Special Education Program National Data Collection

Special Education Program National Data Collection

First Nations Position – BC Region

FNESC/FNSA

Background

Since the inception of the Special Education Program (SEP), the First Nations Education Steering Committee (FNESC) and the First Nations Schools Association (FNSA) have been approved by both BC First Nations and Treasury Board to administer the SEP in BC.

Through extensive consultations with BC First Nations, it was decided and approved prior to the onset of the program, that SEP funding would best meet the needs in First Nations schools if it was administered by formula in what has since been called an “Intervention-based” approach. First Nations schools are notified of their allocation and access it via a workplan that outlines the use of the SEP funding and a budget breakdown of costs. First Nations schools have also consistently provided a report on their SEP expenditures each year as well as completing the First Nations School Annual Report required by INAC. A detailed aggregate report on all activities, both at the school level, and those organized provincially by FNESC/FNSA is submitted to INAC in July each year along with the First Nations Regional Management Organization (FNRMO) Report required by INAC. Recognizing the need for accountability to both First Nations communities and INAC, BC First Nations have consistently provided a level of reporting that exceeds the requirement of the SEP and that is reflective of the Intervention-based approach used in BC.

The use of the nominal roll as a method of collecting special education data has long been considered problematic by BC First Nations. When the special education column on the nominal roll first appeared in 2003, there was concern from First Nations in BC about student confidentiality and the challenge of identifying students in this manner given the Intervention- based approach used in BC. The inclusion of this data collection on this form, and the intended use for the data was not communicated by INAC at that time. As a result, the FNESC board passed a motion supporting schools in not providing this information on the nominal roll form and to continue developing data collection processes that better reflect the Intervention-based model that is supported by INAC.

Recognizing the need for data in this area, FNESC/FNSA developed a comprehensive data collection tool that is a good fit with the Intervention-based approach. The results were reported at the 2007 FNSA AGM and included in the reports to INAC. From this data, incidence rates of special needs in First Nations schools and funding comparisons to provincial schools have been determined. Unfortunately, because the majority ofFirst Nations schools in BC were not reporting their students with special needs on the nominal roll, the data did not match the numbers on the nominal roll of the same year, and its validity, along with other regional approaches was questioned during the national evaluation of the SEP. At the 2008 FNSA AGM, the FNSA membership voted to identify students with special needs in the existing column on the nominal roll (identified as either a 1 or 4), as well as to continue to collect and report data using the FNESC/FNSA data collection tool that was developed and approved.

The recent changes to the nominal roll form raises further concerns, all of which were raised at the July 2008 SEP working group meeting with INAC in Ottawa where revisions to the nominal roll were first proposed.

Summary of Changes to INAC Nominal Roll Reporting by First Nations

Effective 2009-10, INAC will require First Nations to submit detailed information on all High Cost Special Education (HCSE) services provided to students on the Nominal Roll (NR), on a student-by-student basis. Previously, the NR form asked First Nations to identify only whether a particular student received HCSE services (yes/no). The revised form requires First Nations to provide the following information by October 15 each school year student-by-student:

Information About Students

Student identifier number (band – family - child position)
Professional assessment status
Individual Education Plan (IEP) status

Information about Services

(For each service, First Nations must indicate whether services were required in the previous year, if the services previously provided were adequate, and if further services are required in the current year)

Qualified Special Education Teacher
Individual Teacher Aide
Educational Psychological Services
Counselling Services
Speech / Language Services
Occupation / Physical Therapy
Instructional Materials and Assistive Technologies

Challenges with Revised Nominal Roll Form

The following section describes the identified challenges with the revised nominal roll form. It has been organized into categories of areas of concern.

Quality/Validityof Data

Person Completing the Form

At the community level, the people who fill out the nominal roll are most often the education coordinators, and they do not have the level of information on individual students required to complete the revised portion of the form. As a result, they will have to consult with the teachers who have students with special needs in their classrooms. For a large number of communities, this will mean consulting with many teachers from several different schools, both band-operated and provincial.

Teachers completing the forms will also most likely not be knowledgeable of how the services are funded, so they will most likely input all services accessed by the students regardless of how they are funded.

Timing of the Nominal Roll

The timing of the nominal roll will also impact the quality of data collected. September 30th is the cut-off date for data collection with October 15th as the deadline for the submission of the nominal roll. At this time of year, teachers are getting to know their students. They may not have a good sense of the types of services needed, nor the adequacy of the services provided in previous years. As such, they will have to consult with teachers from the previous year to be able to accurately report some of the data at the beginning of the year. This will be particularly challenging for the teachers of any students who have transferred from other schools, and whose files have not yet been transferred. In the fall, teachers will also be developing/updating Individual Education Plans (IEP), so any data pertaining to IEPs at this time of year will be skewed and not reflective of the IEPs in that school year.

