Results Driven Accountability Effort – Question Five

OSERS‘  Office of Special Education Programs (OSEP)  appreciates the comments and suggestions posted in response to the RDA  questions one, two, three and four.

OSEP will accept comments on question 5 until November 9, 2012.

The Office of Special Education Programs’ (OSEP’s) vision for Results-Driven Accountability (RDA) is that OSEP will target its work and investments to best support states in improving results for infants, toddlers, children and youth with disabilities. OSEP worked internally to develop a set of Core Principles to guide its RDA work.

Do you have  any comments or input on these RDA Core Principles?

Download RDA Core Principles:

The following core principles underlie and will guide OSEP’s RDA work:

  1. OSEP is developing the RDA system in partnership with our stakeholders.
  2. The RDA system is transparent and understandable to states and the general public, especially individuals with disabilities and their families.
  3. The RDA system drives improved outcomes for all children and youth with disabilities regardless of their age, disability, race/ethnicity, language, gender, socioeconomic status, or location.
  4. The RDA system ensures the protection of the individual rights of each child or youth with a disability and their families, regardless of his/her age, disability, race/ethnicity, language, gender, socioeconomic status, or location.
  5. The RDA system provides differentiated incentives, supports, and interventions based on each state’s unique strengths, progress, challenges, and needs.
  6. The RDA system encourages states to direct their resources to where they can have the greatest positive impact on outcomes and the protection of individual rights for all children and youth with disabilities, and minimizes state burden and duplication of effort.
  7. The RDA system is responsive to the needs and expectations of the ultimate consumers (i.e., children and youth with disabilities and their families) as they identify them.

Download the RDA Core Principles:

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14 Comments

  1. SPAN supports the key principle related to development of the RDA system in partnership with stakeholders, but is concerned that OSEP appears to hold the perspectives and input of professional stakeholders more important than that of parents, parent organizations, and people with disabilities including youth and young adults with disabilities who should be at the heart of any stakeholder effort. There appear to be more formal opportunities for state directors of special education to provide feedback directly to the Director of OSEP, for example, than there are for parent organizations.

    SPAN supports the principle that the RDA system should be transparent and understandable to states and the general public, especially individuals with disabilities and their families, and urges the Department to work closely with parent centers and disability organizations including organizations representing youth and young adults with disabilities to ensure that the system is, in fact, transparent to the most important stakeholders, ie, parents and people with disabilities.

    SPAN supports the principle that the RDA system should drive improved outcomes for all children and youth with disabilities regardless of their age, disability, race/ethnicity, language, gender, socioeconomic status, or location, and believes that this requires the RDA system to look beneath overall data to find data on the performance of and outcomes for children and youth with disabilities who are from the most discriminated-against groups, such as low income children, children of color, children who are LEP, etc.

    SPAN supports the principles that the RDA system should ensure the protection of the individual rights of each child or youth with a disability and their families, regardless of his/her age, disability, race/ethnicity, language, gender, socioeconomic status, or location, and believes that this will not be possible if the system only looks at outcomes such as performance on state assessments, especially if the review of outcomes triggers more intensive review without looking at the performance of underserved children and youth with disabilities.

    SPAN supports the principle that the RDA system should provide differentiated incentives, supports, and interventions based on each state’s unique strengths, progress, challenges, and needs, but is concerned that this principle needs to be fleshed out more specifically so we know what it really means.

    SPAN supports a general principle that the RDA system should encourage states to direct their resources to where they can have the greatest positive impact on outcomes and the protection of individual rights for all children and youth with disabilities, but is concerned about whether or not we really know where we can have the greatest impact, and is also concerned that any RDA system must support active and informed parent engagement because we DO know that active and informed parent engagement is key to positive lifelong outcomes for children and youth with disabilities. We are also concerned about the principle of minimizing state burden and duplication of effort; we should, of course, avoid duplication of effort, but “minimizing state burden” is not a principle that should be pursued in and of itself and should certainly not be allowed to result in any diminution of civil rights of children and youth with disabilities or rights of parents to be actively involved in their children’s early intervention, special education, or transition services.

