ESE Paperwork Is Simply Not Doable
The following post is long overdue. It was a brutally tedious post to put together, mostly because it deals with one of the very most problematic aspects of public education. I’d like to thank all of the teachers who shared resources, documents, and their time in order to get this post done. It is, unfortunately, somewhat abbreviated with respect to a full description of the paperwork load plaguing ESE teachers, but we felt like we were nearing the point of information overload, or the point at which the reader just decides that it’s too tedious to even read.
A Real Mountain of Paperwork
The paperwork burden associated with ESE has become so fantastically unreasonable that it really is imperative that a thorough audit be taken of just how much paperwork is required for one ESE student in one year.
All of this paperwork must be completed by ESE classroom teachers, in addition to all the usual tasks associated with actually teaching.
Florida ESE teachers are fortunate to have the veritable bible of IEP writing handy: the trusty Developing Quality Individual Educational Plans: A Guide for Instructional Personnel and Families, by Marty Beech, Ph.D., and published by our friends over at the Florida Department of Education Bureau of Exceptional Education and Student Services, who were generous and kind enough to publish this fine work in their spare time, when they’re not passing down new “compliance” orders of one sort or another.
We’ll refer to the guide as the need arises.
In order to produce a proper IEP, one must have a thorough understanding of a given student’s priority needs. In high school, that includes each ESE student’s “transition needs.” For an ESE teacher, this mission is above and beyond the usual IEP related responsibilities that ESE teachers already have, which, amazingly enough, are themselves above and beyond the customary responsibilities of a classroom teacher.
Essentially, transition paperwork is the second layer of horse manure heaped on top of an already stinking cow patty of a job in public education, largely thanks to politicians’ skillful manipulation of public opinion and parental perceptions.
Now is a great time for ESE teachers to count their blessings, at least in Pasco county, because they know all too well that things can always get worse, and probably will.
High school ESE teachers in Pasco County have been issued a handy Transition Teacher Timeline of Responsibilities. It lays out the job requirements very succinctly. It also illustrates the sheer stupidity of current expectations regarding ESE teachers. It points to the fact that the vast majority of influencers in public education policy are totally disconnected from the school-level reality they have helped to create. It is all but impossible to be a good classroom teacher while simultaneously keeping up with all the paperwork and documentation requirements associated with being an ESE transition teacher.
Now, there is no actual “transition teacher” position in the sense that a candidate can apply. It’s just what they call high school ESE teachers in order to heap a whole bunch of extra responsibility on them. The so-called “transition teacher” job is itself an extension of the “case manager” job.
Both designations show what happens when lawmakers pass education mandates that are never adequately funded. New compliance requirements are passed down from the Great Castle to the peasants in the schools on a regular basis. The workloads of case managers only grow. An all-too-familiar slogan at the district office is, “Have the teachers do it.”
According to the movers and shakers and policymakers over at the Pasco County Schools Office for Student Support Programs and Services, “Case managers are responsible for managing all aspects of the student’s education and maintaining the integrity of the student’s ESE files.” That’s verbatim, taken right off the first page of a PowerPoint presentation hosted by the district experts.
Due to IDEA, NCLB, and ESSA and a slew of related federal laws and rules, we are now in a desperate situation where there is simply no earthly way for teachers to satisfy all the requirements. There is just too much required of teachers, and too little required of everyone else. It is a system seemingly designed to fail, where “failure” naturally gives rise to increased calls for “more accountability,” privatization, charterization, and, ultimately, corporatization.
Countless politicians, having treated public education as election fodder for so long, have largely succeeded in creating a situation that is unsustainable. It might just be exactly what they want. It’s the perfect paradigm for those who want to blame public education and replace it, as it is frequently hamstrung by the very people who are charged with advancing it. Rather than offer genuinely substantive ideas designed to help move public education toward excellence, many politicians instead posture in order to somehow cash in on its oft-forecasted demise. Ese paperwork is one very acute symptom of a very sick system.
