviewing the
relationship between manifestation determination hearings and impartial discipline
hearings; reviewing fees for APS attorneys with respect to due process hearing X X X X X
requests; and addressing the district’s IDEA annual compliance determination.
Finally, as part of Recommendations 3d and 5d, include in professional learning
curricula necessary to address compliance issues most frequently related to PED
complaints, due process, Office for Civil Rights complaints, and IDEA annual
compliance determination.
b. Fiscal Issues. To enhance revenue and shift more funds to activities that would boost
high-quality education in inclusive and separate classes, address Medicaid X X
documentation activities and specified transportation issues.
c. Data Collection & Reporting. In coordination with Recommendations 2g, 3e, and X
5e, address data/information coordination; consider reviewing other IEP systems on
X X
the market; and discuss how schools could maintain their own special education
records. x
d. Monitoring & Accountability. In coordination with Recommendations 2h, 3f, and 5f:
ensure that 90 day plans consistently address issues related to students with X
disabilities; and disability data is available through the Academic Master Plan.
superintendent to monitor activities associated with the Council team
recommendations. Have the project manager coordinate reports to the
X
superintendent and cabinet, relevant data, the status of implementation, barriers to
execution that require interdepartmental collaboration, and any need to adjust
planning and expectations.

List of Recommendations
Align Academic Support for All Students. Revise APS’s organizational structure to align
administrative support for teaching/learning to better leverage district resources. Either have
all associate superintendents report to a deputy superintendent or a chief education officer, and
promote the curriculum/instruction leadership position to the associate superintendent level to
reinforce the importance of this function. (For these recommendations, the term deputy
superintendent is used.) Establish expectations for collaborative decision-making and program
implementation across department’s in the district. For example, these more coordinated
activities would include the:
• Selection and implementation of new curricular materials, use of universal design for
learning strategies, training activities, and the solicitation and implementation of district
grants.
• Collaboration between general and special education personnel to address academic and
behavioral concerns, while ensuring that compliance responsibilities were being met.
Multi-tiered System of Supports. Even though the New Mexico’s PED framework for tiered
instruction and interventions is in flux, there is overwhelming consistency in the educational
literature on the components of an effective MTSS framework. The nature of this work is too
important for APS to wait for state guidance. Rather, the district should immediately build on
its SAT and RtI practices to develop/implement a framework of MTSS in academic
achievement, positive behavior, and social/emotional growth--for all students. 106 Consistent
information is readily available nationwide for this purpose. It is highly likely that state
guidance will be founded on the same literature.
The Council team has chosen to use the term MTSS because of its universal meaning in the
educational literature and its use in the federal Literacy Education for All, Results for the
Nation Act (LEARN Act), H.R. 2272, which authorizes state grants to improve literacy at birth
through grade 12. This broad usage makes it easy to find relevant information in any internet
search. The term that PED is reportedly using, i.e., “multi-levelled services and support”
(MLSS), is not in use outside the state. If PED is not convinced to change the term, we
recommend that APS maintain the term MTSS. In any event, the district should clarify to
stakeholders that the framework is essentially MTSS to avoid confusion and maximize use of
resources publicly available across the country.
a. Board Policy and Vision. Establish a school board policy in support of the district’s MTSS
framework (for academics and behavior). The policy should indicate that, when high-quality
Tier 1 instruction is provided and is effective, fewer teachers will need to access and use
evidence-based Tier 2 interventions. When first instruction and interventions are successful,
the MTSS framework ceases to be a process to “get through” in order to justify special
education referrals. Charge the administration with developing and implementing an MTSS
framework and roll-out plan. Expect that the framework will be used, and that it includes all
grades, students, and supports to provide linguistically appropriate/culturally competent
106
The term MTSS is used generically because of its universal meaning in educational literature and its use in the
federal the Literacy Education for All, Results for the Nation Act (LEARN Act), H.R. 2272, which authorizes state
grants to improve birth through grade 12 literacy. APS may choose instead to use the term adopted by PED, multi-
levelled services and support (MLSS).

instruction. Require school-based MTSS implementation plans, e.g., 90-day plans. Have APS
modify the district plan and school plans as the district gains experience with it.
b. District, Zone and School Leadership Teams. Establish leadership teams at the district, zone,
and school levels to support MTSS planning and implementation activities. These activities
could be delegated to existing teams and augmented with personnel who are able to absorb
and carry out the work.
• District MTSS Leadership Team. Have the deputy lead and oversee the development and
implementation of MTSS across the system, using a broad, diverse, and representative team
of stakeholders from district, zone, and school levels. When completed, schedule a two-
day overview for staff and monthly meetings for the MTSS leadership team to ensure use
of a common language, high-quality implementation, and effective resource allocations.
• Zone MTSS Leadership Teams. Have each zone establish an MTSS leadership team with
principals and representatives of zone-based administrators and school personnel who
would be responsible for implementation.
• School-Based Leadership Teams. Based on the district’s MTSS-implementation plan
(Recommendation1c below), establish school-based leadership teams to provide
training/guidance on activities that could be incorporated into each school’s 90-day plans
or other school-improvement plans. These teams should lead each school’s MTSS work to
ensure a common understanding of the framework at the building level. The teams should
also have defined responsibilities, such as providing professional development and
technical assistance, monitoring implementation and supports, and reviewing student data.
c. Implementation Plan. Charge the districtwide MTSS team with developing a written multi-
year action plan with expectations, professional learning, data analytics, and accountability
measures. Identify an aggressive time frame for implementation with short and long-term
objectives. Engage ATF representatives during the development process to address concerns
and maximize buy-in. Disseminate the draft framework to stakeholders, including parents
who are English learners, and obtain their feedback prior to the framework’s finalization.
Incorporate components from the MTSS literature, including universal screeners, formative
assessments, standard protocols for interventions/supports, curricular materials, supplemental
and intensive resources, data platforms, use of data, professional learning, budget allocations,
etc. Make clear that the framework includes all students, including students with disabilities,
English learners, and accelerated learners. Include the following components in the MTSS
framework–
• Framework Design. Review information from PED as well as credible websites, such as
Florida’s Multi-Tiered System of Supports,107 to address recognized MTSS components.
• Department Alignment. Require each department to align staff and priorities to support
the MTSS plan’s implementation. Ensure department deliverables are collaboratively
developed and do not produce competing priorities across schools.
• UDL. Embed universal design for learning (UDL) principles into the MTSS framework,
expanding its reach beyond special education by involving technology and general
107
Retrieved at http://www.florida-rti.org/floridamtss/index.htm.

education in the process.

• Involvement of Students with Disabilities. Although PED associates Tier 3 interventions
with special education, make clear that students with disabilities will not be excluded from
core instruction along with Tier 1 and Tier 2 interventions.
• School-wide Behavior Supports. In addition to work being done to support “first
teaching,” set expectations that schools will provide social emotional learning (SEL) as
part of its MTSS work. This might include the use of a SEL curriculum, community
wraparound services, and the development/implementation of districtwide positive
behavioral intervention and supports. The implementation of behavior interventions or
FBAs/BIPs is not meaningful without a foundation of school-wide and class-wide supports.
• Speech Interventions. Consider how speech/language services can be provided as part of
Tier 1 and Tier 2 interventions. This service model is now more common in urban school
districts nationwide. 108
• Implementation Fidelity. Ensure that observation forms for student learning/behavior
include appropriate Tier 1 instruction, including its differentiation; and that other forms
used by principals/others include components on the appropriateness of selected
academic/behavior interventions. Ensure that interventions are implemented as intended,
i.e., with fidelity.
• Instructional Coaches. As part of the district’s review of instructional coaches and the
sustainability of their positions, clarify the extent to which coaches are used for non-
instructional duties, such as addressing discipline, acting as assistant principals when
principals are out of the building, chairing SATs, etc.
• Instructional Rounds. Develop indicators on the district’s instructional rounds to monitor
whether MTSS components are being put into place. Use follow-up rounds to track trends,
identify strengths, and determine action steps. Ensure that instructional-round teams
monitor the needs of multiple student groups.
• Exemplary Implementation Models. Provide a forum where school and zone personnel
can highlight and share best practices, lessons learned, victories, and challenges in
implementing MTSS for all student groups. Identify and encourage staff to visit exemplary
schools and set aside time for that to happen.
• District Website. Develop a highly visible, well-informed, and interactive web page
highlighting the district’s MTSS framework. Include links to other local and national sites.
Highlight schools in the district that are showing results with this approach and share
stories and data on the effect of MTSS on student outcomes.
• Communication. Communicate with all internal and external stakeholders, ATF
representatives, parents (including those who are English learners) and others about the
purposes and expected outcomes of the plan. Consider commissioning a survey of all
stakeholders to obtain regular feedback on implementation and areas needing follow-up.
• Map Resources and Analyze/Address Gaps. As part of the MTSS planning process, assess
current human resources and instructional materials provided by the district or funded
108
For example, see SPLI and MTSS, retrieved from http://www.nsseo.org/wp-content/uploads/MTSS-SLPs.pdf.

through schools to ascertain their effectiveness and return-on-investment in terms of

improved student outcomes. Compare the value of resources and materials currently in use
in the district with other evidence-based resources in the marketplace and replace low-
value resources currently being used. Establish a menu of increasingly intensive
interventions and resources, which should be vetted against current evidence on
effectiveness and alignment. Ensure that the menu of interventions differentiates levels of
intensity, criteria for use, and contains strategies that are linguistically and culturally
appropriate for a diverse student population. Consider how federal Title I resources could
enhance, supplement, or pay for more effective interventions. If necessary, phase in new
interventions over a reasonable number of years.
d. Written MTSS Guidance. Develop written guidance on the MTSS framework that is
sufficiently specific to develop universal understanding of core principles. As part of the
guidance, address SATs, their composition, roles, responsibilities, and protocols for referral
to special education evaluations. Include reasonable time frames from referrals to parental
consent for evaluation. Incorporate information that reflects APS expectations, including
minimum requirements and areas of flexibility for schools. Have a broad group of
stakeholders review the draft guidance to ensure that it is user-friendly and has no unintended
consequences. Address the high proportion of students found to have an emotional
disturbance at the high school level and its potential relationship to instruction/behavioral
supports. (See later sections of this report.) Also, include in SAT materials information on
Section 504 as a follow-up option. When finalized, post the guidance on the district’s MTSS
webpage with links to more detailed materials, forms, and information publicly available on
the internet.
e. Differentiated Professional Learning. Incorporate the MTSS framework, its implementation,
and written guidance into the district’s professional development program or plan. Ensure that
critical audiences, i.e., general/special educators, related-services personnel,
paraprofessionals, and parents have access to the training. Provide at least four to five days of
training each year, if possible, for school-based MTSS leadership teams over the next two
years. Base training on the Learning Forward Standards for Professional Learning. Consider
how it will be funded, e.g., through stipends, funds for substitute coverage, incentives for
after-school and Saturday training, or summer training. Also, consider how training will be
differentiated and sustained. In addition –
• Access to Differentiated Learning. Ensure that professional learning is engaging and
differentiated based on individual skills, experience, and need. Have professional learning
and technical assistance continue for new personnel and those needing additional support.
• Multiple Formats. Use multiple formats (e.g., videos, webinars, and narrative text) and
presentation approaches (e.g., school-based, small groups).
• Coaching/Modeling. Develop a plan to provide coaching and technical assistance to
principals and school-based leadership teams on practices covered in training sessions and
materials.
• Cross-Functional Teams. Cross-train individuals from all departments working with
schools to ensure a common language and understanding of MTSS. This will help align
and support schools as they work on implementation. Provide direct support, mentoring,
coaching, and technical assistance to principals and teachers on implementation.

• High-Quality Trainers. Identify staff members at all levels who are knowledgeable about
and experienced in the components of MTSS and deploy them as professional developers.
Supplement these staff members with experts from outside the school district.
f. Data Analysis and Reports. Review current data collection, analyses, and reports and
supplement them with indicators or metrics that would be useful in determining whether
schools use MTSS practices and their relationship to student achievement, e.g., growth based
on appropriate instruction and intensive interventions.
g. Monitoring and Accountability. Evaluate the implementation, effectiveness, and results of
MTSS, and include the following–
• Baseline Data and Fidelity Assessments. Use the Self-Assessment of MTSS (SAM) or
other similar protocols for schools to self-assess their MTSS practices. Have network and
districtwide leadership teams periodically review these self-assessments for reliability.
Incorporate SAM results into the school review process to assess fidelity to the framework.
• Data Checks. Using data and charts such as those provided in this report, have the
superintendent, deputy superintendent, and other leaders host regular data conversations
with departments, zone superintendents, and principals to discuss results, anomalies,
needed supports, follow-up activities, and outcomes.
• Timely Communication and Feedback. Assign responsibility for communicating the
MTSS work to stakeholders via multiple channels, e.g., website, television, radio, social
media, etc. Design feedback loops with central office, school personnel, parents, and the
community to assess problems and successes on the ground. Use this feedback to provide
regular and timely information to the district MTSS leadership team on where and how
schools require additional assistance. Consider presenting a bi-annual report to the board
on MTSS to emphasize buy-in and ensure that the highest levels of the district understand
what the system is doing to address its many special education challenges.
Demographics, Referral and Identification of Disability. Improve the overall consistency and
appropriateness of special education referrals, assessments, and eligibility decisions.
a. Data Review. With multi-disciplinary representatives of the district’s MTSS leadership team,
review exhibits 2a through 2f. Include staff from curriculum/instruction, English learners,
zone superintendents, special education administrators, and principals in these reviews.
(Coordinate this activity with Recommendation 2b.) Have the team develop hypotheses about
patterns in the data presented in this section. In addition, examine data on the same variables
by zone and school.
b. Implementation Plan. Based on these data and staff member’s hypotheses about why the
patterns look like they do, embed in the MTSS implementation plan activities to improve the
SAT process for each disability area of concern. Also, ensure that evaluation center
instructional managers have real-time access to evaluation data to regularly review eligibility
and other relevant data, to monitor patterns and trends, and to allow them to take follow-up
action as needed. To support this process, consider hiring a short-term external consultant
with expertise in special education assessments for disability areas of concern. Review APS’s
current practices (including referral-review processes), configurations of assessment
personnel (educational diagnosticians/ psychologists), assessment quality, and assessment
centers. (Coordinate this activity with Recommendation 2c.)