    SPAN supports the principle that the RDA system should be responsive to the needs and expectations of the ultimate consumers (i.e., children and youth with disabilities and their families) as they identify them, especially from underserved and discriminated-against communities.

  2. The Collaboration to Promote Self Determination (CPSD) is a coalition of national organizations that advocates for innovative public policy reform focused on promoting the effective transition of students with intellectual and developmental disabilities into adulthood by preparing them to pursue and obtain optimal outcomes in the areas of employment, economic advancement, and independent living. The undersigned members of CPSD appreciate the opportunity to submit the following recommendations regarding the Core Principles that the Office of Special Education Programs (OSEP) developed to guide its work on Results Driven Accountability (RDA).

    Council of Parent Attorneys and Advocates, Inc
    National Down Syndrome Congress
    National Down Syndrome Society
    Physician-Parent Caregivers
    The Advocacy Institute
    TASH
    United Cerebral Palsy

    Recommendation: Revise Principle 5 as follows:
    The RDA system provides differentiated incentives, supports, and interventions based on each State’s unique strengths, progress, challenges and needs, to the extent these actions reflect the strengths, progress, challenges and needs of the State’s children and youth with disabilities.

    Rationale:
    It is important to clarify that the focus is on the students, not just on the circumstances of the State as an entity. For example, a state that faces economic challenges must still meet the requirements of the Individuals with Disabilities Education Act (IDEA).

    Recommendation: Revise Principle 6 as follows:

    The RDA system encourages States to direct their resources to where they can have the greatest positive impact on outcomes for every child and youth with a disability and the protection of their individual rights, and minimizes State burden and duplication of effort to the extent possible.

    Rationale:
    It is important to more clearly emphasize that decisions to direct resources must benefit every child, not just those who are perceived to be capable of better outcomes. Policy language has referred to “all children” for many years, yet some people still fail to consider students who take the AA-AAS, especially when resources are being directed to have the greatest impact on outcomes. Too many educators still believe these students will have poor outcomes regardless of the resources they are given, instead of understanding that poor outcomes often come from low expectations and the fact that these students may not be given the academic resources provided to other students.

    We agree that it is important to ensure that duplication of effort and the burden on States is reduced, if possible. However, the RDA system should be encouraging States to direct their resources to ensure that students are actually benefiting from the educational services they are receiving. This may involve reducing burden in some areas and increasing it in others. We know that improvement occurred on the State Performance Plan compliance indicators because they were the focus for State determinations. We do not want to lose ground on the outcomes and rights that are related to compliance, because we shifted too much attention away from these indicators.

    Recommendation: Revise Principle 7 as follows:
    The RDA system is responsive to the needs and expectations of the ultimate consumers (i.e., children and youth with disabilities and their families) as they identify them through meaningful opportunities for public input.

    Rationale: The opportunities for public input that have been provided through the RDA blog are appreciated. We hope that meaningful public input will continue as the RDA system is developed and implemented in order to ensure that the needs and expectations of children and youth with disabilities and their families are being met and that any unintended negative consequences are quickly identified and corrected.

    Recommendation: Add an additional Principle as follows:

    The RDA system aligns with and complements States’ accountability systems in order to ensure that students with disabilities are fully included in such systems, including the opportunity to participate and make progress in the general education curriculum and access and achieve proficiency on state assessments used for accountability.

    Rationale:
    Students with disabilities are first and foremost general education students. The RDA system should reflect that understanding by promoting the full inclusion of every student with a disability in the general education curriculum and the State accountability systems.

    Recommendation: Add an additional Principle as follows:

    The RDA system encourages States to support the inclusion of all children and youth with disabilities in the least restrictive environment with respect to their classes, extra-curricular activities and job training experiences, regardless of their age, disability, race/ethnicity, language, gender, socioeconomic status, or location.

