Based on the review, Internal Audit Office observed that the program is functioning at a “marginal” level, meaning there is a potential for loss. The following observations were made:
2. Need for more professional development and training;
3. Inefficiencies in the monitoring process;
4. Inefficiencies in the process of documenting and communicating policies and procedures; and
5. eCSSS not meeting certain business objectives.
Some possible impacts to the department in regards to a lack of personnel and incentives are: higher turnover rates, inconsistent services provided to students, unqualified teachers, a larger caseload of work for current personnel, loss of funds due to hiring contractors, and a higher number of complaints and due process cases. Luke presented the recommendations for the program that included: providing contingency-based financial incentives to recruit employees, aggressively recruit applicants, streamline the hiring process, and revisit bargaining unit contracts to offer higher pay. A management plan was created to improve this area which included: the Office of Curriculum, Instruction, and Student Support will work with the Office of Human Resources to make the application process user-friendly, advertise positions nationally and locally, attend local job fairs, collaborate with local institutes of higher education, and revisit the Educational Assistant career ladder. The management plan is anticipated to be completed by June 30, 2016.
With regard to Observation #2, need for more professional development and training, Luke stated that teachers and support staff are hard-working and dedicated to the students, but there is always room for improvement. Through interviews, the Internal Audit Office discovered that District Educational Specialists want more training and support in regards to handling difficult legal and/or program questions. Through discussions with management, part of the problem is that District Educational Specialists need to understand the differences between legal and program issues; therefore, the need for further training.
In addition, the Special Education Program has made progress in creating training modules, but further ongoing training materials and monitoring of progress needs to be developed and communication with parents needs to be improved so that student support can improve.
Some possible impacts to the department in regards to the need for more professional development and training are: higher number of complaints and due process cases, important decisions being made without considering all factors involved, and employees lacking the correct training to fulfill job responsibilities. Luke shared recommendations to improve the program that included: the program continue mandatory monthly meetings with the parties involved and use the time for discussion and professional development, offer incentives to schools that create effective special education tools/training modules, continue to work on the special education handbook, and consider professional development training on how to better communicate with parents. Luke presented the Special Education Program management plan that included: The Office of Curriculum, Instruction, and Student Support will complete the handbook, offer professional development modules for teaching students with disabilities, offer tips on reading aloud to children with disabilities, and provide data to verify that the number of due process cases has decreased. The management plan is anticipated to be completed by June 30, 2016.
With regard Observation #3, inefficiencies in the monitoring process, Luke stated that credentialing verification is performed by the vendor as stated in their contracts that they are responsible, as well as by the Special Education Section who reviews credentials on two different occasions, meaning credentials are checked up to three times that creates a duplication of work.
Another inefficiency noted was that the Department did not currently have a tracking system of all its special education students that are in private education facilities paid for by the Department; and although the Department did have policies and procedures documented for how often to monitor students at private schools they did not provide tracking sheets and procedures on how and where to document the monitoring.
Some possible impacts to the department in regards to inefficiencies in the monitoring process are: inefficiencies due to duplication in the verification process, less time for the Special Education Section to develop curriculum or training materials, or violations in the law due to special education students in private schools not being monitored. The Internal Audit Office recommendations included: that the Special Education Section consult with the Department of the Attorney General to confirm the employee verification process, continue to finalize the Lotus Notes database and add appropriate fields for tracking private schools, and require schools to document in eCSSS that private school students’ records are reviewed quarterly. Luke shared the Office of Curriculum, Instruction, and Student Support’s management plan that included: The Department will meet with the Department of the Attorney General to discuss credentialing responsibilities, complete the Lotus Notes database to include necessary fields, and establish procedures for tracking and documenting records of students placed in private schools. The anticipated completion date is June 30, 2016.