c. Written Expectations. For each disability area of concern, review district processes, including
referrals, assessments, and eligibility, and amend them to provide more specific guidance. In
coordination with Recommendation 2e, develop schedules for ensuring that the child find
process is carried out within a reasonable period. Incorporate this guidance into a
comprehensive electronic special education manual. Make the manual publicly available. 109
Obtain feedback to the draft language to ensure it is clear and does not trigger unintended
consequences.
Ensure that issues raised in the Council team’s report are addressed, including –
• SAT Practices. Establish protocols for SATs, assessments, and IEP teams to use to support
special education decision-making. Specifically address processes connected with
disability areas where APS is an outlier, including specific learning disabilities, emotional
disturbance at the high school level, white students with autism and black students with
emotional disturbance, and high proportion of English learners with a specific learning
disability or an intellectual disability. (Coordinate this activity with Recommendation 2c
and 2e.)
• English Learners. In coordination with language and cultural equity administrators,
incorporate in the procedural manual information on Els with disabilities.
• Lack of Progress. Provide guidance on evaluating whether students have made adequate
progress after being provided appropriate interventions that were implemented with
fidelity. Consider time lines for remedial actions if the SAT suspects a student needs special
education but documentation is incomplete because of missing information or appropriate
interventions were not implemented with fidelity. APS might consider creating a portal
that would store and share vital SAT elements with teachers and stakeholders to ensure
interventions are provided.
• Exiting Special Education. Establish guidelines for determining when and under what
circumstances a student no longer needs special education to progress educationally. A
transition to services under Section 504 might be appropriate for such students.
d. Differentiated Professional Learning. Plan for and provide all relevant district stakeholders
with the professional development they need to implement activities listed in
Recommendation 3. (Coordinate this activity with Recommendation 2f.)
e. Data Analysis and Reports. Develop and provide regular user-friendly reports to district
leadership showing data like those in exhibits 2a through 2f. If possible, show initial data
related to disability determinations based on the students’ school at the time of eligibility to
determine whether eligibility was shaped by school-based factors. Share data by zone and by
schools within zones. (Coordinate this activity with 2g.)
f. Monitoring and Accountability. Develop a process for ongoing monitoring of expected
referrals, evaluations, and eligibility practices. Rather than using a traditional record-review
compliance model, review data with schools so that they are aware of problems, and they are
better prepared for follow-up action. Enable staff to observe best practices and receive
109

coaching that will improve their knowledge and skills. (Coordinate this activity with
Recommendation 2h.)
5. Expansion of Inclusive and High-Quality Instruction and Supports for Students with
Disabilities. Begin increasing the provision of effective and inclusive special education
services. To expedite this process, consider using an experienced consultant who has had
successful outcomes in this area to help facilitate planning and implementation.
a. Inclusive Education Vision and Board Policy
• Retreat. Have the district’s MTSS leadership team plan a day-long retreat for stakeholders
(including the ATF) on establishing a vision of inclusivity and quality instruction for
Discussions should include but not be limited to:
- School culture for ALL students (including those in specialized classes and centers);
growth mindset; people first language; etc. Have discussions around the prevalent
perception that “special education” will solve academic and behavioral issues, and
what’s needed to mitigate the “remove them from my class” mentality.
- Address the interaction between IEP decision-making for student placement and
school-based models for effective instruction. Until such models and training on them
are in place, IEP teams will be unlikely to consider inclusive settings to be realistic for
students who are otherwise being educated for a substantial period in separate
classrooms.
- Identify and involve exemplar schools that are practicing this inclusive culture to share
their frameworks, practices, results etc.
• Board Policy. Establish a school board policy stating a clear and defined vision for APS
on the value of inclusivity that reinforces the district’s commitment to improving academic
achievement and social/emotional well-being for students with disabilities.
- Highlight the importance of collective central office and zone support, and principal
leadership in providing students with IEPs the differentiated and scaffolded instruction
they need to learn in general education settings.
- Expect that students will receive rigorous core instruction that is linguistically
appropriate and culturally relevant. These expectations should be within reach when
school personnel are provided the resources they need and as teachers become more
familiar with instruction based on the principles of UDL.
- Ensure the district’s vision emphasizes the importance of evidence-based academic and
positive behavior interventions/supports.
b. Implementation Plan. With staff from the multidisciplinary team assembled pursuant to
Recommendation 2b, develop a written multi-year action plan that calls for written
expectations, professional learning, data analytics, and accountability.
- To the extent reasonable, link components in the MTSS implementation plan
referenced in Recommendation 2c. Incorporate the data review proposed in
Recommendation 4. Once the plan is complete, establish ways for school-based teams
to embed local implementation activities into their school improvement plans, e.g.,

90-day plans.
- Volunteer School Cadre. Identify a volunteer cadre of schools to lead in planning and
implementing inclusive service models. Provide each school a small grant with a
template for action planning.
- Phase in this process over about five years to include all schools.
- Identify general and special education personnel who schools can contact to support
their implementation efforts to better meet the needs of students with IEPs.
- Support planning and implementation with professional development based on
information that becomes available in implementing Recommendation 5.
• Collaboration with Higher Education. To the maximum extent possible, collaborate with
current/new higher education and other partners to involve them in this process and
strengthen district capacity. Encourage partners to offer training through their own
programs or other mechanisms as APS engages in this endeavor.
• Feedback. Collect feedback on the draft improvement plan from stakeholders at varying
grade levels and from special/general education administrators, principals, general/special
education teachers, related-service providers, teacher assistants, parents, and community-
based organizations. Continue this feedback loop as the plan is implemented in order to
identify and address concerns.
• Communication. When finalized, post the implementation plan on the district’s website,
along with relevant links to district information and publicly available resources.
Communicate the plan widely to all internal and external stakeholders, including parents
who are English learners, and share the purposes and expected outcomes of the plan.
• Components. When developing the implementation plan, have activities that include but
are not limited to the following—
• Early Childhood. Increase the number of children educated inclusively in regular
preschool classes--with no more than 50 percent and close to 30 percent of classes
composed of children with disabilities. The Council team can provide APS with names of
other school districts that have done this effectively. When more children are successful in
inclusive classrooms, there will be higher expectations for continuing these opportunities
in kindergarten, and spur high-quality education for students with disabilities.
• Differentiated Instruction. Provide for linguistically appropriate and culturally competent
instruction aligned with core standards, differentiated for students with reading and math
performance significantly below those of their classroom peers.
• Effective Instruction Based on Core Curricular Standards. Improve instruction aligned
to core curricular standards and expand increasingly intensive interventions, especially in
literacy and math, to reinforce standards-based instruction. Reconcile the different
instructional materials currently used by general and special educators.
• Supplemental Interventions. As addressed in Recommendation 2c, ensure that students
with disabilities can access Tier 1 and 2 interventions along with Tier 3 interventions
whenever they are appropriate to meet their needs.

• Planned Collaboration. Set expectations that general/special educators, paraprofessionals,

and related service personnel will collaborate in providing instruction and interventions for
students they have in common.
• Positive Support for Behavior. Enhance supports for teachers who work with students with
challenging behavior to increase their time engaged in teaching and learning.
- Identify and expand the number of personnel available to observe classrooms, model
effective practices, and coach in schools with no other internal expertise.
- Address the numerous issues associated with APS’s process for requiring FBAs/BIPs;
have the APS/ATF facilitator address FBA/BIP issues of concerns, including those
described in this report; and identify a group of stakeholders to work with the facilitator.
- Ensure that personnel who have expertise or knowledge of issues associated with
students whose behavior adversely impacts learning are integrally involved in the
reform process, e.g., BCBAs, redirectors, social workers, psychologists,
general/special educators, EAs, etc.
• Criteria/Guidance. Revise criteria and guidance for when FBA/BIPs are required and
when they are to be considered. Ensure the guidance and forms are user-friendly, effective,
and workable.110 Align requirements with those established under IDEA and New Mexico
code. Identify best practices in FBA implementation, and build them into guidance along
with explanations.
• Social Work. Remove the requirement for an FBA/BIP to initiate/maintain social work
services through an IEP. The Council team is aware of no federal or state requirement for
this standard in APS or anywhere else. The district could easily be using either formal or
informal procedures, such as classroom observations, social work assessments, or outside
evaluations rather than FBAs to demonstrate a student’s need for this service. In addition,
do not link a social work assessment to “least restrictive environment (LRE).”
• Placement. Consider an FBA when determining if a student requires a more restrictive
placement. Various protocols are used by Council member districts in making this
determination, and they can be provided upon request.
— Various Formats. Establish various FBA/BIP formats that can be used based on the
intensity of student needs, e.g., practical versus comprehensive.111 The provision of a
practical FBA should not be based on a student’s disability status and should be
available to assess students with/without IEPs.
— Technology. Ensure that FBA/BIP electronic templates are working properly.
— Personnel. To the maximum extent possible, rely on individuals who have graduate
training in the development of FBAs to guide or engage in comprehensive FBA
assessments.
- English Learners with IEPs. Bring together personnel from the English learner and special
110
Upon request, the Council team will seek and share models of FBA/BIPs and guidance that have been user
friendly/legally sufficient in other districts for consideration.
111
For example, see the PBIS website discussing ‘practical’ and ‘comprehensive’ FBAs, retrieved from
https://www.pbis.org/common/cms/files/Forum12/A6_Loman_Strickland.pptx.

education departments, along with others with instructional expertise, to develop

intervention models for ELs with disabilities. Based on a review of current models, identify
best practices in the implementation of special education and language acquisition
strategies.
• Flexible Service Delivery Models. Identify effective approaches for supporting students in
general education classes using flexible service models. Such models should 1) improve
teaching/learning of students in general education classes using a flexible service delivery
model; 2) expand options for students who would otherwise attend specialized programs
to receive instruction in general education classes; and 3) support English learners with
IEPs to address their language acquisition needs as well as their instructional needs related
to their disabilities. To support implementation of these models, address the following –
— Improving and expanding high-quality co-teaching, including using UDL strategies;
— Providing effective supplemental interventions inside or outside of general education
classes with flexible groupings of students with common intervention needs, and
adjusting the groups based on changing in student needs.
— Explaining how to “count” students with IEPs educated in general education for a
significant amount of time but less than 80 percent of the day;
— Improving master schedules by sharing models that schedule activities for students
with disabilities first, using schools that have been successful in this area.
— Scheduling common planning time for special and general educators who work with
the same students.
• Specialized Program Configurations, Instruction and Support. Review APS’s
specialized program offerings to assess whether the district needs eight different
specialized programs (in addition to cross-categorical services). 112 Also, address issues
raised during the Council team’s review, including those listed below.
— Ensure that various service models have names that are user-friendly.
— Ensure curricular materials and instructional practices are sufficiently rigorous and
meaningful, and strategies are in place that result in students progressing academically.
Ensure students receiving instruction based on alternate standards are using appropriate
materials, e.g., Unique Learning Systems, rather than materials designed for instruction
aligned with Common Core State Standards, e.g., Ready/I-Ready.
— Address APS’s funding methodology for special and general education to remove any
barriers for students in specialized programs to access general education classes; 113
— Review custodial staff assignments to ensure they consider disability-related school
cleanliness issues;
• Class Composition and Age Rages. Establish thresholds for the maximum number of
112
See for example, the Chicago Public Schools’ configuration of services at
https://www.cps.edu/odlss/Pages/ServicesandPrograms.aspx.
113
If necessary, consider implications of state funding and any need to lobby for changes to promote inclusive
instruction.

students with IEPs (excluding those with speech/language services only) in general
education classes, maximum class sizes for specialized programs, and maximum age
ranges for specialized classrooms. Identify schools that have classrooms exceeding these
thresholds. Based on these data, have associate superintendents and principal support
administrators (general/special) work with principals to problem-solve and make changes.
• APS Centers. Within a reasonably short period, establish the two APS centers that enroll
only students with disabilities as schools. Consider the fiscal/programmatic efficiency of
having two principals for a small number of classes and students and the possibility of
having one principal overseeing both schools. Have the principal(s) directly report to one
(or two) zone associate superintendent(s) with continued support from and interaction with
the special education department.
c. Written Expectations. As part of the implementation plan from Recommendation 5b, develop
written expectations on each plan component. (Coordinate and link with Recommendation
2e.) Prior to finalizing any written expectations/guidance and forms, establish a reasonable
period to obtain and take into consideration feedback from stakeholders, including the ATF.
Also, pilot guidance/forms prior to finalization with volunteer personnel to eliminate any
unintended consequences.
d. Differentiated Professional Learning and Parent Training. Embed in the professional
development curriculum content needed to carry out Recommendation 5. (Coordinate and
link with Recommendations 2f and 3e.) Embed into instructional rounds indicators on
implementing plan components. With multi-disciplinary representatives on the district’s
MTSS leadership team (Recommendation 5b), map out the professional development
curriculum and specify which stakeholders are the main audiences for the professional
development. Consider an annual conference to showcase exemplary school practices,
information, etc. Planning needs to include but not be limited to the following –
• How training will be provided using a multidisciplinary and interdepartmental approach,
so that professional learning to promote inclusive education is not viewed solely as a
“special education” initiative;
• The provision of compliance information through an instructional practice lens;
• Content, mode of delivery, time/frequency, communication of training, follow-up
activities, etc. To the extent possible, have training provided at the school level through
professional learning communities, and through blended learning;
• Written materials that support training and follow-up via web-based postings;
• How all stakeholder groups will be included, e.g., principals, general and special educators,
clinicians, EAs, parents, etc., and how training information will be relevant and
differentiated for specified personnel;
• How and when all personnel will be trained in each critical area, and any need for
substitutes and/or stipends for out-of-school time;
• How key information will be communicated effectively, including the use of on-line
training for compliance issues that are more routine in nature;
• What additional modeling, coaching and supports may be needed;