Of course, choice is the central theme in the incantations of the public education raiders who promise a magical transformation if we only allow them to privatize education. It is worth mentioning that those who incessantly beat the school choice drum never mention the absolutely insane workload literally heaped on “teachers.” The combination of the choice theme with the teacher accountability gimmick, coupled again with the virtual absence of any accountability for anyone else, plays well on the emotions of largely ignorant parents who are understandably fixated on getting every possible “service” under the sun delivered to their kids at whatever cost necessary to anyone else, and minimal cost to themselves.
Let’s be honest. This is America. Anyone who thinks that business interests don’t salivate at the unrealized profit potential that might be extracted from the public coffers in the name of school choice is woefully misguided.
The IEP Writing Process: A Very Brief Summary
Before writing an IEP, a case manager needs to get written input from all stakeholders, since verbal input is just not adequate. Input forms must be distributed to the student, parent(s)/guardian(s), and of course, at least one general education teacher, even if the student doesn’t have a general education teacher. The case manager needs to get permission from the parents to invite an agency or two to the IEP meeting. Of course, that’s another form. It must be distributed a second time if the first issuance fails to secure parental consent. Attempts to Obtain Consent must be documented.
Next, the case manager is required to send out a Notice of Meeting (formerly called an invitation) to everyone.
To be fair, this menial part of the overall process used to be even more tedious. Pasco teachers used to be required to send a different version of the invitation for each attendee, specifically noting that it was to the parent, or the student, or an agency. It’s only because the district adopted the Florida IEP writing platform, located online as a part of the Portal to Exceptional Education Resources or (PEER), that Pasco teachers can send out one version to every attendee. PEER can be accessed (as a guest) here.
Anyway, in keeping with their arbitrarily designated role as repository of all information and documentation-in-the-making, ESE teachers are required to make parents aware of the Procedural Safeguards (courtesy of Congress via the USDOE). Procedural Safeguards are essentially a list of rights that parents and students have while dealing with any given school district ESE department. In the past, case managers have had to issue the parents a Procedural Safeguards booklet every single year. Later teachers were allowed to provide a brief written summary of the Procedural Safeguards, which were to be reviewed at every IEP meeting, along with information about how they can get the unabridged version. Even parents thought annual issuance and review of Procedural Safeguards was tedious and stupid. In a miraculous show of common sense, teachers are now only required to document that the parents are aware of how to obtain a copy. Most continue to get a signature from parents lest they be found guilty of failing to provide the information.
It is fair to ask why teachers are required to distribute so much information to parents in the first place. It could easily be centralized and streamlined, thereby relieving ESE teachers of a very unnecessary burden. Instead of passing down an endless stream of **ACTION REQUIRED** emails directing teachers to pass information along to parents, the staff at the district office could establish an Office for ESE Information (Browning loves offices “for.”) from which all pertinent information could be obtained by parents annually. Parents would then have a single source for all of the general, nonspecific information related to their kids’ educations. Teachers could then stick to the nuts and bolts of IEPs, and the information specific to each individual student they serve, and even spend more time teaching.
Even better, virtually all the information that ESE teachers are currently required to distribute to parents, and document that that they have, could be made easily available, aggregated on the Florida DOE website. If parents don’t have access to the internet, then they could sign up for a mailing list.
Before a case manager can write an IEP, a transition interview or two, as well as a transition assessment, will need to be conducted. The Student Input Form, together with the student’s grades and teachers’ observations, is not adequate. A student’s classroom performance is only part of the copious amount of information required to produce an IEP. Teachers have no choice but to leave the curriculum, which they are already hard pressed to get through in a school year, in order to “interview” the students, “assess” their transition needs, and “manage” their transition to post-school adult living.
There are literally hundreds, perhaps thousands, of so-called “transition interviews” and “transition assessments.” An ESE teacher is not allowed to use the same instrument on any given student for two consecutive years, so administering these things is just that much more of a big pain in the ass.
The transition component of IEPs marks a gigantic usurpation of parental responsibility by the government. No one noticed. We’ll have to get back to that too.