    Rationale:
    In spite of the least restrictive environment requirement in IDEA, many students are still being denied access to the least restrictive environment because of their age, disability, race/ethnicity, language, gender, socioeconomic status, or geographic location. It is especially clear from OSEP educational environment data that students with intellectual disabilities, autism, and multiple disabilities are much more likely than most other students with disabilities to be in excluded from the general education classroom all or a large portion of the day. This is especially true as these students get older or if they come from certain race/ethnicity groups and/or from economically disadvantaged backgrounds or from districts with less progressive policies. We also know that this problem exists with respect to the involvement of students with intellectual disabilities, autism and multiple disabilities in extra-curricular activities and job training experiences that are open to other students. In many cases, these trends could be reversed if States focused on Universal Design for Learning and on supports that would make it possible for these students to succeed in inclusive environments.

  3. I am concerned about Principle 6: “The RDA system encourages states to direct their resources to where they can have the greatest positive impact on outcomes and the protection of individual rights for all children and youth with disabilities, and minimizes state burden and duplication of effort.”

    This principle does not appear to conform to the Individuals with Disabilities Education Act (IDEA). Under IDEA states must direct resources in ways that positively impact each child served under the law, regardless of whether a child is part of a cohort experiencing the “greatest” positive impact. Some students do not have high outcomes but require large amounts of resources to receive special education and related services, based on their Individualized Education Program (IEP). A state is not free to redirect resources from those students simply because they are not demonstrating a particular outcome.

  4. The American Speech-Language-Hearing Association (ASHA) is pleased to have the opportunity to comment on the U.S. Department of Education Office of Special Education Program’s Results Driven Accountability outreach efforts soliciting comments on this new strategy to shift the balance from a system focused primarily on compliance to one that puts more emphasis on results for children with disabilities. ASHA is the professional, scientific, and credentialing association for more than 150,000 members and affiliates who are audiologists, speech-language pathologists (SLPs), and speech, language, and hearing scientists. More than half of our members work in public schools and have an integral and active role in the school community. Therefore, education is a priority area for the Association. ASHA members who work in school-based settings provide primary services to over 1.5 million students with speech, language, and hearing disabilities. (2010, Data Accountability Center) The high incidence of speech-language impairments requires a large, highly qualified pool of SLPs to meet these students’ needs. Additionally, school-based audiology services are integral to improving access to education for students with hearing loss through the recommendation of specific strategies and the management of complex technology.

    While ASHA supports the proposed draft RDA Core Principles outlined in the RDA Blog Question 5, we do make the following specific recommendations:

    RECOMMENDATION: Amend Principle #5 by adding the word in quotation, so that it reads as follows:
    5. The RDA system provides differentiated incentives, “appropriate” supports, and interventions based on each State’s unique strengths, progress, challenges, and needs.

    RECOMMENDATION: Amend Principle #7 by adding the sentence in quotation, so it reads as follows:
    7. The RDA system is responsive to the needs and expectations of the ultimate consumers (i.e., children and youth with disabilities and their families) as they identify them. ” This includes ensuring that families are knowledgeable about their rights and responsibilities and have full knowledge of the credentials for each service provider working with their child.”

    Thank you for the opportunity to provide these comments on behalf of ASHA’s members and the students they serve.

  5. I truly believe that all teachers desire their students to achieve. I also believe the very best reading, math, or English teacher cannot lead/teach a student whose disability is so significant the he/she can achieve grade level mastery of skills. As a school psychologist, I know the expectations that parents/guardians hold for their children; however, I also know that I, the best teachers, or medical doctors cannot find the solutions to make everyone meet the same standards. Each of us is unique – but when it comes to education we are all the same? I do not need a test to provide information about a student’s reading abilities, when that unique student hasn’t mastered some basic life skills. Now I ask, “Which is most important, teaching a twelve-year-old to read or working on toilet-training for health and comfort wellness?”

    One would never demand a vision impaired individual to just look a little more to see or a hearing impaired person to try and listen better, why should we ask a person whose cognitive impairment to achieve academically is more than possible? It is true that one’s disability doesn’t define the greatness that can be accomplished by a disabled human; but, by ignoring the limits of individuals, we may be placing obstacles in their pathway to greatness. I think that is just as dangerous as limiting access to the pathway in the first place.

    Accountability is always a concern for all of us. Academic testing is only one manner of measurement. If we don’t use a valid and reliable method of assessment to help us solve problems with student achievement, improve instructional methodologies, help prepare those who can enter into competetitive workforce, then this is another gross misuse of money, time, and other resources. This one size fits all is just another lie.