• Principal leadership training necessary to maximize and leverage inclusive and high-
quality instruction and supports, including training on flexible uses of school-based
budgets to expand inclusive education;
• Ongoing training needs for new personnel;
• Involvement of ATF, higher education partners, and parents, etc. 114
In addition, keep in mind issues raised by focus group participants, including the need for the
training webpage to provide accurate information for targeted audiences; classes filling up
quickly during the school day and variability of principal approval; reliance on a “train the
trainer” model when principals cannot afford trainers to inform school-based personnel; etc.
e. Data Analysis and Reports. With the multidisciplinary team assembled in Recommendation
5b, identify data and charts such as those included in this report as well as others that are
necessary for district, zone, and school personnel to problem-solve, strategize, and proactively
carry out their responsibilities.115 Based on these data, develop standard user-friendly reports
that inform progress at various levels of the district. In addition to activities proposed in
Recommendation 2g and 3e, embed in the 90-day plans the types of data needed to better
target patterns and areas of concern. Use risk ratios to better understand district practices and
their effects.
f. Monitoring and Accountability. Expect all principals to oversee special education in their
buildings and hold them explicitly accountable for such. Articulate how cohort principal
leaders will work with their principals and how they will ensure principals are serving students
with disabilities. Embed the following activities into the monitoring and accountability
systems described in Recommendations 2h and 3f.
• Data Checks. Include information on students with disabilities in data discussions to
inform follow-up actions and track outcomes. Ensure that data includes all SPP indicators.
• Fidelity Assessments and Instructional Rounds. Review tools used for instructional
rounds and revise them as needed to monitor instruction/interventions being provided to
students with disabilities in general education classes, resource classes, specialized
program and cross-categorical classes, and centers. Initiate technical assistance,
professional development, coaching, and mentoring to improve practices based on the
results of rounds.
• Timely Communication and Feedback. Establish a process for timely feedback to the
district’s MTSS leadership team on barriers to effective inclusive education.
6. Parent Support & Engagement. Improve APS’s engagement with parents/families of children
with disabilities to expand their involvement in schools and support of their children’s
education.
a. District Parent Advisory Council. Work with a broad range of parent representatives from all
114
For parents, see Recommendation 6a.
115
See, e.g., achievement data (exhibits 3a-I,3x); suspension data (3p, 3r); educational environments (3j-o, 3p);
attendance (3t), special program configurations (3p-u, 3w, 3z, and 3bb), percentages of students with IEPs by
school; and other relevant data, such as average and outlying class sizes and age ranges, total days students are
suspended, and dropout rates for students with/without IEPs.

zones and various community-based organizations to design an effective districtwide advisory

council, hosted by the special education associate superintendent, to collaborate with the
special education leadership on various aspects of zone-based parent advisory committee
meetings. Have the parent council include representatives from each of the zones and ensure
they reflect a variety of student/parent needs. Have the parent council address the manner in
which APS meets state requirements and can reach out most effectively around the frequency
and timing of zone meetings; the content of meetings; processes for addressing parent
questions; zone meeting notices; and their attention to parents who are English learners or
who have sensory disabilities; child care; refreshments; time of day, etc. Furthermore, have
the parent council review the professional development curriculum described in
Recommendation 5d and give feedback on topics of interest to parents.
b. Parent Conferences. Consider having one or two districtwide parent conferences during the
year.
c. Presence of Associate Superintendent. At regular intervals, have the special education
associate superintendent attend the zone-based parent advisory committee meetings to have a
visible presence and address parent concerns.
7. Interdepartmental Collaboration. Specifically charge senior staff in all central office
departments with collaborating with each other to support teaching and learning for students
with disabilities. Hold them accountable for that collaboration. In addition--
a. Collaborative/Inclusive Discussions and Deliverables. Ensure all central office, zone, and
school decision-making affecting teaching and learning includes special education/related
services personnel. Have department representatives from special education and the English
learner unit meet regularly to address responsibilities for English learners who have
disabilities. Charge staff with developing and implementing models of effective instruction
and supports for English learners with IEPs. (Coordinate with Recommendation 5b.)
Planned Interaction. Have the deputy superintendent establish a master schedule for all
departments involved in supporting instruction/behavior to meet regularly and facilitate
agendas and act on common concerns and issues, e.g., early childhood, curriculum, instruction,
supports, etc. Develop a template that would identify and guide administrators on such issues
as the discussion of curriculum materials. Plan for regular meetings between the following
department representatives:
• Early Childhood. General/special education administrators to discuss early childhood
curriculum, instructional practices, and expansion of inclusive educational models;
• Personnel Recruitment. Special education, English learners, and human resource
administrators to address personnel recruitment and retention issues (including bilingual
special education/related services personnel) and establish uniform guidance on inter-
school personnel transfers not governed by negotiated agreements, e.g., transfers requested
by related service personnel.
b.. Zone Level Collaboration. Have the deputy superintendent meet with zone associate
superintendents, their respective staff members, and departmental personnel who liaise with
zone associate superintendents and their supervisors. Special education personnel would
include special education associate superintendent, special education school and program

support executive directors, 116 and special education principal support administrators. Have
them discuss better collaboration on regularly scheduled interactions and strategies to improve
teaching/learning for students with disabilities.
Zone Associate Superintendent Administrative Meetings. Have the special education
principal support administrators who regularly attend zone associate superintendent’s
meetings to acknowledge positive trends and leverage resources needed to address patterns
of concern. Prioritize--
— Reviewing school data on issues delineated in this report and other areas relevant to
teaching and learning for students with disabilities (as well as MTSS);
— Developing strategic actions with principals having common issues and individual
principals having unique issues. Use data to inform issues.
— Developing professional learning for cohort personnel based on Recommendation 5d
(as well as 2f and 3d).
— With a standard protocol, monitor the cohort schools based on Recommendation 5f
(as well as 2h and 3f).
Expected Practices. Have the special education associate superintendent and zone
associate superintendents jointly establish expectations for special education
administrative practices and do the following –
— Zone Principal Meetings. Expect regular special education principal support
administrator and periodic associate superintendent attendance at principal zone
meetings and expect attendance by center principal(s).
— School Visits. Establish schedules for special education personnel (e.g., principal
support administrators, program support administrators, etc.) to routinely visit assigned
schools. Expectations for these schedules need to be realistic, given the number of
assigned schools.
— Instructional Rounds. Expect principal support administrator participation in
instructional rounds. As part of this process, ensure instructional round protocols
include observations of specialized classes.
c. Cross-Functional Training. Conduct cross-training of personnel from different departments to
ensure that essential information is provided to all principals, leadership teams, and teachers.
As more general educators are expected to demonstrate differentiated instruction and other
strategies normally reserved for special education, then special education administrative
personnel can support activities requiring a higher level of expertise.
8. Special Education Department Organization and School Support. The following
recommendations are designed to enable special education department personnel to more
effectively assist principal leaders and school personnel to support teaching/learning.
a. Student Achievement Executive Director Oversight. The following changes are offered for
APS’s consideration. The Council team believes that these changes--with additional input from
special education leadership—could make reporting lines clearer and easier for central office,
116
See Recommendation 8 for recommended school and program support directors.

zone, and school-based personnel to understand. These changes apply to the student
achievement executive director’s direct reports. (See Exhibit 4j.)
Have three directors 117 report to the student achievement executive director, one each
responsible for school support, program support, and related services support. This would
require one more administrative supervisory position. Have each administrator be responsible
for the following –
• Principal Support Director. Have the eight principal support administrators oversee the
IEP specialists (with elementary administrators) and cross-categorical services. If possible,
hire two more BCBAs and assign one to each zone.
— Role. Have the principal support director with assistance from principal support
administrators support the zone associate superintendents and principals to improve
teaching/learning and promote effective inclusive instruction and behavioral support.
— Principal Support Administrators and Related Services. Remove from the principal
support administrators’ responsibilities the 10-to-15 related-services personnel each
supervises. This would give administrators more time for school visits; support for IEP
specialists and head teachers; and development of indicators on cross categorical
services with support aligned to these indicators.118 These changes would alleviate the
unreasonably large spans of control currently assigned to lead principal support
administrators and principal support administrators.
— Head Teacher Liaison. Have the head teacher liaison report to the principal support
administrator (instead of the compliance executive director) to reinforce the
instructional aspect of the head teachers’ role. Have the principal support director,
compliance executive director, and head teacher liaison collaborate in their support of
head teachers.
• Program Support Director. Have this position supervise personnel who support
specialized programs, along with transition programs, extended school-year, and
homebound initiatives. Currently, 10 program support personnel are used to engage APS’s
specialized programs. Determine whether this number is sufficient to visit school
programs, develop indicators for high quality instruction, and support instruction aligned
with these indicators. Have program support personnel with relevant expertise support the
programs to which they are assigned.
• Related Services Support Director. Have three liaisons report to the director – one each
for psychologists/social workers; occupational therapy, physical therapy, adapted physical
education; and nursing.
— Role. Coordinate with the evaluation/related services executive director 119 on the hiring
and development of liaison role/ responsibilities and authority.
— Oversight. Establish relationships between liaisons and principal support
117
The term director is being used for descriptive purposes. APS may decide to use a different administrative level
for this position.
118
See Related Services Support Director for supervision of related services personnel.
119
Have the executive director continue to oversee assessments at centralized evaluation centers.

administrators to provide additional support for related services personnel assigned to

schools within their zones. However, have the related-services support director in
combination with their liaisons be primarily responsible for supervision of related-
service providers in the field. Establish administrative positions for the liaisons to meet
personnel evaluation requirements—if necessary.
— Regular Meetings. Have liaisons meet regularly with their respective service providers
in interdisciplinary settings to provide opportunities for cross-talk, discussions of
relevant issues, and training. Initiate discussions with PED representatives to ensure
that any logging requirements do not interfere with meetings, discussions, and other
activities involving non-caseload matters.
— Review of Centralized Evaluation Centers. Consider whether the special education
evaluation process could be returned to schools and operate in compliance with
required evaluation-time frames. Although the centralized process is generally
effective, it has resulted in the removal of personnel from schools. Consider hiring an
outside consultant knowledgeable of the evaluation process to review APS’s model and
develop other options.
• Removal from Executive Director’s Oversight. To align administrative work more closely
with school-based operations and normal principal reporting lines, remove the following
reports from the student achievement executive director’s oversight:
— Support Assistant Principals. Have the 10 support assistant principal positions
currently assigned to schools with large numbers of specialized-program classes report
instead to the principal at each respective school. Have indirect reporting relationships
with the program support administrator to provide feedback about programmatic needs.
Have each principal make the hiring decision on his/her support assistant principal,
with input from the student achievement executive director.
— Special School Principal(s). As discussed above, establish the Aztec and Highland
complexes as schools with one or two principals who would report to one or two zone
associate superintendents. This would enable school administrators to discuss with
peers and zone associate superintendents issues related to school management,
instruction, etc. Expect principals and program support administrators to collaborate
and continue the special education department’s current level of support for specialized
schools.
• Related Operational Activities
— Feedback/Communication. Review and obtain feedback about the proposed special
education department recommendations with zone associate superintendents and other
stakeholders. Upon finalization of changes, post the organization chart on the special
education and district website.
— Functional Directory. Develop a functional directory of the new organization that
clearly describes who to call/email for information based on subject areas of interest or
need. Base the directory on a pyramid of support, starting at the school level, moving
to the zone, and then to the central office. (Include general education resources that
may also be available.) Update this information as personnel change. Until changes are
made, post the organization chart currently in use on the special education webpage.

When finalized, post the functional directory on the district’s website and other venues,
and distribute it broadly to stakeholders.
— Clear Lines of Oversight. Have a clear written roadmap to show how information is
expected to be communicated consistently from special education to the field. Include
direct supervisory lines and explain how they interface with indirect reporting lines.
This product should communicate decision-making authority within the special
education department, and to zones and school personnel.
b. Operational Changes.
• Caseload Entry. Have the human resources department and the finance and special
education offices review the current process to validate school-based services and the FTE
data submitted by schools for the state. Determine whether this degree of centralized
review is necessary. Instead, consider additional training and monitoring of schools that
have had relatively low-quality data entry, and hold schools accountable for the entry of
reliable data. This change would free up the director from entering these data and allow the
director to address other pressing issues.
• Full-Day Special Education Leadership Meetings. Have the superintendent meet with the
special education associate superintendent to review the content of the associate
superintendent’s weekly day-long meetings with staff to discuss its purpose, deliverables,
utility, etc. Consider ways in which a weekly two- to three-hour meeting could address
essential activities. Have the associate superintendent delegate more decision-making to
her leadership team and hold them accountable.
9. School-based Special Education Support. Strengthen principal leadership and oversight
of special education. Add new personnel support for special education administration and
operations if necessary.
a. Principal Leadership. Have the deputy superintendent facilitate a team to develop principal
leadership training that would focus on their oversight of special education and inclusive
instruction/behavioral support. Consider having principal professional learning communities
handle this subject. Identify the knowledge principals need that should be incorporated into
additional training opportunities.
b. IEP Specialists, Head Teachers, and Special Education Assistant Principals. Although
principals have primary oversight for the operation and administration of special education,
they also need to delegate much of that responsibility. To succeed, personnel should have the
training and time necessary to carry out their responsibilities. These responsibilities include
but are not limited to ensuring the timely flow of processes related to the SAT, child find,
eligibility and IEP team meetings, development of high-quality IEPs, support for more
inclusive and effective instruction, compliance, meeting with school personnel, parent support,
complaint/due process coordination, coordination between special education department
personnel and principals, etc. These activities affect teaching and learning for students with
disabilities and district adherence to multiple federal, state, and local requirements.
With stakeholders, including principals, head teachers, IEP specialists, special education
administrators working with head teachers and IEP specialists, along with ATF leadership,
consider the following recommendations to improve critical school-based positions.

