Analysis and Recommendations for the
Education Equality Task Force
From The Ontario Coalition for Inclusive Education
It is imperative that the Task Force recommends fundamental change
funding formula concerning special education. Unlike others, it is not more
money for which we ask. That alone will not achieve the change that is urgently
We rarely hear concerns about the Special Education Per Pupil Amount
This confirms our conviction that most special education funding should be
census-based, knowing the provincial grants per student each year for special
education allows school boards to base long-term planning upon their overall
It seems that Intensive Support Amount #1 is also working well for Ontario.
Boards are reimbursed for prescribed, specialized equipment they have provided
for individual students. Apparently, this money has never been overspent. The
$800 “deductible” should be removed, and associated professional
development and technical support be reimbursed, to ensure equipment is utilized
It is difficult for us to know what is happening with ISA #4 funding, which
involves inter-ministerial cost-sharing.
ISA #2 and #3 and the Special Incidence Portion (SIP) violate all of the Guiding
Principles of this Task Force, re:
- Quality of Student Learning and Achievement
- Equity and Fairness
- Responsiveness to Local Needs
The problem is huge: essentially school boards demonstrate that increasing
numbers of students are failing, while they divert millions of dollars
away from the very programs that should assist them.
(For the purposes of the rest of this paper, we will refer to ISA 2 and 3
and SIP as “ISA”.)
This Task Force must clearly direct the government to stop the harm of ISA
immediately, before more funds are allocated to it, this November.
Our definition of “a quality education” involves:
- Respect for the potential and the contribution of all students
Maximizing all students’ learning by designing instruction to
promote their strengths
Proof of improved outcomes – but now there are no outcome measures for
students exempted from EQAO tests. (And surely improved outcomes mean guaranteeing
attendance at school – as the first step!)
- “Special education program” is defined in the Education
Act essentially as an Individual Education Plan (IEP). It need not involve
in ways that force the congregation and segregation of exceptional
students. Rather, this definition means that a variety of supports can be
for individual students and brought to them in regular class placements.
The law must be respected – specifically, Education Act
Regulation 181, which came into effect in September 1998 but
is still not enforced.
The Ministry’s IEP Standards could promote accountability
but must be implemented.
Quality of Student Learning and Achievement
- ISA criteria and documentation prejudge, emphasize and encourage
student failure – both social and academic. Students with developmental
disabilities, with autism and with behavioural exceptionalities have been
most harmed by ISA criteria.
Talk about failure! Some of these children are not attending school at all.
Criteria that brings boards ISA $ for “behavioural” students is
virtually the same as for expulsion of those kids. Boards are rewarded financially
for NOT preventing and resolving problems. And then, Boards continue to get
money when ISA-eligible students are not attending school – at
all, or regularly or full days.
- To meet ISA criteria, students with developmental disabilities
are given assessments that may be invalid (eg outdated, not meant to predict
inappropriate for the population) and unreliable (eg at the extremes
of the scale, in the first percentile)
Boards get more ISA funding if they limit a student’s educational
programming to social and life skills. This encourages segregation.
They can lose money
if academics are even taught, let alone learned! Boards are also
anxious to allow peers or other students to provide supports to learn
lessons, mentoring, or volunteering since it could jeopardize the
perceived need for an Educational Assistant.
- This harm is unlikely to end when this ISA Review is over. School
boards are wary of ever documenting student progress, lest funding ever be
- We warned Premier Mike Harris in 1999 that ISA is an incentive,
promoting over-identification of student problems, as the research shows
(Refer to Parrish and NASBE Winning
Ways, and OECD) We were right, and ISA is wrong.
Equity and Fairness
- ISA does not “respond to different needs of students” at
all. It records student deficits and disabilities and dictates programming
objectives. Instead, ISA actually creates more and more “need”
Is this about treating school boards fairly, or students? The “needs
of school boards” should be the same as “the needs of students” – not
at cross-purposes. Currently school boards gain ISA funding at the expense
of their most vulnerable students
An unnecessary and harmful competition has been created between “ISA
kids” (who have in no way been entitled to the ISA funds their documentation
justifies) and “SEPPA kids” (who don’t really exist
now) The Portability adjustments will turn this into a major problem.
Most Boards closed segregated schools for students with developmental disabilities
10-15 years ago. Why do they persist in Hamilton, Toronto and Ottawa public
boards – the very ones with budget difficulties?
The Task Force should be considering the allocations, outcomes and costs of
provincial schools, where students with sensory impairments may remain segregated
and some with learning disabilities receive short-term help. It is inequitable
that so much more government funding is available to students attending provincial
schools than is ever available for them to be educated close to home – 24
hour a day care, room and board, school, and even transportation home
ISA exists because the Ministry says there are proven variations among school
boards in percentages of “high cost” students. But Ministry
comparisons are reliable and valid only if all boards have the same ability
to amass such
complex documentation, and only if all are equally willing to document
students so negatively. ISA does not reimburse costs nor does it look
at actual costs
in determining eligibility.
- The Ministry charts and graphs show variation among boards in
percentages of ISA-eligible students. But the Task Force must consider numbers
students too. Boards with the highest percentages may actually reflect
- Current provincial ISA funding would make it appear that 1.88%
of Ontario students are ISA-eligible, even though only 1.12% have actually
met the criteria.
Peter Gooch, Education Finance manager, predicted that 80% of Boards will “punch
through their ceilings”, that is, demonstrate they should be getting
more ISA money. Will the Ministry allocate the additional $120-150 million
this involves? But it may be that many are getting more ISA funding than
they deserve. Will the Ministry cut their special ed funding?