While the government took responsibility away from the parents and foisted it upon classroom teachers, it still requires teachers to ask parents for permission in order to involve any government agency in assisting with students’ transition needs. This is absolutely fucking insane. The teacher shouldn’t be involved in half of all this bullshit to begin with, but since no one else in the entire service chain wants to do it, everyone decided to foist it on the teachers.
Moving forward through this seemingly inescapable morass, case managers mustn’t forget to assess each student’s progress toward his or her IEP goals and their associated objectives (or) benchmarks. Students have either objectives or benchmarks, because using the same method for all students is just too sensible and overly efficient. Every student’s progress toward every goal and objective must be documented in the student’s IEP Quarterly Goal Progress Report. This is in addition to the academic grades submitted twice per quarter.
The case manager is required to author a Present Level Statement (PLS), for every Domain or Transition Service Activity Area (whew) in which each student has needs. An IEP may easily address six, seven, eight, or in some cases, even ten or eleven areas.
According to Marty Beech, PhD, the author of the aforementioned manual, The PLS “contain(s) comprehensive and understandable information about the student’s needs related to the disability, based on data from a variety of sources across applicable domains/transition service areas.”
Beech is a veritable IEP savant, so we’d better listen.
A few paragraphs later, Beech spells out the composition and purpose of the PLS in more zealous detail:
The statement of the student’s present levels of academic achievement and functional performance provides an objective synthesis of information. It includes a description of the following components:
• The student’s strengths and what the student is currently able to do,
• How the student’s disability affects involvement and progress in the general education curriculum or participation in appropriate activities and
• The student’s educational needs.
The information in the present level statement provides the baseline for the development of the rest of the IEP. The statement may incorporate the results of the student’s evaluations, state and district assessments, transition assessments, classroom performance, and other relevant information. The annual goals, accommodations, services and placement decisions documented in the IEP should be based on the information about the student’s needs contained in the present level statements.
That’s a tall order for a person who is supposed to be spending the majority of the day teaching and managing a classroom. That’s okay though, because after we’ve written several dozen of these monstrosities we have begun to realize that the academic/curricular part of teaching is just smoke and mirrors designed to provide a reliable facade for our real role as paper mills fixated on compliance and the avoidance of liability for the district. You see, when the parents sue, the district has cleverly put the teacher squarely in legal crosshairs. If something doesn’t get done, well, it’s the teacher’s fault. After all, the district told the teacher to get it done.
So, fuck the curriculum; let’s just make sure this mountain of paperwork is done really well, documented, and filed real nicely.
Anyway, now it’s time to write goals associated with their respective Present Level Statements, and based on the progress toward the previous goals we’ve recorded and documented (in addition to academic grades).
Our trusty authority on IEPs schools us on what goals are all about:
A measurable annual goal is a yearly target that addresses a student’s educational needs that result from the student’s disability identified in the present level statements. It describes the specific or target skill or behavior to be mastered within 12 months in measurable (observable) terms. Two key phrases guide the IEP team in setting measurable annual goals:
• Meet the needs that result from the student’s disability to enable the student to be
involved in and make progress in the general education curriculum.
• Meet other educational needs that result from the student’s disability.
The IEP team continues with the first and second step in the problem-solving process embedded in Florida’s MTSS (FDOE, 2011). The IEP team will establish annual goals and short-term objectives or benchmarks, if applicable, and then complete the third step when it determines the special education services and supports the student needs.
Holy shit. This is really starting to get all encompassing here.
Luckily, Beech condenses everything about Present Level Statements and Goals into a handy guide so teachers quickly understand just how hopelessly impossible the job is.
Present Levels of Academic Achievement and Functional Performance and Measurable Annual Goals
Step 1. “What exactly is the problem?”
Define, in objective and measurable terms, the goals to be attained. Determine
the discrepancy between what is expected and what is occurring.
Step 2. “Why are the desired goals of the student not occurring?
What are the barriers?”
Identify possible reasons why the desired goals are not being attained. Generate hypotheses (reasons) why the student is not attaining the goals. Consider factors involving the student, curriculum, instruction and learning environment. Special Education Services and Supports
Step 3. “What are we going to do?”