• Head Teacher for All School Levels. Establish a head teacher role or position for all grade
levels to provide for a common set of expectations, training, and support.
— Role and Responsibilities. Establish clear written expectations for head teachers’
roles/responsibilities and principal’s support and engagement with head teachers.
— Criteria for Position Options. Consider the various options below for head teachers.
Establish criteria for options, and base them on such factors as number of students with
IEPs, instructional/behavior needs of students, specialized programs, etc. Possible
future options include:
o Full time position
o Annual stipend
o Reduced caseload
o Clerical support (perhaps with a stipend for current school clerks or hiring of
part-time clerks)
• Rationale for Change to IEP Specialist Position. Effective special education
administration/operation requires personnel who are housed at each school. This enables
personnel to know school staff, students, and parents, and generally be available to address
critical issues. The funds from the IEP specialist positions and IEP liaison position can be
applied to the head teacher options listed above. This change could help address the number
of APS’s special education teacher vacancies.
• Special Education Assistant Principals. As discussed above, hire or deploy assistant
principals to support the administration/operation of special education.
c. Student-Staff Ratios. Have the deputy superintendent, senior special education executive
director, and finance personnel review staffing ratios summarized in this report (see Appendix
A) and other caseload data. NOTE: Relatively low or high student-to-personnel ratios in
Appendix A do not necessarily mean that an area is staffed inappropriately. However, outlier
ratios should prompt further review. Review caseloads to ensure that adequate numbers of
special education and related-services personnel are at each school to carry out their expected
responsibilities. Based on a full review, consider changes needed short and long term. In
addition, have the group collect data showing caseloads and workloads for special educators
and ancillary staff to identify those exceeding the norm and monitor.
d. Miscellaneous Related Service Personnel Issues
• Nonspecial Education Funds. Expedite the use of operational funds for social workers,
speech/language pathologists, school psychologists, and other personnel areas so they can
be used to support students.
• School Psychologists. The low FTE numbers of school psychologists raises concerns.
Even though their role is supplemented by educational diagnosticians, these professionals
are assigned to centralized evaluation centers. School psychologists have unique graduate
training that would provide value to school personnel, such as support for students with
significant behavioral issues, SAT processes, FBA/BIPs, etc. Consider options for
increasing the number of school psychologists, including those who are bilingual.
• Allocation to Schools. Take specialized program demographics into consideration when
allocating social workers and other ancillary staff.

• Telepractice. Take steps to ensure that students receive speech/language pathology

services through telepractice in accordance with guidelines of the American Speech-
Language-Hearing Association (ASHA). 120
• Logging Services. Confirm with PED its directive for logging ancillary services (every 15
minutes), whether it is currently in effect or will be in effect in the future. Advocate for
elimination of the requirement.
• Special Education EAs. Consider commissioning with ATF a survey of EAs to more fully
understand barriers to their effectiveness. Act on the findings.
e. Special Education Related Shortages. Create a sense of urgency with the human resources
department, ATF, the special education unit, bilingual personnel, and finance staff around the
need to develop and implement a more aggressive and coherent personnel recruitment and
retention strategy for the district. Meet regularly to review data on identified shortage areas.
Explore external resources that could help fill hard-to-find special education-related vacancies.
Also address the following by--
• Expanding recruitment options and additional funding for recruitment purposes;
• Improving APS’s position management system;
• Having human resources resume prescreening of applicants to facilitate principal review
and selection by:
• Prioritizing the filling of vacancies in programs having students placed by the district, i.e.,
in highly intensive/specialized classes;
• Communicating better with EAs about the career pathways program;
• Stopping intra-APS transfer practices during the school year, which would require
• Increasing salaries in personnel areas with compensation significantly below neighboring
districts (particularly for EAs) to discourage transfers to other districts. Establish signing
bonuses to encourage new hires in high shortage areas. These options would require
• Addressing retention practices, including initiation of new-teacher mentoring, that includes
special educators, ancillary personnel, and educational assistants;
• Establishing incentives for general educators who hold special education certifications to
become special educators. This would require discussions and negotiations with ATF;
• Having centralized onboarding support for new teachers, including support for new special
educators from the Philippines.
• Ensuring program support teachers assist special educators teaching under the alternative
licensure program have the capacity and time to be effective;
10. General Compliance Support, and Data and Fiscal issues. Consider the following actions
to improve compliance; address data issues; and enhance revenue.
120

a. Compliance Support. Increase support for activities that include the following –
• Special Education and Section 504 Standard Operating Procedures Manuals. Expedite
the development of electronic manuals on special education and Section 504. Include
written expectations associated with Recommendations 3c and 5c. Incorporate information
on the FBA/BIP process. Establish the manuals as webpages with user-friendly summaries
with links to more detailed information and public resources. Collaborate with stakeholders,
including parents, to identify useful publicly available resources and links. Ensure staff
members are available to update information regularly. Provide training to stakeholders
and parents to boost their understanding of core elements of special education and Section
504. Place this information on the webpages. Ensure training is accessible to parents with
diverse linguistic needs and sensory limitations. 121
• Legal Support. Strengthen compliance by taking actions like the following –
— Unified Representation. Have a single legal firm or in-house counsel represent all
special education related legal assistance. Suggest counsel actively engage with the
Council of Great City Schools’ legal counsel meeting next October in Louisville.
— Collective Bargaining Training. Have an attorney regularly provide to all special
education department personnel information on the collective bargaining agreement
and their obligations under it. Hold staff accountable for adherence to the agreement.
Repeat this process with new staff and all staff with new issues as they arise. Record
webinars or videos and post them on the website.
— Order of Manifestation Determinations and Impartial Discipline Hearings. Have
legal counsel review the district’s flow chart on students with disabilities having long-
term disciplinary removals and consider holding manifestation determinations PRIOR
to any disciplinary expulsion hearing (unless the behavior related to the use of a
weapon, drugs, or infliction of serious bodily injury).
— APS Attorney Fees for Due Process Hearing Requests. With special education
leadership, legal staff, and finance personnel, review Exhibits 4d and 4e and examine
fees paid for APS legal representation in due process hearings compared to plaintiff
attorney fees. Develop actions to reduce the number of hearing requests and the
generation of attorney fees. Consider using special education personnel to manage due
process hearing requests that are not complex, are easily resolved, and may not involve
a parent or district attorney.
• IDEA Annual Compliance Determination
— 80th Day Data to PED. As part of APS’s special education discussions with PED,
address the agency’s decision to obtain from school districts 80th day data that requires
attention a day or so after winter break. 122
— Other Activities. Have the joint APS/ATF external consultant discuss issues related
APS’s designation by PED as “needs intervention” for the fourth time. Include
121
122
Because the district must resolve issues involving students who are mutually reported by APS and other districts,
this time frame is difficult if not impossible to meet.

discussions of delayed evaluations and untimely/inaccurate data. Consider current

actions and what the district could be doing to improve compliance.
• Professional Learning. In implementing Recommendations 3d and 5d, incorporate into
training the necessary steps to address compliance issues on PED complaints, due process,
Office for Civil Rights complaints, and IDEA annual compliance determinations.
b. Fiscal Issues. Pursue the following activities to enhance revenue and shift more funds to boost
high-quality education in both inclusive and separate classes.
• Medicaid Documentation. Expedite the use of Synergy for ancillary personnel like nurses
to track service delivery. Review potential revenue based on charter school Medicaid
billing to determine APS’s return on investment. If the return is beneficial, take actions
necessary to carry out this activity.
• Transportation. Ensure that students with IEP-required EAs receive this service and that
protocols are in place for such IEP decisions. Ensure that processes are in place for schools
to provide supervision of students during early drop off and late pick-ups. To the extent
feasible, link IEP and transportation systems to reduce transportation delays and make
routing more efficient.
c. Data Collection and Reporting. In coordination with Recommendations 2g, 3e, and 5e, address
the following on data collection and reporting –
• Data/Information Coordination. Have a protocol in place for coordinating data and
information collection from all involved departments and personnel.
• IEP System. Have special education leadership with zone, school, and technology
representatives review IEP systems available in the market place and compare them with
APS’s current system. Evaluate usability, data collection, ease of reporting, special
education management, and ability to migrate data to the student information system and
IEP system. Use this information to determine if the benefits of a new system outweigh
maintaining the current system.
• Special Education Records. Develop a plan for 2019-20 to have schools maintain their
own special education records. Address how schools can respond to record requests and
record transfers. The Council team can share contacts with other large urban school
districts that maintain school-site special education records.
d. Monitoring and Accountability. In coordination with Recommendations 2h, 3f, and 5f –
• 90-Day Plans. Have processes in place to ensure that school-based 90-day plans
consistently address issues related to students with disabilities and that
achievement/behavior data are disaggregated by disability status.
• Academic Master Plan. Ensure that data associated with Academic Master Plan indicators
are disaggregated for students with disabilities and English learners with disabilities.
superintendent monitor activities associated with the Council-team’s recommendations. Have
the project manager coordinate reports to the superintendent and cabinet, the status of
implementation, barriers to execution that require interdepartmental collaboration, and any
need to adjust planning and expectations.

APPENDICES
Appendix A. Incidence Rate and Staffing Ratios
The Urban Special Education Leadership Collaborative and the Council of the Great City
Schools, including its team members who have conducted special education reviews, collected the
data reported in these tables. The data do not give precise comparisons, so the results need to be
used with caution. District data are not consistently reported (e.g., some districts include
contractual personnel and others may exclude them) and the numbers are sometimes affected by
varying placement types used by a school district. The data may count all students with IEPs,
including those placed in charters, agencies, and nonpublic schools. Still, these data are the best
available and are useful as a rough guide to staffing ratios.

Incidence of Students with IEPS and Personnel Staffing Ratios (Fall, 2018)*
% IEPs of All Speech/Lang
Sp Ed Teachers Paraeducators Psychologist
Students Pathologists
# IEPs % IEPs Number Ratio Number Ratio Number Ratio Number Ratio
Agawam Public Schools 656 15% 39 17 100 7 15 44 3 219
Atlanta Public Schools 4,950 11% 431 11 224 22 65 76 22 225
Albuquerque Public Schl 16,738 20.4% 1217 13.8 1290 12.98 161.5 103.6 97.6** 171.5
Anchorage School Dist 6,779 14.1% 716.8 9.5 786.4 8.6 65 104 44.7 151
Arlington VA Pub Sch 2952 13.9% 343 8.6 262 11 38 77 22 134
Austin Pub S D 9,450 11.7% 802 11.8 912.8 10.4 88.7 107 54.5 173
Baltimore City Publ Sch 12,719 16.5% 999.5 12 429 21 92 140 NA NA
Baltimore County P Sch 12,127 11.4% 1025.4 11.8 2305 29.6 187.5 92 145.7 87
Boston Public Schools 10,478 19.9% 1293 8.1 1104 9.5 133.4 79 63.6 165
Bellevue, WA SD 1,947 10.3% 82.7 23.5 118.6 16.4 17.4 112 17.3 112.5
Bridgeport, CT 2,618 14.3% 204 13 254 10 25 105 33 79
Buffalo Public Schools 7744 16.6% 753 10.3 439 17.6 109 71 62 125
Cambridge Publ Schools 1,200 20% 176 7 103 12 20 60 22 55
Carpentersville, IL 3,139 15.8% 227 13.8 380 8.3 43 73 28 112
Chicago Public Schools 54,376 13.7% 4,649 11.7 4,228 12.9 390 139 261 208
Cincinnati Pub Schools 8,928 17.4% 457 19.5 801 11.1 62 144 57.7 155
Clark Cty School Dist 32,167 10% 2,247 15 1,346 24 299 108 180 179
Cleve Hts- Univ Hts Cty 1,100 18% 83 14 58 19 7 158 8 NA
Cleveland Metropolitan 8,350 21.4% 855 9.8 486 17.2 81 103 82 102
Columbus City, OH 9,727 18.1% 650 15.0 990 9.8 64 152 78 125
Compton CA Unified SD 2981 11.2% 126 28 118 25 5 596 14 213
Dallas, TX 13,470 9.1% 1,078 12.5 868.5 15.5 81 166 37 364
DeKalb 428, IL 879 14.1% 58 15.2 205 4.3 9 98 7.5 117
DesMoines Public Schls 4,854 15.3% 493* 9.8 358.5 13.5 37.3 130 11.5 422
D.C. Public Schools 8,603 18% 669 13 653 14 90 96 78 111
Davenport Comm Sch 1,857 12% 188 10 287 7 NA NA NA NA
Deer Valley Unified SD 3,289 9% 190 18 229 15 49 68 108 31
Denver Public Schools 9,142 12% 592 16 528 18 94 98 98 94
Detroit Public Schools 8,731 16.1% 535.8 16 458 19 98 89 40 218
ESD 112 1,987 14% 55 37 158 13 20 100 12 166
Elgin U-46, IL 5,304 13.1% 252.8 21 288.5 18 71.9 74 20 265
Everett Pub Schools, WA 1,049 17% 74 15 51 21 4 263 5 210
Fort Worth 6,144 8% 520 12 450 14 73 85 31 199
Fresno, CA 8,271 11.2% 509.6 16.2 603.1 13.7 75.5 110 65.7 126
Greenville County, SC 9,894 14% 463 21 376 26 93 106 25 396
Guilford County, SC 10,062 12.8% 575 17.8 448 22.5 127.7 79 52.33 192
Houston Independ SD 15,655 7.3% 3,159 5.0 3,158 5.0 160 98 150** 104
Jackson County FL 2,740 11.3% 193 14.2 89 30.8 25 119 110*** 274
Kalamazoo Pub Schools 1,667 14% 70 24 79 22 15 112 NA NA
Kent, WA Pub Schools 3,069 11.3% 148.7 20.6 318 9.7 32.3 95 25 123
Lake Washington, WA 3,145 11.7% 155.1 20.3 241.5 13.0 32.6 96.5 24.7 127.3
Kyrene School District 1,544 9% 141 11 124 13 27 58 14 111
Lakota Local 1,800 10% 126 15 120 15 39 47 18 100
Los Angeles Unified SD 71,969 13.1% 4900.9 14.7 6019.9 12.0
328 328.2 219 557 129
Madison, WI Pub Schools 3,808 14.0% 347 10.9 448 8.5 86 44 49 77.7
Marlborough Pub Sch 1,198 25% 141 9 115 11 7 172 4 300
Memphis City 16,637 15% 912 19 655 26 53 314 58 287
Miami-Dade 40,012 11% 2,500 17 1,226 33 209 192 206 195
Milwaukee 16,406 20.9% 1281 13 988 16.6 169 80 136 121
Montgomery Cty Sch 17,226 12% 1,588 11 1,398 13 293 59 97 178
Naperville IL 203 1978 11% 150 13 237 8 33 59 22 90
Nashville 10,141 12.3% 680.5 14.9 594 17.1 109 93 65.5 155
New Bedford 2,655 21% 204 14 205 13 26 103 9 295
N. Chicago, IL (in Dist.) 614 16% 39 15.7 27 22.7 8 76.8 5 122.8
Oakland Unified SD 5401 14.0% 404 13.4 175 31 47 115 43.5 125
Oak Park Sch Dist 97 875 16% 78 12 90 10 14 63 8 110
Omaha, NE 10,658 17.0% 477 22.3 NA NA 63.6 168 35.9 297
Orange County, FL 24,385 11.1% NA NA 1,165 20.9 202 121 99.5 245
Pinellas County, FL 14,701 13.0% 881 16.7 774 19.0 150 98 79 187
Pittsburgh Pub Schools 4,210 18.1% 308 13.7 263 16 31 136 16 263