Level of Nominal Roll Participation in BC

Due to individual negotiated agreements between First Nations and Canada, several communities in BC do not report students on the nominal roll. This constitutes approximately 10% of the student population in First Nations schools in BC. The data pertaining to students attending schools in those communities will not be included if the nominal roll form is the tool used, so the data will be inaccurate.

Wording of Headings

The wording of several of the headings is subject to interpretation from region to region and from school to school, rendering the data under those headings to be invalid. For example,

the term, Qualified Special Education Teacher is problematic. In BC, there is no provincial certification criterion or process for special education teachers. In the BC provincial education system, school districts determine their own criteria for being eligible to be considered a special education teacher. In addition, other terms for the same role are used such as Learning Assistance Teacher or Learning Resource Teacher. It will be unclear how to respond to this section for teachers completing the form.

Another problematic term on the form is Individual Teacher Aid. Many teacher assistants work with more than one student, sometimes in small groups organized by ability. These teacher assistants will then not be included on the form if it is solely focused on one teacher assistant working with one student. Teacher assistants may also be counted twice depending on the interpretation of this section. A teacher assistant may work with more than one student on an individual basis at different times during the day/week. They would then be counted for each of the students they work with.

Two categories are linked together in the heading Instructional Materials and Assistive Technology. These are very different and the cost for both can differ significantly. It would be prudent to separate the need for assistive technology as a stand alone category to determine the needs in this area.

At the top of all of the Services, is the heading INAC Funded High Cost Special Education Services Provided Last Year and Required This Year. As previously indicated, it is anticipated that there will be confusion in this section for the following reasons

-Many schools supplement SEP fund with other INAC program funds and from the core budget. Since these are also “INAC Funded”, they will be included and services provided by SEP will not be isolated.

-Provincial and First Nations schools in BC will most likely have difficulty with this section as the teachers completing the form will most likely not be knowledgeable of how the services are funded.

Determination of Specialist to Student Ratios

The way the nominal roll form is currently laid out, it will not be possible to determine the number of counselors, special education teachers, teacher assistants, and other specialists working in schools. The form focuses on students receiving services, but not the numbers of staff providing the services. This is important in determining appropriate student: staff ratios.

Type of Data Collected Will Not Support a Case for Increased Funding

The intention of the data collected on the form is to demonstrate that students with High Cost Special Needs are receiving services through SEP, yet there is no linkage to the funding used to provide the services. Out of necessity to meet the high needs in First Nations schools with limited funding, many schools pull funding from other areas. This results in deficits in other program areas and services, and the shortfall of the SEP is not documented.

There is also no indication of the extent or types of special needs in First Nations communities. Although this information should not be collected by INAC on the nominal roll, it needs to be gathered in order to more accurately reflect the need for resources. Incidence rates can be used to compare provincial funding levels per category and more clearly demonstrate funding inequities.

Incongruent with the Intervention-based Approach

As more regions move to an Intervention-based model, an approach supported by INAC and Treasury Board, it is important that any form of data collection be reflective and supportive of this approach.

In addition to conducting specialized assessments to determine areas of student need and the provision of services to address specific disabilities, the Intervention-based approach also enables schools to address the needs of students who are having difficulties but who would not yet be considered eligible for a moderate to severe designation. For some disabilities, providing services during critical times of brain development can facilitate the formation of neural pathways that will last a lifetime. By the time some of the students’ disabilities would be determined severe enough to be considered eligible for the SEP, the window of opportunity for mitigating some of the severity would be lost. The proposed nominal roll data collection process neglects this key aspect of an Intervention-based model.

The other key area of an Intervention-based model that the nominal roll method omits is training, both of school staff and community members and parents. The holistic Intervention-based model addresses all areas and includes the need for training. Any data collection method should include this aspect.

Student Confidentiality

It has been well documented in the 2003 motion of the FNESC board and in discussions at the FNSA AGM that First Nations are concerned about the level of student specific data collectedand required by INAC. Increasing the amount of individual student information on the nominal roll is not supported and will need to be discussed at the 2009 FNSA AGM.

Politically

Reverting to the nominal roll is a step backwards. This contradicts the sentiment of Indian Control of Indian Education and the more recent passing of provincial and federal legislation recognizing the inherent right of First Nations jurisdiction over the education of their children. In order to provide education in an effective way, First Nations must also control the data collection pertaining to the education of their children. If collected via the nominal roll, First Nations will have no access to or control of the data, its quality and its use.