IEP Progress Monitoring and Reporting to Parents
Step 4. “Is it working?”
It seems so much simpler and easier to do now, especially with all the extra time teachers have after instructing and grading and managing student behavior and dealing with all the other tasks that come with actually teaching.
Anyway, every goal has several components: the Mastery Criteria, usually expressed in a percentage or ratio of successes to attempts, the Assessment Procedure(s), which describes how progress will be assessed, an entry that shows how often progress will be reported, and of course, at least two Short-term Objectives (or Benchmarks).
After the goals section of the IEP is completed, the ESE services section needs to be properly completed. It’s a complete list of any and all ESE services a student is to receive for the duration of the plan. The case manager has to recreate the list every year, even if nothing has changed.
After that, the assessments section needs to be done. It lists every assessment a student is going to face during the upcoming year, and what accommodations are needed in order for the student to be “fairly assessed.” I’ve never really understood how accommodations for certain students on an assessment are fair to the students who don’t get them, but whatever.
This thing is a monster that must be fed.
After that exercise in clerical tedium, it’s time to move on to more clerical tedium. Case managers need to document any and all Related Services each student needs, such as special transportation, or certain therapy services.
If the student requires special transportation, then it’s the teacher (yes, the teacher) who arranges for it, by filling out all Transportation Service Form (formerly known as a Special Transportation Request), and sending it, along with copies of the front page of the IEP, the signature page, and the “services page,” to the transportation department.
Now we need to consider Supplementary Aids and Services. Here’s what ol’ Doc Beech has to say about the subject:
Supplementary Aids and Services
IEP-16. The IEP contains a statement of supplementary aids and services,
including location and anticipated initiation, duration, and frequency. (34
CFR §300.320(a)(4) and (7))
IDEA identifies supplementary aids and services as a separate category of services, including aids, services and other supports that are provided in regular education classes or other education-related settings, as well as in extracurricular and nonacademic settings. These aids and services enable students with disabilities to be educated with students without disabilities to the maximum extent appropriate in accordance with the LRE decision-making process.
The distinction between supplementary aids and services and special education and related services is primarily the intent or expected outcomes of the services.
• Supplementary aids and services are provided in regular education classes or
other educational settings to enable students with disabilities to be educated with students without disabilities.
• Related services are provided to enable the student to benefit from special education services.
It may be helpful to think of supplementary aids and services as accommodations or supports that enable the student to participate in the general education program or in other activities with students without disabilities. The present level statement should provide evidence of the need for initiation or continued use of particular supplementary aids and services. Supplementary services may include a note taker, sign language interpreter, personal assistant or proctor for assessments. A factor that should be considered in regard to supplementary aids and services is any training and support the staff and family may need to work with the student. Service logs or data may be used to document that needed aids and services have been provided.
Supplementary aids may include accessible instructional materials and specialized equipment used in regular classes, such as large-print textbooks, digital text, recorded materials or other types of assistive technology. Students who have special communication needs may require alternate communication systems. Identification of special communication needs includes the particular method the student will use for language expression or reception, as well as consideration of the opportunities the student will have for direct communication with peers and instructional personnel. If a student requires the use of an assistive or augmentative communication device, teachers and support personnel should be able to communicate with the student and support the student’s use of the device. Examples of supplementary aids and services include:
Sign language interpreter Braille textbooks
Proctor for assessments Digital instructional materials
Homework assistance Positioning assistance
Specially designed software Homework hotline
Assistive technology assistance Note taker
Case managers just can’t catch a break.
After case managers are done dealing with that bunch of horseshit, they’re ready to move on to even more. They have to list the Classroom Accommodations that will be given to each student, along with their specific frequency, duration, and the location of delivery. We have a ton of them to choose from, but we’d better not pile them too high, because then we have to document using them, and that just adds to the tedium.
Next, it’s on to Extended School Year Services (ESY). ESY is what replaced summer school around the turn of the century because politicians refused to fully fund ESE summer school. In its stead they created the Extended School Year , which is designed to appear to have actual educational value in order to placate parents, but is really just a completely disconnected two weeks of glorified babysitting, compliments of the ignorant taxpayer.