Portland Public Schools 7,168 14.5% 282.5 25.4 414 17.3 99.6 72 59.3 121
Providence, RI 4460 18.8% 340 13 339 13 40 111 28 159
Renton, WA 2,108 14.7% 129 16.3 294 7 20 105 15 140
Rochester, NY 5,472 20% 559.2 9.8 428 12.8 148 37 64 85.5
Rockford IL Pub S 4,065 14% 336 12 334 12 49 83 24 169
Round Rock 3,313 8% 369 9 171 20 41 81 29 115
Sacramento 6,519 13.9% 288.1 22.6 246.2 26.5 33 128 50.8 197.5
San Diego Unified SD 16,300 12% 1,100 15 1,300 13 196 84 129 126
Saugus, MA 462 15% 28 17 29 16 6 77 NA NA
Sch Dist of Philadelphia 33,686 20% 1,535 22 610 56 99 341 100 337
Scottsdale, AZ 2,891 10.9% 246 11.8 230 12.6 39.4 73 28.4 102
Seattle, WA 7,.281 12.5% 548.8 13.3 823.3 8.8 82.2 89 60.2 121
Shelby County (Memphis) 14556 12.7% 852 17.1 768 19.0 55 265 60 243
St. Paul, MN 7,152 18.8% 523 13.7 536 13.3 97 74 19 376
Sun Prairie Area S Dist 697 10% 62 12 93 8 14 50 7 100
Tacoma Pub Schl WA 3,894 12% 172.5 23 223 17 33.6 116 27 144
Tucson Unified SD 8,092 14% 409 20 419 20 61 133 54 150
Washoe County Dist, NV 8,551 14% 472 19 325 27 77 112 37 232
Williamson Cty Schl 2,824 9% 213 13 400 7 34 121 23 178
West Aurora, IL SD 1688 13% 120 14 101 17 21 80 13 130
Worcester, MA 5,172 21% 254 21 366 15 38 137 NA NA
Averages 13.7% 14.1 15.2 119 167
* The Urban Special Education Leadership Collaborative and the Council of the Great City Schools,
including its team members who conducted school district special education reviews, collected the data
reported in these tables. The data do not give precise comparisons, so the results need to be used with
caution. District data are not consistently reported (e.g., some districts include contractual personnel and
others may exclude them) and are sometimes affected by varying placement types used by a school
district. The data may count all students with IEPs, including those placed in charters, agencies, and
nonpublic schools. Still, these data are the best available and are useful as a rough guide to staffing ratios.
** Data includes psychologists and educational diagnosticians.

Occupational
Ratios for Social Workers, # IEPs Social Workers Nurses (School/RN) Physical Therapy
Therapy
Nurses, OTs & PTs
Number Ratio Number Ratio Number Ratio Number Ratio
Agawam Pub Schools 656 NA NA 8 82 3 219 3 219
Anchorage School Dist. 4,950 NA NA 112.8 60 21.9 309 7.8 869
Albuquerque School District 16,738 98.5 169.9 N/A N/A 65.3 256 22.7 737
Atlanta Public Schools 6,779 30 165 58 85 12 413 3 1650
Arlington Pub Schools 2952 15 197 *30 98 20 147 6 492
Austin Pub S D 9,.450 NA NA NA NA 12.6 751 12 760
Baltimore City Public 12,719 194.1 66 NA NA 38 335 11 1156
Baltimore County Pub Sc 12,127 48.7 249 179.8 67 65.2 186 27 449
Bellevue, WA SD 11,534 4 487 13.2 148 5.3 367 5.3 367
Boston Public Schools 1,293 52.1 201 128 82 60 175 21 499
Bridgeport, CT 2,618 38 69 28 94 7 374 2 1309
Buffalo Public Schools 7744 48.5 160 NA NA 75 103 29 267
Cambridge Pub School 1,200 16 75 0 NA 16 75 7 172
Carpentersville 3,139 36.5 86 27.5 114 22 142 6 523
Chicago Pub Schools 54,376 355.7 142 334 151 115 440 35 1445
Cincinnati Pub Sch 8,928 NA NA NA NA 19 470 5 1786
Clark Cty School Dist 32,167 NA NA 173 186 68 474 29 1100
Cleve Hts-UnivHtsCty 1,100 7 158 5 220 2 550 1 1100
Cleveland Metropolitan 37,890 NA NA 69 113 36 216 9 864
Columbus City, OH 9,727 36 270 103 94 43 226 24 405
Compton CA Unified SD 2981 1 2981 1 2981 1.5 1987 .5 5962
Dallas 13,470 7 1924 NA NA 14.5 929 4 3368
DeKalb 428, IL 879 8 110 7 126 3.4 256 1.3 204
DesMoines Public Schls 4,854 25.8 188 58.4 83 7 693 4.8 1011
D.C. Public Schools 8,603 90 96 127 68 48 180 16 538
Davenport CommSch 1,857 NA NA 7 266 NA NA NA NA
Deer Valley Unified SD 3,289 NA NA 37 89 19 174 4 823
Denver Public Schools 9,142 74 124 77 119 25 366 12 762
Detroit Public Schools 8,731 76 115 38 230 31.6 276 10 873
Elgin U-46, IL 1,987 56 95 59.5 89 25.2 210 4 1326
ESD 112 5,304 NA NA 5 398 6 332 3 663
Everett Public Schools 1,049 2 525 11 96 2 525 3 350
Fort Worth 6,144 NA NA 106 58 16 384 10 615
Fresno, CA 8,271 33.5 247 53.1 1156 3 2757 NA NA
Greenville County, SC 9,894 20 495 132 75 14 707 4 2574
Guilford County, SC 10,062 75 134 39 258 24.7 407 11 958
Houston Independence SD 15,655 NA NA NA NA NA NA NA NA
Jackson County, FL 2,740 25 110 BA NA 6 457 3 913
Kalamazoo Pub 1,667 5 334 2 834 4 417 3 556
Kent, WA Pub Schools 3,069 2.2 NA NA NA 12.8 240 4.8 639
Kyrene School District 3,145 NA NA 4 386 2 772 2 772
Lake Washington SD 1,544 NA NA 23.6 133 19.3 163 3.3 953
Lakota Local 1,800 6 300 14 129 8 225 2 900
Los Angeles Unified SD 71,969 361.6 199 590.6 122 189.9 379 41 1743
Madison, WI Public Schls 3,808 68 56 38 100 34 112 13 293
Marlborough Public 1,198 9 134 10 120 4 300 2 599
Memphis City 16,637 55 303 68 245 11 1513 9 1849
Miami-Dade 40,012 NA NA 206 195 65 616 23 1740
Montgomery CtySch 16,406 NA NA NA NA 112 154 61 283
Milwaukee 17,226 140 117 101 162 30 547 13 1262
Naperville, IL 203 1978 27 73 29 68 4 494 3 659
Nashville 10,141 NA NA 57 178 29.5 344 6 1690
New Bedford 2,655 67 40 30 89 11 242 3 885
North Chicago, IL 875 10 61.4 NA NA 3.6 170.5 1.6 383.8
Oak Park Sch Dist 97 614 12 73 8 110 7 1125 1 875
Omaha, NE 10,658 37 288 73 146 NA NA NA NA
Orange County, FL 24,385 67 364 108 226 10.5 2322 7 3484
Pittsburgh Pub Sch 5401 40 105 40.6 104 7 601 8 526
Portland, OR 7,168 14 512 NA NA 20.2 355 5.3 1352

Oakland Unified SD 4,210 19 284 30.8 175 12 450 2 2701

Pinellas County, FLa 14,701 108 136 128 115 56 263 23 650
Portland Pub Schools 6,513 10 652 NA NA 20 326 9 724
Providence 4460 35 127 NA NA 11.5 388 4.5 991
Renton, WA 2,108 0 NA 17 124 15 141 3 703
Rockford IL Pub S 5,472 26 135 32 127 12.5 325 4.5 903
Rochester, NY 4,065 89 61.5 55.5 98.6 29.2 187.4 11 497.5
Round Rock 3,313 NA NA 1 NA 10 332 3 1105
Sacramento 6,519 8 NA 5* NA 2 NA 0 NA
San Diego Unified SD 16,300 NA NA 129 127 40 408 10 1630
Saugus, MA 462 4 116 5 93 2 231 1 462
Schl Dist of Philadelphia 33,686 NA NA 280 121 20 1685 20 1685
Scottsdale, AZ 2,891 NA NA 31 93 13.8 210 3.8 761
Seattle, WA 7,.281 NA NA NA NA 44 165 11 662
Shelby County (Memphis) 14556 66 221 79 184 29.22 498 12.84 1134
St. Paul Pub Schools 7,152 92 78 33 217 36 199 12 596
Sun Prairie Area S Dist 697 8 88 1 NA 5 140 2 349
Tacoma Pub Sch (WA) 3,894 NA NA 1.2 NA 19 205 11 354
Tucson Unified SD 8,092 26 312 53 153 10 810 4 2023
Washoe Cty Sc Dist 8,551 NA NA 35 248 12 713 7 1222
West Aurora SD, IL 2,824 19 89 7 241 11 154 7 241
Williamson Cty Schl 1688 NA NA 37 111 22 187 5 819
Worcester 5,172 NA NA NA NA 12 431 5 1035
Averages 247 164 361 968

Percent Students with IEPs of Total Enrollment & Students with IEPs to Staff Ratio in Ascending Order
Special Speech/Lang Social Occupational Physical
Rank % IEPs Paraeducators Psychologists Nurses
Educators Pathologists Workers Therapists Therapists
1 8% 7 4.3 26 31 26 58 64 128
2 8% 7 5.26 37 55 40 60 75 172
3 9% 8.6 6.3 44 64 56 62 103 219
4 9% 9 7 44 77.7 61 64 112 241
5 9% 9 7 47 85.5 67 67 140 283
6 9% 9.1 7 50 79 69 68 141 293
7 10% 9.5 7 58 90 73 75 142 349
8 10% 9.8 7 59 94 73 82 147 350
9 10% 9.8 8 59 100 75 83 154 354
10 10% 10 8 60 100 78 85 154 367
11 10.3% 10 8 63 102 82 89 163 384
12 11% 10 8.3 65 104 86 89 171 449
13 11% 10.3 8.5 68 110 88 89 172 462
14 11% 10.9 8.6 71 110 89 93 174 492
15 11% 11 9.7 71 111 95 93 180 498
16 11.2% 11 9.7 73 111 96 94 186 523
17 11.3% 11 10 73 112 105 96 187 526
18 11.4% 11 10 74 113 115 98 18 538
19 12% 11.4 10 74 115 116 98.6 199 556
20 12% 11.7 11 76 117 124 100 205 596
21 12% 12 11 77 121 126 104 210 599
22 12% 12 11.1 78 123 127 110 211 615
23 12% 12 12 79 124 134 111 216 620
24 12% 12 12 80 125 135 113 219 639
25 12% 12 12.6 80 127 140 114 225 659
26 12.3% 12 12.8 80 128 142 115 231 663
27 12.69% 12.5 12.9 81 129 153 119 240 676
28 12.7% 13 12.98 83 130 158 119 242 680
29 13% 13 13 84 134 160 120 256 703
30 13% 13 13 85 138 165 121 276 724
31 13.1% 13 13 89.1 140 170 124 265 737
32 13.7% 13 13 93 142 188 126 285 761
33 13.9% 13 13 95 144 197 127 300 762
34 14% 13.4 13 95 150 221 127 309 772
35 14% 13.7 13 96 151 249 129 325 819
36 14% 13.8 13 96.5 154 284 133 326 823
37 14% 14 13 98 155 300 142 332 864
38 14% 14 13.5 100 155 300 144 332 869
39 14% 14 14 103 159 303 148 344 873
40 14% 14 14 103.6 166 312 153 366 875
41 14% 14 14 104 169 334 155 367 885
42 14% 14 15 105 171.5 384 162 374 900
43 14% 14 15 105 178 487 163 384 903
44 14.1% 14.9 15 106 178 495 165 388 953
45 14.1% 15 15 108 179 525 175 408 991
46 14.7% 15 16 111 195 652 178 413 1011
47 15% 15 16 111 198 673 184 417 1079
48 15% 15 16 112 199 705 186 424 1035
49 15% 15.2 16.4 112 208 195 431 1100
50 15.3% 15.7 16.6 112 210 217 450 1100
51 15.4% 16.0 16.6 114 213 230 470 1105
52 16% 16.3 17 115 218 220 473 1134
53 16% 16.3 17 116 219 241 474 1222
54 16% 17 17.1 117 223 245 477 1262
55 16.2% 17 17.6 121 225 248 494 1309