With regard to Observation #4, inefficiencies in the process of documenting and communicating policies and procedures, Luke stated that policies, procedures, and training materials are documented but not centrally located, so they can be difficult to find. Additionally, the Special Education Section does not have written procedures documenting its current contract monitoring practices and mainly relies on the schools to monitor the quality of the contracted services.
Some possible impacts to the department in regards to inefficiencies in the process of documenting and communicating policies and procedures are: inaccurate information, inefficiencies due to time wasted searching for materials, and a higher risk of not transferring knowledge. Luke presented Internal Audit Office’s recommendations that included: the Special Education Section continue to work on the special education handbook, create a library of reference and training materials on the Department’s Intranet, and develop procedures that reflect current contract monitoring practices. Management’s plan included: that the Office of Curriculum, Instruction, and Student Support will research a user-friendly site for documentation, develop and organize a library for documentation, complete the handbook, and document the current contract monitoring processes and procedures. This should be completed by June 30, 2016.
With regard to Observation #5, eCSSS not meeting certain business objectives, Luke reported that the eCSSS had several inefficiencies: the Service Verification Module does not allow information to be edited, the program does not populate vendor/contract employee’s information throughout multiple districts, allow for user-friendly creation of ad hoc reports and any system change requests are costly to make.
Some possible impacts to the department in regards to the system shortfalls are: inefficiencies due to duplicate effort and manual creation of reports, less time for staff to develop curriculum or training materials, and errors in billing amounts paid to service providers. The Internal Audit Office stated that they understand that system change requests are costly, but as a leading practice to consider management address these system changes to increase the efficiency and effectiveness of the eCSSS system. Management’s plan included: The Office of Curriculum, Instruction, and Student Support will work with the Office of Information Technology Services to clarify the updated roles and responsibilities of staff as changes are made to the system and continue to collaborate to address identified inefficiencies in the system. The anticipated completion date is June 30, 2016.
Committee Member Brian De Lima asked if the Office of Information Technology Services was contacted to see if the ability to make edits in the system could be corrected. Luke responded that they are currently working on a new system called Infinite Campus to replace the old system. Committee Member De Lima stated that the corrections should be made quickly. Committee Member De Lima asked if the June 30, 2016 completion date is reasonable, will Infinite Campus be implemented by then. The Internal Audit Office was not sure when Infinite Campus was going to be implemented. Luke also explained that the system inefficiencies that were brought up in the report are only affecting the Special Education Section and not the field.
Committee Member De Lima expressed concern that carryover monies are not being used to help special education needs. Luke explained budget carryover funds were not part of the scope of the Internal Audit Office’s review, but it had been discussed with the Office of Fiscal Services and a report would be presented by the Office of Fiscal Services. Committee Member De Lima stated that the Internal Audit Office should have reported that information, which is of critical concern and should be focusing on the process that generates millions of unspent money. He urged the Internal Audit Office to amend the report to reflect the budget surplus discussion.
Committee Member De Lima stated that in terms of personnel, the Internal Audit Office did a good job of identifying problems and asked how teachers will be helped in the classroom. Committee Member De Lima added that money from vacant positions should be used to support and retain teachers. Committee Member De Lima asked if Internal Audit looked at whether the policies and procedures are comprehensive. Luke explained that we asked the Special Education Section for the policies and procedures they had as well as researched throughout the intranet and the numerous memos and notices in the department. Committee Member De Lima appreciated the effort working together and stated that it would be helpful to refer the operational review to the Student Achievement Committee.
Committee Member Williams referenced written testimony from the Special Education Advisory Council regarding Acts 128 and 129 and asked if they are being monitored. Luke confirmed that Acts 128 and 129 allow the Department to monitor students and private facilities if the Department is paying for the students’ education. While the students are being monitored, there is no central database to see how many students are paid for by the Department and when they are being monitored. Committee Member Williams requested that the testimony be referred to the Office of Curriculum, Instruction, and Student Support for consideration.