Responsiveness to Local Needs:
- Who defines “local needs”? After all, the province is
disputing school trustees’ ability to make such judgments. Kids should
not bear the brunt of battles between boards and the Ministry over funding
- “Local needs” should mean the cumulative total of all of the individual
needs of students attending school in that locality. What is very clear is that
students’ educational needs are not the same as ISA criteria.
Every exceptional student is entitled to an IEP that states individual needs
and “responds” accordingly. Ministry IEP Standards could
help a lot, if ever implemented.
- Regulation 181 requires that regular class placement be considered
for every exceptional student every year. Money saved, accordingly, on
transportation should be reinvested to pay for support for educational success
closer to home.
- Huge savings in transportation costs to and from provincial schools
should be reallocated for every student effectively supported at home.
The Ministry must enforce Regulation 181, to ensure “that integration
should be recognized as the norm of regular application because of the benefits
it generally provides (Supreme Court of Canada decision re Emily Eaton). The
Coalition knows that many families’ wishes are disregarded and
support is altogether denied in regular classes, forcing segregation
students, particularly those having intellectual disabilities. And
why should transportation costs be inflated in this way?
The Ministry must effectively monitor placement statistics in Boards’ October
Reports and analyze the vast difference among boards in rates of
segregation of students, in each exceptionality category.
Re: Special Education:
- Again, “need for funding” should be determined by
all the support requirements of all of the student IEPs.
School boards submitted Special Ed Plan reviews last July but it took more
than a year for any response from the Ministry. It is unacceptable that another
year’s cycle of planning and spending has occurred without feedback.
The Provincial Auditor has pointed out that no one can “balance need
and efficiency” unless the school board can actually show that students’ goals
are met and the system’s performance targets are evaluated.
A small proportion of the province’s current ISA funds should not revert
to SEPPA but be kept as a reserve fund, to respond to very unusual local circumstances.
Boards could apply for extra money under special circumstances (e.g. perhaps
to make a major “deinstitutionalization” effort to return a large
number of deaf or blind students home from provincial schools). Another proactive
move would be to make schools accessible – pay for capital changes once
and you’ll save on operating costs. Boards might also apply to the Ministry
for professional development projects for systemic change. In any of these
instances, a more responsive funding model would not only be educationally
and cost-effective, but it would also be transparent. Trustees, SEAC, parents,
and taxpayers could all be involved in planning and monitoring – to
check if there was value for money.
Re School Renewal:
- ISA is regressive. Boards are rewarded when they do not accommodate
students, and problems result. Making schools accessible is a pro-active
- All Ontario schools should be free of barriers of all kinds It
is better to build schools barrier-free or to invest in appropriate renovations
to keep students unnecessarily dependent on adults, such as EAs
- The Pupil Accommodation Grant should provide grants for accessibility.
This is not a special education expense.
- It is shocking that people refer to ISA as “I’ll Say
Anything”, or “I’ll Sign Anything”. Teachers have been
told their job is to get the money, no matter what this means to students.
The Association of Professional Support Services Personnel says it is against
the codes of ethics for psychology, social work and speech pathology to describe
students in ways that match ISA criteria – but thousands of such
reports have been written.
Who checks whether ISA files contain fraudulent documentation? Most Boards
have not followed the Ministry directive to inform parents even of the ISA
- Because Boards get money by telling the Ministry they are providing
certain supports, they can be held legally responsible to provide them.
But, in no way is ISA “student-focused” – at present there
is no requirement that ISA money be spent on the students whose documentation
met the criteria. ISA is said to be merely a “surrogate statistic” – i.e.
a crude way to determine which Boards have higher costs.
Now that Portability measures mean that the funding must follow “ISA
students” when they move from one board to another, Boards’ legal
liabilities will increase.
The ISA model is not accountable to students, their families or ultimately
to their communities – and thus taxpayers. There is no value for money – quite
Only as long as there is an envelope approach, should the SEPPA special ed
envelope remain “sealed”. It was inappropriate, last year,
to allow boards to spend increases in SEPPA due to increased enrolment
other than on
special ed expenses.
Ultimately, however, inclusive education ends the distinction between “special” and “regular” education.
Funding should be spent flexibly – for the benefit of all, without “envelope” restrictions.
e.g. classroom teachers not specialists benefit from professional development
money. Exceptional students might benefit from smaller regular class
sizes, or more teacher planning time (as would ALL students). But there
a long way to go!
The Ministry should not give Boards greater flexibility unless it gets rid
of ISA and ensures there are effective accountability measures in effect – such
as true enforcement of Regulation 181 and its IEP and Special Ed Plan
- ISA is an increasing waste of money. The Ontario Principals’ Council
estimated in September 2000 that 20% of ISA funds were wasted on obtaining
it. That added up to $120 million across Ontario. Peel Board estimated
that ISA documentation used to cost $0.5 million a year, but rose to $2.8
this past year, taking most of its resource staff time. Another $10 million
more was allocated to school boards in the Ontario Budget last June - for
- The Task Force should ascertain how much the Ministry of Education has spent
for its part in ISA. We don’t think the documenting and audits
will ever end.
- Much more money will have to be spent on legal action supported by the Education
Act and Regulations, the Ontario Human Rights Code and the Canadian Charter – especially
once Portability provisions begin, when ISA money moves with students.
- It may well be that school boards need more money, but how can
we ever know? ISA is a totally inappropriate measure of educational needs,
and their distribution
across Ontario. It burdens teachers and harms students, shaming all who