56 17% 17 18 127 232 266 498 1326

57 17.4% 17.1 18 128.3 233 386 518 1488
58 17.7% 18 18.4 130 240 398 525 1532
59 18% 19 19 133 243 700 547 1553
60 18% 19 19 135 263 834 550 1630
61 18% 19 19.1 136 265 601 1650
62 18% 19 20 137 287 616 1685
63 18.1% 19.5 20 139 295 644 1690
64 19% 20 20 140 300 693 1740
65 19% 20.3 21 144 319 702 1786
66 19.3% 20.6 21 158 337 713 1849
67 19.4% 21 22 172 376 772 2023
68 20% 21 22 192 396 810 2187
69 20% 21 24 218 1029 2574
70 20% 22 25 263 1125 2574
71 20.4% 22.6 26 265 1513 2701
72 20.5% 23 26 314 1685 2941
73 20.9% 23.5 27 341
74 21% 24 31 596
75 21% 24 33
76 21% 37 56
Avg. 13.7% 14.2 15.2 119.2 167.1 247 164 361 968

Appendix B. Data and Documents Reviewed

DATA Collected
• Graduation Rates
• Disability Types
• Absences
• 504 Plans
• Race/Ethnicity
• English Learners
• Special Education Evaluation Timeliness
• Achievement Rates
• Post-Secondary Transition
• NAEP Scores
• Educational Settings
• Students in Various Special Education Programs
• Suspension Rates
• Personnel FTE Numbers
• Attorney Fees
QUALITATIVE INFORMATION
Absenteeism
• Chronic Absence/Truancy Outreach and Intervention Guide
• APS School Attendance Guidelines
Behavior and FBAs/BIPs
• APS objections to PED findings
• PED complaint findings
• FBA/BIP/PBIS training
• FBA checklist, part A
• Addressing Student Behavior Manual
• BIP scatter plot results
• Timeline and background on special education issues in APS
• FBA special education meeting 4-14 handout
• Addressing Student Behavior
• When to Use Functional Behavioral Assessment
• Safe civil Schools, Basic FBA/BIP
• New Mexico BIP Form
• Jan. 5, 2018 Memorandum to ES Principals/Instructional Coaches re: New FBA/BIP
Rollout for 2017-18
• Randy Sprick: Addressing Suspension and Expulsion through a Three-Tiered Model of
Behavior Support
• BIP Flow Chart
• FBA Flow Chart
• December 19, 2016 Memorandum re: Special Education Department Administrative
Bulletin, Process for FBA and BIP for Special Education Students
• March 16, 2018 FBA/BIP Special Education Department Administrative Bulletin

• Functional Behavior Assessment (FBA)/Behavior Intervention Plan Implementation

Checklist
Charter Schools
• Charter School Special Education Support and Compliance Briefing to CGCS Review
Team
• Office of Innovation and School Choice findings re: charter school and corrective action
plan
Compliance
• Oct. 25, 2018 PED Annual IDEA Determination Letter for APS
• Jan. 3, 2018 APS Compliance Agreement for 2016-17 Annual Determination of Needs
Intervention: Year 3
• Due Process Hearing Request Data Request: End of 2016/2017 School Year and 2017-18
School Year
• APS Corrective Plans with PED
• NM Special Education Code
• NM State Systemic Improvement Plan
• Complaint Findings from PED
• Requests for Proposals for Legal Services
• Description of Data Reports to School
Manuals
• Section 504 Guidelines (PED) March 2010
• PED Special Education Guidance
Organization
• Special Education Supervision (excel file) 2018-19
• APS Special Education Organization Chart
• APS Organization Chart
• APS Special Education Meeting Prioritization
• Various APS Special Education Job Descriptions
• Communication Practices
• Principal Hiring Process
• Principal Packet
Response to Intervention
• Various Responses to CGCS Requests for Information
• New Mexico RTI Manual
• R1 CIP Tier 1 (Notated)
• R4 CIP Tier 2 (Notated)
• R5 Follow up SAT Meeting Summary (Notated)
• R10 Student Observation (Notated)
• R11 Dyslexia Characteristics Checklist for Teacher (Notated)
• R12 Tier II Required Signatures for SAT
• SAT Training (SAT Chairs) 2018-19 PPT
School Models
• APS Magnet Schools
• School Models Graphic

Union Related
• Appendix 3 Letter to Supt. Reedy
• APS/ATF Joint Letter Workload
• ATF/APS Special Education Task Force
• Mentor Peer Background Fast Facts
• Peer Mentor APS/ATF PAR Case Study
• May 8, 2018 Prohibited Practice Complaint
• Union Mentor-Peer Article (2018-19)
• Union Prohibited Practice Guide (2018)
• Vote of No Confidence
Miscellaneous
• APS Special Education Survey report, April 2018
• Response to CGCS Request for Information
• IEP Form
• Developmental Preschool Program
• District Supported Reading and Math Interventions
• District Comprehensive Support Programs
• Parent Request (Special Education) Referral Procedures
• Special Education Training
• 90 Day Plans – school examples

Appendix C and D. Draft Working Agenda and Invited Participants

Council of Great City Schools Site Visit - Special Education
Albuquerque Public Schools
September 24 - 27, 2018
Monday, September 24, 2018
4:30 - 5:00 p.m. Meeting with Sam Adams, Esq., Adams Crow Law Firm
5:00 - 5:30 p.m. Meeting with Evelyn Howard-Hand, Esq., Walsh Gallegos Law
Firm
6:15 - 8:15 p.m. Dinner with Superintendent Raquel Reedy and Dr. Richard
Bowman
Tuesday, September 25, 2018 - Rio Puerco Room, City Center, 6400 Uptown
Blvd. NE, Albuquerque, NM 87110
8:00 - 9:00 a.m. Lucinda Sanchez, Associate Superintendent for Special

Education
9:00 - 9:30 a.m. Dr. Madelyn Serna Marmol, Assistant Superintendent of Equity,
Instruction, and Support
9:30 - 10:00 a.m. Todd Torgerson, Chief of Human Resources & Legal Services;
Karen Rudys, Executive Director, Labor Relations
10:00 - 10:45 a.m. Debbie Elder, Executive Director, Office of Innovation and
School Choice; Dr. Joseph Escobedo, Senior Director, Charter
Schools; Amy Chase, Charter School Coordinator, Patricia
Espinoza, SPED Liaison to Charter Schools
10:45 - 11:45 a.m. Amelia Milazzo, Executive Director of Curriculum & Instruction;
Jami Jacobson, Senior Director of Elementary Learning; Senior
Director of Secondary Learning, Jessica Villalobos, Senior
Director, Language and Cultural Equity, Matt Lindsay, Director
Curriculum and Instruction
11:45 - 12:15 p.m. LUNCH
12:15 - 12:45 p.m. Tami Coleman, Chief Financial Officer; Scott Elder, Chief
Operations Officer; John Dufay, Executive Director,
Maintenance & Operations; Royce Binns, Senior Director,
Student Transportation

12:45 - 1:15 p.m. Special Education: Cindy Soo Hoo, Executive Director for
Compliance
1:15 - 2:00 p.m. Bonnie Anderson, Director, Budget, Data, Synergy; Claudia
Gutierrez, Senior Director, Student Achievement; Bernadette
Lucero-Turner, Senior Director, Evaluations and Related
Services
2:00 - 2:15 p.m. BREAK
2:15 - 3:15 p.m. Associate Superintendents: Dr. Gabriella Blakey, Associate

Superintendent for Leadership and Learning - Zone 1; Dr.
Antonio Gonzales, Associate Superintendent for Leadership and
Learning - Zone 2; Yvonne Garcia, Associate Superintendent for
Leadership and Learning - Zone 3; Troy Hughes, Associate
Superintendent of Leadership and Learning - Zone 4
3:15 - 4:15 p.m. Special Education Principal School Support Specialists: See
attached list of participants.
4:15 - 5:15 p.m. Special Education Teachers: See attached list of participants.
5:15 - 6:15 p.m. Parents/Community Members: See attached list of participants.
6:30 - 8:30 p.m. DINNER
Wednesday, September 26, 2018 - Rio Puerco Room, City Center, 6400 Uptown
7:45 - 8:45 a.m. Related Services Providers: Speech and Language Therapists,
Physical Therapists, Social Workers, Nurses, Assistive
Technicians, Orientation and Mobility Technicians: See
attached list of participants.
8:45 - 9:30 a.m. Psychologists, Diagnosticians: See attached list of participants.
9:30 - 10:30 a.m. Special Education Staff: See attached list of participants.
10:30 - 11:15 a.m. Principal Support Specialists: Kenneth Salazar, Sheri Jett, Chris
Sanchez, Sharon Olguin, Rachel Vigil, Katherine House, Gene
Saavedra
11:15 - 12:15 p.m. Labor Partners: Albuquerque Teachers Federation

President, Ellen Bernstein; Kathy Chavez, ATF/EAs; Organizing
& Communications, Marianna Anaya; add 4 more, (add
conference call, if necessary, after site visit) (See attached list.)
12:15 - 12:45 p.m. LUNCH

12:45 - 1:45 p.m. SPED Support Assistant Principals: Felicia Mondragon,

Chaparral; Mary Cade, Sandia HS; Lisa Goodman, Montezuma;
Anna Phillips, Jimmy Carter; Johanna Lucero, Mark Twain; Kacy
Cash, Grant; Nicole Slayton, Valley HS; Heidi Dudley, Marie
Hughes
1:45 - 2:15 p.m. Dr. Kris Meurer, Executive Director, Student, Family &
Community Supports (Medicaid) Phone Interview: call 505 220-
5441; and Joann Sanchez, Manager: School-Based Medicaid
Program (in person).
2:15 - 3:00 p.m. Para-educators: See attached list of participants.
3:00 - 3:15 p.m. BREAK
3:15 - 4:15 p.m. General Education Teachers: See attached list of participants.
4:15 - 5:15 p.m. Elementary Principals: See attached list of participants.
5:15 - 6:15 p.m. Middle/High School Principals: See attached list of participants.
6:15 - 7:30 p.m. DINNER
Thursday, September 27, 2018 - Superintendent’s Office, 6th Floor, 6400 Uptown
8:30 - 12:00 p.m. Work offsite.
12:00 - 12:30 p.m. LUNCH
12:30 - 2:00 p.m. Meeting and debrief with Superintendent: Superintendent

Raquel Reedy, Dr. Richard Bowman, CGCS Review Team.

Individuals Interviewed
Leadership Team
• Superintendent Raquel Reedy
• Dr. Richard Bowman, Chief Information and Strategy Officer
• Lucinda Sanchez, Associate Superintendent for Special Education
• Dr. Madelyn Serna Marmol, Assistant Superintendent of Equity, Instruction and Support,
• Dr. Kristine Meurer, Executive Director of Student, Family and Community Supports
• Tami Coleman, Chief Financial Officer
• Scott Elder, Chief Operations Officer
• John Dufay, Executive Director, Maintenance and Operations
• Royce Binns, Executive Director, Transportation
Office of Associate Superintendents

• Dr. Gabriella Blakey, Associate Superintendent for Leadership and Learning - Zone 1,
• Dr. Antonio Gonzales, Associate Superintendent for Leadership and Learning - Zone 2,
• Yvonne Garcia, Associate Superintendent for Leadership and Learning - Zone 3,
• Troy Hughes, Associate Superintendent of Leadership and Learning - Zone 4,
• Sheri Jett, Support Principal - Zone 1
• Gene Saavedra, Support Principal - Zone 2
• Rachel Vigil, Support Principal - Zone 3
• Chris Sanchez, Support Principal - Zone 4
Curriculum and Instruction

• Dr. Madelyn Serna Marmol, Assistant Superintendent of Equity, Instruction and Support,
• Aimee Milazzo, Executive Director of Curriculum and Instruction
• Jami Jacobson, Senior Director of Elementary Learning
• Jessica Villalobos, Senior Director, Language and Cultural Equity
Office of Innovation and School Choice

• Deborah Elder, Executive Director, Office of Innovation and Learning
• Joseph Escobedo, EdD; Senior Director, Charter Schools
• Amy Chase, Charter School Coordinator
• Patricia Espinosa, Charter School Liaison
Student, Family and Community Supports

• Kristine Meurer, Executive Director
• Joann Sanchez, Manager: School-Based Medicaid Program
District Principal Support Services

• Sharon Olguin, District Mentor Principal
• Sheri Jett, Support Principal - Zone 1
• Gene Saavedra, Support Principal - Zone 2
• Rachel Vigil, Support Principal - Zone 3
• Chris Sanchez, Support Principal - Zone 4