Committee Member Williams asked about the completion date of June 30, 2016 that is listed for all of the observations and for clarification of what is meant by completion. Luke clarified that the completion date would be when the management plans would be addressed. Committee Member Williams asked that the Board be provided a report on June 30, 2016 to report on the completion. Committee Chairperson Mizumoto asked for periodic updates to see if progress can be made. He was unsure whether including updates in quarterly reports were frequent enough. Committee Member Williams stated that since the report was being forwarded to the Student Achievement Committee, an update can be provided at that time and that the update should come from the Office of Curriculum, Instruction and Students Support, not Internal Audit. Committee Member Williams also wanted statistics on private school students being funded by the Department.
Committee Member Margaret Cox stated that the Committee needs a longer period to discuss special education. Committee Member Cox added that student achievement is more important to monitor than facilities, and teachers have been given an abundance of clerical work for a long time. Committee Member Cox stated that there needs to be a Committee meeting with only special education on the agenda.
Committee Vice Chairperson Horner agreed with Cox, that the Internal Audit report could be used as a blueprint for further review. Committee Vice Chairperson Horner stated that staffing had been a reoccurring issue, and it would take collaboration to resolve it. Committee Vice Chairperson Horner suggested a clerical position helping with paperwork, to give special education teachers the capacity to focus on teaching. There has been work with colleges to create programs for local teacher training. Committee Vice Chairperson Horner mentioned working with community colleges as well to increase the pool of possible applicants and looked forward to a broader dialog on special education.
Ex Officio Committee Member Hubert Minn shared Committee Member De Lima’s sentiments. Ex Officio Committee Member Minn expressed concern with the inadequate data system and stated that the students need more than observations to address problems. He inquired why the audit rating for that observation was low. Luke clarified that the problem with the system is with entering data on contracts in the state office and is not at the school level.
Ex Officio Committee Member Amy Asselbaye arrived at 10:36 a.m.
Ex Officio Committee Member Patricia Halagao arrived at 10:36 a.m.
Committee Member De Lima asked if there is a date for the special education handbook to be finished. Luke replied that her understanding is that the handbook is with the Department of the Attorney General, and the only deadline she had to give was
June 30, 2016. Suzanne Mulcahy, Assistant Superintendent, Office of Curriculum, Instruction and Student Support stated that the handbook has gone between the Department and the Department of the Attorney General several times and she was not sure who was working on it at this time. Committee Member De Lima would like to have a General Business Meeting executive session to bring the Department of the Attorney General in to report on the status.
Student Representative Brennan Lee arrived at 10:37 a.m.
Committee Chairperson Mizumoto asked when the last operational review of the Special Education Program was conducted. Maria Montero, a consultant to the Internal Audit Office from KMH LLP, replied that this report is the first that is strictly operational. Committee Chairperson Mizumoto directed attention to the 17% vacancy rate and the rating of “moderate.” Montero stated that based on the assessment, the findings are significant but not material, so the vacancy rate would be considered moderate. Committee Chairperson Mizumoto questioned whether it was appropriate to rate 17% as moderate, since it seemed like a higher risk rating was warranted. Committee Chairperson Mizumoto stated that a June 30, 2016 deadline to complete all recommendations seems unrealistic and there needs to be communication within the Department to create milestones to track progress. He requested that interim milestones be added to the report. There are broad recommendations for parent communication, but Committee Chairperson Mizumoto asked if the Internal Audit Office has specific suggestions or could work with Department administration to see what they can do. Luke replied that detailed prior suggestions included newsletters and training sessions. Lastly, Committee Chairperson Mizumoto asked why credentials are being checked up to three separate times. Montero explained that the reason is unknown. It could be a teaching and learning issue, but there has been collaboration with the Department of the Attorney General for clarification.
ACTION: Motion to refer the Operational Review of the Special Education Program to the Student Achievement Committee for inclusion and discussion, as well as the following General Business Meeting and executive session (De Lima/Williams). The motion carried unanimously with all members present voting aye.