Lack of Meaningful Consultation

After the national SEP evaluation, INAC developed an Action Plan to address some of the criticisms that were raised. The majority of actions listed to address the issues state that INAC HQ will work with regions and First Nations, including the development of revised reporting mechanisms. Although there was a meeting of the SEP Working group and INAC in July 2008, the concerns raised regarding the nominal roll at that time were disregarded. The form was developed by INAC and then shared with First Nations, at which time First Nations were told the process was a “done deal”.

Current Direction - BC Region

Recognizing the need for SEP data collection, FNESC/FNSA have developed a data collection tool that includes the following information.

Information About Students

Student Identification
Student Assessment (by specialist or school staff)
Gender and Grade
Individual Education Plan (IEP, yes / no / in progress)
Persistent Learning Disability
Communication Disorders
Fetal Alcohol Spectrum Disorder
Intellectual Disability (moderate, severe)
Behaviour Disorder – Acting Out (moderate, severe)
Behaviour Disorder – Internalizing (moderate, severe)
Autism Spectrum Disorder (moderate, severe)
Physical Disability (moderate, severe)
Hearing Impairment (moderate, severe)
Vision Impairment (moderate, severe)

Information About Services

Activities identified in the First Nation’s workplan and budget for each student are numbered and associated with individual students so that exact information about services (service type, actual cost) can be derived for each student.

FNESC/FNSA enters all information captured from all schools in Workplans and Student Data Collection Forms in a Microsoft Access database; FNESC/FNSA program staff work directly and extensively with communities on the submissions to provide guidance and support in the service delivery planning process, and to ensure data accuracy.

This process results in a data set that allows for in-depth analysis to inform program management practices and support accountability. For example, FNESC/FNSA is able to determine the level of investment in specific types of services and cross-reference this with students’ assessed needs (incidence rates) to provide a complete picture of program funding requirements and trends, including comparisons with provincial programs and services.

FNESC/FNSA along with the INAC BC Regional office is currently exploring alternative options for providing SEP data to INAC, including pulling the information being required on the revised nominal roll from the First Nations schools special education database controlled by FNESC/FNSA. These options will be presented to the FNSA membership for discussion and direction at the April 2009 FNSA AGM.

Figure 1 on page 8 compares the data collected by both systems. This comparison highlights the ability of FNESC/FNSA to provide the needed data to INAC. The benefits of such an approach for First Nations schools are significant. The data remains controlled by First Nations, and the type of data collected is more meaningful and reflective of an Intervention-based approach, and thus better meets the needs of First Nations. In addition, many of the challenges listed that will be incurred by adding the data collection component to the nominal roll will be alleviated for First Nations schools. Portions can be extracted to meet INAC reporting requirements. It is recommended that the possibility of a similar national approach be explored.

Figure 1: Comparison of Data collected by INAC and FNESC/FNSA

INAC Nominal Roll SEP Data Collected / FNESC/FNSA Workplan Data Collected / Overlap
Student Identifier Number / Student Identification (currently initials) / There would need to be a consistent student identifier agreed upon. Consultation with and recommendations by First Nations to be done.
Professional assessment status / Assessment (by specialist and school staff) / Same data
Gender / Gender / Same data
Grade / Grade / Same data
IEP status / IEP Status / Same data
No data / Special Education Categories (see listing p.6) / FNESC/FNSA collects detailed categorical information which enables better understanding of the nature of special needs in First Nations schools. It also enables funding comparisons to province.
Qualified Special Education Teacher / Each student is linked to the school workplan activities/services that support them. Data can be pulled/queried by categories listed on the left to determine access to those services for each student. The cost of those services can also be determined including a breakdown of SEP funding used and other funding used. / FNESC/FNSA data enable more in depth analysis of funding sources for SEP services. Accountability for SEP funding is possible as it is linked to students with special needs.
Individual Teacher Aide
Educational Psychological Services
Counselling Services
Speech Language Services
Occupational Therapy
Physical Therapy
Instructional Materials and Assistive Technology
Service Provided last year? / Available in year to year records / Since this data will be collected each year, it will be known which students received services each year. This will be pulled from records.
Adequate? / Not collected / Not collected by FNESC/FNSA currently but can be added
Required this year? / Not collected / Unmet needs section will need to be added.

FNESC/FNSA SEP Data Collection – BC Region February 2009 Page 1