• Kenneth Salazar
• Katherine House
Legal Team
• Sam Adams, Esq., Adams Crow Law Firm
• Evelyn Howard-Hand, Esq., Walsh Gallegos Law Firm
Labor Partners
• Albuquerque Teachers Federation
• Ellen Bernstein, President
• Kathy Chavez, ATF/EAs
• Marianna Anaya, Organizing and Communications
Special Education
• Lucinda Sanchez, Associate Superintendent for Special Education,
• Cindy Soo Hoo, Executive Director
• Bonnie Anderson, Director, Budget, Data Synergy
• Claudia Gutierrez, Director, Student Achievement
• Bernadette Lucero-Turner, Director, Evaluations and Related Services
Tuesday, September 25, 2018

3:15 - 4:15 p.m.
Special Education Principal School Support Specialists

• Lisa Oliphant
• Tillie Tierney
• Stephanie Fascitelli
• Lila Ramirez
• Patricia Rajala
• Yvonne Madrid
• Cindy Hoppman
• Shelly Henderson
• Kathryn Shull
• Annittra Atler
• Lianne Pierce
• Tracy Hutton
• Loretta Garcia
4:15 - 5:15 p.m.
• Special Education Teachers:

• Leslie (Jay) Decker, Lowell ES, Zone 1
• Jackie Cusimano, Manzano HS, Zone 1
• Jurgen Filemon, Pajarito ES, Zone 2
• Ray Rodriguez, Jimmy Carter MS,Zone 2

• Stephanie Davy, West Mesa HS, Zone 2

• Kathy Woodruff, LBJ MS Teacher, Zone 3
• Cindy Shroba, Petroglyph ES, Zone 3
• Vanessa Jaramillo, Tony Hillerman, Zone 3
• Stephanie Blythe, Collet Parl ES PK, Zone 4
• Zayda Raimundi, Madison MS, Zone 4r
• Georgea Hantzopoulus, La Cueva HS, Zone 4
• Monica Luna, Zone 3, Cibola HS
• Kimberly Mackey, Zone 3, James Monroe MS
• Danielle Garcia, Zone 2, Adobe Acres ES
• Jainanna Sweet, LBJ, Zone 3
• Nancy Guzman, MacArthur , Zone 3
• Patricia Eisenzimmer, Macarthur, Zone 3
5:15 - 6:15 p.m.
Parents/Community Members:
• Kristen Horne, Special Ed Parent Advisory, Desert Ridge, North Star, Zone 4,
• Martha Favela, District Health Advisory, George I Sanchez, Zone 2
• Rene Salcido, District Health Advisory, George I Sanchez, Zone 2,
indengrse13@hotmail.com
• Susan Menicucci, Special Ed Parent Advisory, Cleveland MS, Zone 4,
susanmen03@outlook.com
• Philip Menicucci, Special Ed Parent Advisory, Cleveland MS, Zone 4,
susanmen03@outlook.com
• Frank Gallegos, PTA, Adobe Acres, Zone 2
• Bernadette Acosta, Title I
• Cristina Murray-Krezan, Gifted, Zone 4
• Alma Ramirez, Valley, Zone 3
• Cathy Salazar
• Charles White
Wednesday, September 26, 2018

7:45 - 8:45 a.m.
Related Services Providers:

Speech and Language Therapists:
• Yolanda Anthony, SLP
• Carla Collins, SLP Liaison
• Karen Shirley, SLP Liaison
Physical Therapists:
• Bethany Balzis, Physical Therapist
• Lucille Lopez, Neuromotor PT Liaison
Occupational Therapists:
• Amy Markham, Occupational Therapist

• Sid Alley, Neuromotor OT Liaison

Social Workers:
• M.J. Cunningham, Social Worker
• Merion Hayworth, Social Work Liaison
Nurses:
• Jody Wagner, District Resource Nurse
Assistive Technicians:
Orientation and Mobility Technicians:
Adaptive Physical Education Teacher:
• Laura Speer, Adaptive PE Teacher
• Elizabeth Hudson, APE Liaison
8:45 - 9:30 a.m.
Psychologists:
• Meredith Faith, Psychologist
• Aaron Sanders, Psychologist
• Niloufer Mody, Psychologist
Diagnosticians:
• Valerie Treseder, Diagnostician
• Ricky Adams, Educational Diagnostician
• Marguerite Lorenzi Gonzales, Educational Diagnostician
• Kim Rayner, Educational Diagnostician
9:30 - 10:30 a.m.
Special Education Staff

• Jennifer Bossow, BCBA, bossow@aps.edu
• Leigh Adams-Emanuel, Head Teacher Liaison
• Denette Chavez-Johnsen, Data Analyst
• Tommi Cordero, Data Resource Specialist
• Melissa Maestas, Special Education Auditor
• Susan Oppel, IEP Specialist Liaison
• Zoe Ann Alvarez, Curriculum Resource Teacher
• Jennifer Carr, SEALIP teacher
• Meghan Shanley, UDL Team
• Judith Edwards, Nursing
• Adriana Kerr, DCSS Resource Teacher
• Jody Wagner, Nursing
• Carol Leyendecker, Gifted Liaison
• Jennifer Cunico, Early Childhood Resource Teacher
• Karen Krall, Principal, Transition Services
• Eulalia Gonzales, Principal, Transition Services
• Bernadette Lucero-Turner, Executive Director

10:30 - 11:15 a.m.

Principal Support Specialists
• Kenneth Salazar
• Sheri Jettj
• Chris Sanchez
• Sharon Olguin
• Rachel Vigil
• Katherine House
• Gene Saavedra
11:15 - 12:15 p.m.
Labor Partners: Albuquerque Teachers Federation

• Ellen Bernstein, President
• Kathy Chavez, ATF/EAs
• Marianna Anaya, Organizing and Communications
• Angela Reynolds, MA, LED; Educational Diagnostician, NE Diagnostic Center; ATF
Vice President for Support and Related Service Personnel
• Donna Teuteberg, LCSW, School Social Worker, Sandia High School;
• Toni Seidler, Special Education Head Teacher, Garfield STEM School;
• Mary Mercier, Consulting Teacher, APS/ATF Mentor/PAR Program
• Alethea Patterson-Jahn, Head Special Education Teacher, Truman Middle School
• Judy M. Martinez, Speech-Language Pathologist (SLP), Atrisco Heritage Academy, HS
12:45 - 1:45 p.m.
SPED Support Assistant Principals

• Felicia Mondragon, Chaparral
• Mary Cade, Sandia HS
• Lisa Goodman, Montezuma
• Anna Phillips, Jimmy Carter
• Johanna Lucero, Mark Twain
• Kacy Cash, Grant MS
• Nicole Slayton, Valley HS
• Heidi Dudley, Marie Hughes
2:15 - 3:00 p.m.
Para-educators/Special Education Educational Assistants:

• Henrietta Webb, MS EA, Zone 1, Hayes MS
• Martin Melendrez, ES EA, Zone 1 (MRI), Whittier ES
• Lisa Sparks, MS EA, Zone 3. LBJ MS
• Kara Aguilar, ES EA, Zone 3, Petroglyph ES
• Carla Perea, HS EA, Zone 4, La Cueva HS
• Heidi Curry, MS EA, Zone 4

• Rebecca Boyer, West Mesa HS, Zone 2

• Chelsea Rovida, Pajarito ES, Zone 2,
• Matthew Medina, Pajarito ES, Zone 2
• Jeremiah Lopez, ES EA. Zone 1, Mark Twain ES
• April Gillen, ES EA Zone 1, Mark Twain ES
• Arlene Gallegos, ESEA, Zone 1, Whittier ES
• Amy Trujillo, ES EA Zone 2, Rudolfo Anays ES
3:15 - 4:15 p.m.
General Education Teachers:

• Jane Altwies, Hubert Humphrey Elementary, Zone 4
• Angela Durham, Lowell Elementary, Zone 1
• Esther Saavedra-Lucero, EG Ross, Zone 4
• Nina Zuni, Tierra Antigua, Zone 3
• John Keelin, EG Ross, Zone 4
• Robert Chavez, Navajo ES, Zone 2
• Dawn Tarman, Hodgin ES, Zone 4
• James Christopher, Hayes MS
• Ashley Daniels, Eisenhower MS
• Tim Greenman, Atrisco Heritage HS
• Cheyenne Lytle, Cibola HS
• Dan Shanley, Manzano HS
• Martha Bedeaux, La Cueva HS
4:15 - 5:15 p.m.
Elementary Principals:
Charters:
• Pam Greene, El Camino Real Academy of population
• Tonya Newton, Alice King Community School
• Costa Pavlakos, Principal, Highland Complex
Zone 1:
• Mark Woodard, Montezuma ES
Zone 2:
• Valarie Hoose, Chaparral Elementary School
Zone 3:
• Lesley Cummins, Craig Robinson
Zone 4:
• Jack Vermillion SY Jackson ES
5:15 - 6:15 p.m.
Middle/High School Principals:

Middle School:

Charters:
• Mary Tarango, 21st Century Public Academy (5-8)
Zone 1:
• Shawn Morris, Van Buren
Zone 2:
• Stacia Duarte, Ernie Pyle Middle School
Zone 3:
• Mike Bachicha, LB Johnson
Zone 4:
• Debbie Garrison, Madison MS
High Schools:
Charters:
• Doreen Winn, Public Academy for Performing Arts
• Lisa Heimer, Principal, Aztec Complex
Zone 1:
• Ryan Homistek, Albuquerque HS
Zone 2:
• Amanda DeBell, Rio Grande High School
Zone 3:
• Anthony Griego, Valley HS
Zone 4:
• Dana Lee, La Cueva High School
Phone Interview with New Mexico Public Education Department

October 22, 2018, 2:00-3:00 PM
• Deborah Dominguez-Clark, Director of Special Education, Special Education Bureau

• Cynthia Romero, Data Supervisor, Special Education Bureau
• Tim Crum, Deputy Director of Special Education, Special Education Bureau
• Charlotte Marcotte, Special Education Bureau

Appendix E. Strategic Support Team

The following were members of the Council’s Strategic Support Team on special
education who conducted this project for the Sacramento Unified School District.
Tanya Browne
Tanya Browne currently supports the schools, students and families of the Dallas
Independent School District as the Executive Director for Special Education. With a focus on
collaboration and capacity building, Ms. Browne leads a team of more than 400 staff who are
improving supports and services for students by 1) redesigning campus support 3) creating tools
aligned with the standards 4) maintaining compliance in key areas such as transition services 5)
creating inclusive opportunities for students 6) ensuring students receive services within their
school community. The Dallas ISD serves more than 14,000 students receiving special education
services. Ms. Browne received a bachelor’s degree in Journalism and master’s degree in
Educational Administration from the University of Texas at Austin. During her 25-year tenure in
education, Ms. Browne also served as a special education specialist and supervisor, a secondary
Associate Principal (supervising general/special education, Talented and Gifted (TAG) and
English as a Second Language (ESL) teachers) and, most recently, as the Executive Director of
Special Programs in the Austin ISD. During her tenure as a special education teacher, Ms. Browne
was twice named Teacher of the Year. Ms. Browne believes that educators are called not only to
teach but to help remove barriers to ensure all students access general education through effective
and safe learning environments. Due to the scope of her role in Dallas ISD, in 2017, Ms. Browne
was selected to receive a 2017 Dallas Business Journal Women in Business Award.
Sue Gamm, Esq.
Sue Gamm, Esq., is a special educator and attorney who has spent more than 40 years
specializing in the study and understanding of evidence-based practices, policies, and procedures
that support a systemic and effective education of students with disabilities and those with
academic and social/emotional challenges. Ms. Gamm has blended her unique legal and special
education programmatic expertise with her experiences as the chief specialized services officer for
the Chicago Public Schools, attorney and division director for the Office for Civil Rights (US
Department of Education) and special educator to become a highly regarded national expert as an
author, consultant, presenter, and evaluator. Since her retirement from the Chicago Public Schools
in 2003, has been engaged in 30 states and the District of Columbia with more than 50 school
districts and five state educational agencies working to improve the instruction and support
provided to students with disabilities. Twenty-one of these reviews were conducted through the
auspices of the Council of the Great City Schools. Ms. Gamm has written standard operating
procedure manuals for special education practices and multi-tiered systems of support (MTSS) for
more than 10 school districts, and has shared her knowledge of the IDEA, Section 504 of the
Rehabilitation Act, the Americans with Disabilities Act and related issues at more than 70 national,
state and local conferences. Ms. Gamm has authored/co-authored numerous periodicals and
publications, including those focused on MTSS, disproportionality for special education,
responding to OCR investigations, and assessment. She also testified before Congressional and
Illinois legislative committees. Ms. Gamm has served as a consulting attorney on several of the
Council’s amicus briefs focusing on special education that were submitted to the U.S. Supreme
Court. Further, she consults with the Public Consulting Group and numerous school districts and