What ESY lacks in substance it more than makes up for with the sheer volume of idiotic paperwork it produces. When it comes to public education, money is always tight, so services that aren’t absolutely required by law are scrutinized thoroughly.
With regards to ESY, teachers have to churn out an incredible number of forms for each and every student recommended.
So, now it’s really nothing more than another big bunch of wasted time: essentially two weeks of free babysitting under the cover of “school.”
Another post altogether is necessary to accurately relate the sheer stupidity that goes into “recommending” a student for ESY in Pasco County. Suffice it to note that doing such a thing produces another, entirely separate heap of senseless documentation and pointless paperwork. Here’s a brief look:
School districts are required by federal law to ensure that every student is being served in the Least Restrictive Environment (LRE) possible. Very loose interpretations of IDEA and its LRE components have led to a senseless-yet-relentless drive for so-called inclusion, resulting in many students being in far less “restrictive” environments than the ones they ought to be in. An ESE case manager is required to add up all the minutes in each school week that an ESE student is at school but not in the general education environment, and then subtract the result from the total number of minutes in the school week. A student’s “placement” is derived from the percentage of the total that an ESE student is in contact with general education students. Passing and lunch, for example, are counted towards participation in general education. The intrepid folks over at district change the total number of minutes in the school week nearly every year, which throws off the LRE ratio for every Access Point student in the entire district, and since it’s the ESE case manager’s job alone to make sure that the LRE portion of the IEP documents an accurate placement, all access case managers are required to amend every IEP in order to reflect the change.
Next, case managers are responsible for informing parents that their child is actually growing up and will be an adult soon under Florida statute, as well as for informing them of their options for retaining guardianship, and the resources available to them through other agencies in the event that they wish to do so. This is called Transfer of Rights at the Age of Majority. Essentially we are responsible for informing parents and students at 16 years of age (verbally), 17 years of age, and then again when they turn 18.
Just exactly why is that our job anyway?
Federal law provides that the so-called “IEP Team” meet and discuss Reevaluation options every three years for every ESE student. It usually coincides with the date of the annual IEP meeting. Here’s another instance wherein the IEP Team– er, ESE case manager– er, teacher, is expected to pore over copious amounts of various data and decide whether or not a student is still placed correctly, or needs to be reevaluated. Of course, there’s another form for that.
But wait! There’s more!
Before case managers can dispense with this nasty beast of a task, they’d better make sure they have all the related paperwork neatly arranged in a predetermined order determined by the same screwups who created this entire fucked up system to begin with.
After this huge trove of nonsense is organized and ready to file, case managers can go file it, along all the bullshit paperwork that goes with it, themselves, since they have so much free time during their workdays. Alternately, they can have the Compliance Resource Teacher review their annual exercise in self-flagellation and nit-pick them to near insanity.
Incidentally, the mere fact that so-called “Compliance Resource Teachers” even exist exposes the fact that Exceptional Student Education has run right off the tracks. To be clear, here’s a teacher who spends all of her or his time reviewing paperwork produced by other teachers because a bunch of self-interested, disconnected “leaders” created a system wherein teachers are the only ones held to account in providing special needs students with an education, and documenting that they have.
It turns out that this this case manager moniker thing was really a brilliant move by the lawyers, judges, and bureaucrats, who somehow cooperated to thoroughly screw ESE teachers in one fell swoop, while simultaneously absolving themselves of any responsibility whatsoever. In many cases, teachers are personally liable for mistakes related to the provision of ESE services and/or documentation.
As any reasonable person can plainly see, saddling every ESE teacher with the additional job of ESE case manager and/or transition teacher is moronic and counterproductive, and, without a doubt, degrades a teacher’s ability to function as a highly effective educator.
Unfortunately, it would be equally moronic to expect any of this to change anytime soon. Politicians are far too interested in getting votes at the expense of everything else, including the state of public education, the careers of public school teachers, and, thereby, the students they claim to care so much about in the first place.