  6. The Office of Special Education Programs (OSEP) has been a primary part of the development of a system of parent driven stakeholders over the last twenty years. Parent Training and Information Centers (PTI’s) and Community Parent Resource Centers (CPRC’s) are at the heart of a national partnership to enhance advocacy, support and training for children with disabilities and their families. If at this point OSEP is moving away from direct testimony of parents as part of overall performance review of programs, then we need to make sure that there is a new design for parent driven evaluation and input regarding program outcomes.

    A level of expertise and engagement has been developed in states throughout this country. We must find significant ways to infuse that expertise and those experiences into the new Results Driven Accountability System (RDA). The PTI/CPRC Network has been charged with providing the kind of support and training necessary for parents of children with disabilities to achieve an understanding of rights and responsibilities. If the RDA system is being charged with assuring the protection of individual rights for children with disabilities then the PTI/CPRC Network should be an important part of this new configuration. One of the most important aspects of the work we have learned over these years is that the underserved community needs true supports if its participation is to be meaningful.

    If the Annual Performance Review (APR) is to be re-aligned as part of the RDA system the PTI/CPRC Network should participate in developing and designing new indicators. Parent engagement will be required at every level if the core principles are to have the kind of credibility needed for true accountability. If the substance of the core principles is intended to drive improved outcomes then new standards must be articulated within the APR structure, which reflect the true concerns of families.

    Given the changes to public education being driven by privatization and other reforms, it is important that RDA in special education function as a way to highlight and/or upgrade the protections contained in the Individuals with Disabilities Education Act (IDEA). Some issues have not been addressed in the past through the Annual Performance Review (APR). Equity, in terms of the allocation of resources, is one of those issues. In working with families over the years this is a concern, which has continued to surface. Children with disabilities must have access to supports and services if programs are to be delivered effectively. The excellence, which has been sought by everyone working in the arena of special education, has been elusive. Parents, as well as advocates and administrators have experienced this frustration. If our collective goal is to achieve better outcomes then equity and excellence must be fused into our new Annual Performance Review.

  7. “The RDA system encourages states to direct their resources to where they can have the greatest positive impact on outcomes and the protection of individual rights for all children and youth with disabilities, and minimizes state burden and duplication of effort.”

    The wording of Core #6 may leave underrepresented groups out of resource allocation if they are deemed not to have the greatest impact due to the groups smaller makeup in various states. All groups should be supported regardless of where the child resides with national proven best practices.

    The wording of Core #5 is concerning here as well as it again seems to defer to what each state deems important at the moment instead of holding the progress of all groups on equal standing.

    Additionally, RDA should be based on real outcomes and opportunities, not just on accountability measured from test scores. Results should look at what percentages of students with disabilities are in various types of courses within the state, Gen Ed vs. AP vs. Modified Curriculum. How many of these students are graduating and what types of diplomas are being assigned to them, how many are going on to college. That is true results and accountability and RDA should rest within those real outcomes and how they increase over time.

  8. WE need to bring back the accountability over the state departments of education by the USDOE/OSEP/OSERS. As it stands now, our state has developed a ridiclouls state complaint feature which includes “simultaneous” notice to the district of the complaint. They wait months to tell parents they did it wrong because it was not submitted “simultaneously.” Even where the complaint is sent to the district within minutes of the state filing, they will reject it.PArents with no access to email are shut out entirely. Additionally, because district administrative positions pay so much more than state DOE jobs, the investigators are often far more interested in developing collegial relationships with local districts to hop into one of those more lucrative positions than they are in doing what is right for children. When they blow it on a state complaint, there is no longer an appeal to a higher authority, even where the mistake will have a deliterious effect on children statewide.
    Graduation rates for ALL children with disabilities must be tracked and improvements tied to increased funding. Accountability to some kind of real evaluation standard for children confined to segregated and institutional schools (vineland, ABAS, something!). Public reporting of the use of aversive interventions and seclusion (which should NEVER be allowed) and restraints of students with disabilities by district program. Public reporting of progress by students with disabilities in segregated schools. Public reporting of the length of time students with disabilities in segregated schools are bussed. (and requirements to reduce ride times to no more than 30 minutes either way.) Unhook PTI funding from state department of education approval, allowing agencies to operate on behalf of children without concern for losing the funding. Require public reporting of the amount of special education dollars spent for teachers (defined as at least 300 minutes a day in a classroom) and curriculum/evaluation materials, from all other administrative funding, with a target for reasonable administrative costs (10%?). A district that is too top heavy indicates that money is not reaching the level of the student and is instead creating a plethoria of meeting-attenders and administrators who do little or nothing to improve outcomes for actual children.