state educational agencies and provides training at national, state, and local conferences on special
education matters, particularly in the area of special education disproportionality. Ms. Gamm has
also been recognized for her legal expertise in the area of special education through her
engagement as an expert witness or consultant involving nine special education federal class action
or systemic cases. She is admitted to practice before the Illinois Bar, the Federal Bar, and the U.S.
Supreme Court Bar.
Julie Wright Halbert, Esq.
Julie Halbert has been legislative counsel for the Council of the Great City Schools for over
22 years. In that capacity, she has served as a national education legal and policy specialist, with
emphasis on special education. She worked extensively on the reauthorizations of the Individuals
with Disabilities Education Act (IDEA) in 1997 and 2004. Ms. Halbert is responsible for drafting
numerous technical provisions to the IDEA and providing technical assistance to Congress and the
U. S. Department of Education. In 1997 and again in 2005, she testified before the U.S. Department
of Education on its proposed regulations on IDEA 2004. Ms. Halbert has directed each of the
Council’s special education strategic review teams, including special education reviews in the
Anchorage, Austin, Boston, Chicago, Charleston, Cincinnati, Des Moines, District of Columbia,
Guilford County (NC), Memphis, New York City, Richmond, Philadelphia, Pittsburgh,
Providence and St. Louis. Working with national experts Sue Gamm and Judy Elliott, she has
published a Council national white paper on the implementation and development of MTSS, Multi-
Tiered Systems of Supports for our nation’s urban school districts. Ms. Halbert most recently,
January 2017, took the lead working with our cities in the development of the Council’s amicus
brief to the Supreme Court of the United States in Endrews v. Douglas County School District, on
determining the educational benefit standard due by our districts to students with disabilities when
implementing their IEPS. This case is certain to be one of the most important cases since Rowley
decided over thirty years ago. She was also the counsel of record for the Council of the Great City
Schools’ amicus briefs in the Supreme Court of the United States in (a) Board of Education of the
City School District of the City of New York v. Tom F., On Behalf of Gilbert F., A Minor Child
(2007); (b) Jacob Winkelman, a Minor By and Through His Parents and Legal Guardians, Jeff
and Sander Winkelman, et al., v. Parma City School District (2007); (c) Brian Schaffer v. Jerry
Weast, Superintendent of Montgomery County Public Schools, et al., (2005); (d) Parents Involved
in Community Schools v. Seattle School District, and Meredith v. Jefferson County Board of
Education (2007) and Forest Grove School District v. T.A, (2009). Ms. Halbert graduated with
honors from the University of Maryland and the University of Miami School of Law. She is
admitted to practice in the Federal Bar, the U.S. Supreme Court Bar, and the Florida and
Pennsylvania Bars. Additionally, for the past year, together with Husch Blackwell partner John
Borkowski, Ms. Halbert is assisting to develop and implement national legal webinars for urban
district’s counsel and key staff on emerging legal issues for the Council’s districts. They include,
Civil Rights Priorities at the End of One Administration and Beginning of Another, Hate Speech,
Micro-aggressions and Student First Amendment Rights.
Marco Tolj
Marco Tolj currently serves as the Director of Strategic Planning and Data Management
with the Division of Special Education, in the Los Angeles Unified School District. Throughout
his 18-year career working for the second largest school district in the nation, he has held a variety
of roles. He started his career in LAUSD as a campus aide and later worked as a special education

teacher, Special Education Coordinator, Special Education Program Specialist and Assistant
Principal, while simultaneously serving in a variety of adjunct roles working with students, staff
and the community. Mr. Tolj has developed a strong understanding of how to provide leadership
and direction in the form of school and district reform, particularly in the areas of instruction,
student achievement, behavior and student discipline, attendance, promoting a positive school
climate and the integration of students with disabilities. He has firsthand experience in successfully
implementing new instructional initiatives, coordinating various programs, capably resolving
student discipline and safety issues, and effectively collaborating with outside agencies and other
District offices. As Administrative Coordinator, Local District Central, he had the privilege of
leading a diverse group of exceptional individuals who support almost 12,000 students with
disabilities (SWD). One of his main goals was to ensure that schools, students and families receive
the most efficient, effective collaborative support possible. LAUSD’s Local District Central made
great strides in accomplishing this task because he grounded his work around Fullan’s Right
Drivers (Group Quality, Focus on Instruction, Systems and Building Capacity) and Simon Sinek’s
Golden Circle. He prides himself in adhering to his personal “Why”, which is “Connecting to
Fulfill Dreams”. Marco Tolj has represented LAUSD at both the Special Education Local Plan
Area Administrators (SELPA) of California and at the Greater Los Angeles Area SELPA (GLASS)
meetings and has served as a Liaison with the LAUSD Office of Government Relations. Marco
co-founded the ONE Conference in collaboration with California State University, Los Angeles
(CSULA), the Charter College of Education (CCOE). The goal of this conference is to create an
opportunity for schools to learn strategies, attain resources, and build a network of support to make
the vision and outcome of integrating students with disabilities in the least restrictive environment
a reality. In 2016, Mr. Tolj was awarded the ACSA Region 16 Special Education Administrator of
the Year award.

Appendix F. About the Council and History of Strategic Support Teams

The Council of the Great City Schools is a coalition of 75 of the nation’s largest urban
public-school systems. 123 The organization’s Board of Directors is composed of the
superintendent, CEO, or chancellor of schools and one school board member from each member
city. An executive committee of 24 individuals, equally divided in number between
superintendents and school board members, provides regular oversight of the 501(c)(3)
organization. The composition of the organization makes it the only independent national group
representing the governing and administrative leadership of urban education and the only
association whose sole purpose revolves around urban schooling.
The mission of the Council is to advocate for urban public education and to assist its
members in to improve and reform. The Council provides services to its members in the areas of
legislation, research, communications, curriculum and instruction, and management. The group
also convenes two major conferences each year; conducts studies of urban school conditions and
trends; and operates ongoing networks of senior school district managers with responsibilities for
areas such as federal programs, operations, finance, personnel, communications, instruction,
research, and technology. Finally, the organization informs the nation’s policymakers, the media,
and the public of the successes and challenges of schools in the nation’s Great Cities. Urban school
leaders from across the country use the organization as a source of information and an umbrella
for their joint activities and concerns.
The Council was founded in 1956 and incorporated in 1961 and has its headquarters in
Washington, DC. Since the organization’s founding, geographic, ethnic, language, and cultural
diversity has typified the Council’s membership and staff.
123
Albuquerque, Anchorage, Atlanta, Austin, Baltimore, Birmingham, Boston, Broward County (Ft. Lauderdale),
Buffalo, Caddo Parish (Shreveport), Charleston County, Charlotte-Mecklenburg, Chicago, Buffalo, Clark County
(Las Vegas), Cleveland, Columbus, Dallas, Dayton, Denver, Des Moines, Detroit, Duval County (Jacksonville),
East Baton Rouge, Fort Worth, Fresno, Guilford County (Greensboro, N.C.), Hillsborough County (Tampa),
Houston, Indianapolis, Jackson, Jefferson County (Louisville), Kansas City, Little Rock School District, Long
Beach, Los Angeles, Memphis, Miami-Dade County, Milwaukee, Minneapolis, Nashville, Newark, New Orleans,
New York City, Norfolk, Sacramento, Oklahoma City, Omaha, Orange County (Orlando), Palm Beach County,
Philadelphia, Pittsburgh, Portland, Providence, Richmond, Rochester, Sacramento, Salt Lake City, San Diego, San
Francisco, Seattle, St. Louis, St. Paul, Toledo, Washington, D.C., and Wichita

History of Strategic Support Teams of the Council of the Great City Schools
The following is a history of the Strategic Support Teams provided by the Council of the Great
City Schools to its member urban school districts over the last 18 years.
City Area Year
Albuquerque
Facilities and Roofing 2003
Human Resources 2003
Information Technology 2003
Special Education 2005 & 2018
Legal Services 2005
Safety and Security 2007
Research 2013
Special Education 2018
Anchorage
Finance 2004
Communications 2008
Math Instruction 2010
Food Services 2011
Organizational Structure 2012
Facilities Operations 2015
Atlanta
Facilities 2009
Transportation 2010
Austin
Baltimore
Birmingham
Operations 2008
Facilities 2010
Financial Operations 2015
Boston
Curriculum & Instruction 2014
Food Service 2014
Facilities 2016
Bridgeport
Transportation 2012
Broward County (FL)


Food Services 2009
Transportation 2009
Buffalo
Superintendent Support 2000
Curriculum and Instruction 2000
Personnel 2000
Facilities and Operations 2000
Communications 2000
Finance 2000
Finance II 2003
Bilingual Education 2009
Caddo Parish (LA)
Facilities 2004
Charleston
Transportation 2014
Charlotte-Mecklenburg
Transportation 2013
Cincinnati
Chicago
Warehouse Operations 2010
Special Education I 2011
Special Education II 2012
Christina (DE)
Cleveland
Student Assignments 1999, 2000
Transportation 2000
Facilities Financing 2000
Transportation 2004


Theme Schools 2009
Columbus
Facilities Financing 2002
Finance and Treasury 2003
Budget 2003
Food Services 2007
Transportation 2009
Dallas
Procurement 2007
Staffing Levels 2009
Dayton
Finance 2001
Communications 2002
Budget 2005
Denver
Personnel 2001
Common Core Implementation 2014
Des Moines
Budget and Finance 2003
Detroit
Assessment 2002
Communications 2002
Curriculum and Assessment 2003
Communications 2003

Textbook Procurement 2004

Food Services 2007
Facilities 2008
Finance and Budget 2008
Stimulus planning 2009
El Paso
Fresno Information Technology 2019

Guilford County
Facilities 2004
Transportation 2017
Hillsborough County
Transportation 2005
Procurement 2005
Transportation 2015
Houston
Capitol Program 2010
Procurement 2011
Indianapolis
Transportation 2007
Finance 2018
Jackson (MS)
Bond Referendum 2006
Communications 2009
Jacksonville
Organization and Management 2002
Operations 2002
Finance 2002


Finance 2006
Facilities operations 2015
Budget and finance 2015
Kansas City
Finance 2005
Operations 2005
Purchasing 2006
Program Implementation 2007
Stimulus Planning 2009
Transportation 2016
Finance 2016
Facilities 2016
Little Rock
Los Angeles
Finance 2005
Business Services 2005
Louisville
Management Information 2005
Memphis
Food Services 2016
Procurement 2016
Miami-Dade County
Construction Management 2003
Food Services 2009
Transportation 2009
Maintenance & Operations 2009
Capital Projects 2009
Milwaukee
Research and Testing 1999


School Board Support 1999
Alternative Education 2007
Minneapolis
Finance 2004
Federal Programs 2004
Transportation 2016
Nashville
Food Service 2010
Newark
Food Service 2008
New Orleans
Personnel 2001
Transportation 2002
Hurricane Damage Assessment 2005
New York City
Norfolk
Testing and Assessment 2003
Transportation 2018
Finance 2018
Omaha
Buildings and Grounds Operations 2015
Transportation 2016
Orange County
Palm Beach County
Transportation 2015
Safety & Security 2018
Philadelphia

Food Service 2003

Facilities 2003
Transportation 2003
Budget 2008
Human Resource 2009
Transportation 2014
Pittsburgh
Technology 2006
Finance 2006
Business Services and Finance 2016
Research 2016
Portland
Procurement 2010
Operations 2010
Prince George’s County
Transportation 2012
Providence
Business Operations 2001
MIS and Technology 2001
Personnel 2001
Puerto Rico
Hurricane Damage Assessment 2017
Reno
Facilities Management 2013
Food Services 2013
Purchasing 2013
School Police 2013
Transportation 2013
Richmond

Transportation 2003
Financial Operations 2018
Rochester
Finance and Technology 2003
Transportation 2004
Food Services 2004
Sacramento
San Antonio
IT Operations 2017
Transportation 2017
Food Services 2017
Human Resource 2018
San Diego
Finance 2006
Food Service 2006
Transportation 2007
Procurement 2007
San Francisco
Technology 2001
St. Louis
Textbook Procurement 2004
St. Paul
Transportation 2011
Seattle
Transportation 2008
Maintenance and Operations 2008
Procurement 2008

Food Services 2008

Transportation
Toledo
Washington, D.C.
Finance and Procurement 1998
Personnel 1998
Communications 1998
Transportation 1998
Facilities Management 1998
Legal and General Counsel 1998
MIS and Technology 1998
Transportation 2005
Common Core Implementation 2011
Wichita
Transportation 2009

Albuquerque Special Education Report-FINAL

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Confidential Attorney Work Product

Council of the Great City Schools Page i

NAEP Achievement Rates for Students with IEPs ....................................................................................47

Council of the Great City Schools Page ii

Council of the Great City Schools Page iii

Council of the Great City Schools Page 1

CHAPTER 1. PURPOSE AND ORIGINS OF THE PROJECT

The Work of the Strategic Support Team

Council of the Great City Schools Page 2

Sue Gamm, Esq.

Methodology and Organization of Findings

Council of the Great City Schools Page 3

• Appendix D lists individuals the team interviewed individually or in groups.

Council of the Great City Schools Page 4

CHAPTER 2. BACKGROUND AND OVERVIEW

Council of the Great City Schools Page 5

Council of the Great City Schools Page 6

Important court findings included the following:5

Council of the Great City Schools Page 7

Council of the Great City Schools Page 8

As a result of the survey, APS/ATF developed a joint committee made up of special

Council of the Great City Schools Page 9

CHAPTER 3. EXECUTIVE SUMMARY

Council of the Great City Schools Page 10

Council of the Great City Schools Page 11

CHAPTER 4. FINDINGS AND RECOMMENDATIONS

I. Multi-Tiered Systems of Support and Implications for Child Find

Council of the Great City Schools Page 12

NM Guidance for RtI

Council of the Great City Schools Page 13

PED’s RtI Webpage

Council of the Great City Schools Page 14

Locally devised implementation plan. As each school develops its local

Council of the Great City Schools Page 15

Council of the Great City Schools Page 16

In response to disciplinary actions Required only when considering

When considering long-term

Fidelity of Implementation Tools

APS Guidance and Practices

Council of the Great City Schools Page 17

According to the department’s webpage, core curriculum/instructional practices are

Council of the Great City Schools Page 18

FBA/BIP Training PowerPoint

Council of the Great City Schools Page 19

Council of the Great City Schools Page 20

Focus Group Feedback

Council of the Great City Schools Page 21

Council of the Great City Schools Page 22

Council of the Great City Schools Page 23

Child Find Implications

Council of the Great City Schools Page 24

Focus Group Feedback

Council of the Great City Schools Page 25

OPPORTUNITIES FOR IMPROVEMENT

Council of the Great City Schools Page 26

Council of the Great City Schools Page 27

Council of the Great City Schools Page 28

Council of the Great City Schools Page 29

Council of the Great City Schools Page 30

Council of the Great City Schools Page 31

Recommendations to improve the district’s identification of students with disabilities are

Council of the Great City Schools Page 32

II. Disability Demographics

District Prevalence Rates