  9. I really have to wonder what kind of oversight and accountability there is.
    Who is really watching.
    Huge reams and mountains of paperwork are not the answer.

    While it seems better than when it was a few years ago, in our school system it has been obvious that they feel they can just do what they want. If that means failing to offer the required services. which include something as basic as Special Ed Instruction in Math for my son, then, so what… The child, my son, is being left behind.

    Our school system has always insisted on having my son, who has a very serious disability that involves deficits in math skills, participate in the regular ed., grade level, math curriculum. Not appropriate, at all.

    And, as some have mentioned, LRE is the HUGE and abused smoke-screen that they use to get away with this.

    They use this to absolve themselves of any responsibility to provide that staff, resources, services, etc. that are required by law, as they are mandated to actually help to teach my son Math.

    1. Who is watching? REALLY
    2. We need to address the use of things like LRE being abused and used as an illegal smoke screen.

    • The Illinois State Board of Ed had issued a mandate that we get a certain percentage of students into General Ed, or else. We are closing our our fabulous supported, small group instructional classes and programs. We are wheeling our students (literally) with one on one’s sitting in the back of the easiest classes, trying to control their frustrations-sitting where they can’t be engaged because they don’t have a clue to the standards their same age peers are learning. These students KNOW the other students are working on things they are not. This is NOT the choice of the school administrators! AND we can’t teach them what they need to learn based on their individual assessment data! PLEASE place blame where blame is due! The government policies! And yes, parents who are forcing, because they “believe” the student will be normal if they are with normal kids, full inclusion for all.

  10. While I would support the core prinicples currently devised, I would add support the research and disseminatation of replicable, research-based practices that clearly demonstrate they support improved student performance.

    For example, while there is a great deal of support for LRE – do we have replicable research data that supports that students instructed in those environments achieve over students educated in other environments? And if so, what supports are needed (are required) to be in place to get those results? And if the supports cannot be offered by a system, where should the child be best educated – or does the research suggest the evidence is SO STRONG that LRE with specific supports should be required to be provided? Does it hold true for ALL/SOME/FEW students with specific special education disabilities?

    There are many research-based practices, such as curriculum adaptations imbedded into the curriculum, that we KNOW benefit all kids. Any yet they are not required for all curriculum – why?

    We neecd to throw all of our assumptions on the table and test them ALL. We may find as we did in the case of reading instruction, that long-held beliefs are just WRONG. Because people believe something strongly, that belief does not make it true.

  11. I think it would be a great idea to get the federal government out of education. There is always the ax of non-compliance over our heads and the threat of not receiving the small amount of $s provided. I am not certain that OSEP ever receives honest feedback from the field. The paperwork is killing us and there is less $ every year. This year the Medicaid billing was about destroyed. We lost about 1/2 of what we had been billing. And the so called research (RMTS) is a ridiculous waste of time and $s.

    • Our district spends 62% of it’s income on the 12% of students with IEP’s. We keep students through 21, without additional funding. Yes, protect rights not dreams and beliefs. BTW College is not an educational right. What on earth? Higher Education means “higher thought processes” not higher years old.
      Give that 11.9 million grant (discrimination of students with intellectual disabilities really?) Back to those you made responsible for their education through 22. The definition of intellectual disability is significant limitations both in intellectual functioning and in adaptive behavior. Yeah, let’s see why they are not being accepted where expectations were one does “significant theoretical and abstract elements, as well as applied aspects” Wiki

  12. Perhaps Principle 2, (transparent and understandable) might include how “accountability” will be expressed – i.e. in what form and how often will results be made available to the public

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