Appendix A
Agency Reponses:
Board of Education and Services for the Blind
State Department of Education
BESB
Agency Response to LPR&IC Findings and Recommendations
1. The program review committee found BESB has the potential to be the supportive state administrative structure and central resource Connecticut needs to provide quality education services for children with vision-related disabilities. To promote leadership for vision education and clarify roles within the system, the committee recommends the statutes be amended to articulate BESB's education services mission as follows: the Board of Education and Services for the Blind, in collaboration with the state department of education, shall support local school districts in meeting the educational needs of children with vision-related disabilities by providing, within available appropriations, advice, assistance, and resources, including the specialized educational services and materials children require because of their blindness or visual impairment.
AGENCY RESPONSE: We are generally supportive of a change in statutory language that clarifies the agency mission in addressing the disability-related needs of children who are blind and visually impaired so that they can meet with educational success. However, BESB's role as the lead agency in delivering support services and goods to children must remain clear. Accordingly, we request the following language to clarify the agency's role as the lead agency in this area: The Board of Education and Services for the Blind, in collaboration with the state department of education, shall support local school districts in meeting the vision-related needs of children who are blind and visually impaired to promote their educational achievement and success. The Board shall be the lead agency in providing, within available appropriations, advice, assistance, and resources, including the specialized educational services, materials, and equipment that children require because of their blindness or visual impairment.
2. The committee also concluded removing the term "board of education" from the agency's title would further clarify its actual role in the education system. When established, BESB was responsible by law for the "care and supervision" of pupils receiving instruction at the residential school for the blind in the state. With the enactment of federal and state special education laws, it no longer has authority over students or educational policies and programs. BESB has evolved to become a service agency for all persons with vision-related disabilities and its title should reflect that role. Since its current name is misleading, the program review committee recommends the Board of Education and Services for the Blind be renamed Connecticut Services for the Blind. The agency's current seven-member advisory board should also be renamed Connecticut Services for the Blind Advisory Board.
AGENCY RESPONSE: We support a change in the name of the agency, and will forward a proposed new name after full consultation with stakeholders, including agency employees.
3. The program review committee found there have been occasions where initiatives to improve vision education services have been undertaken by one of the agencies without participation by the other. For example, the education department recently developed and issued a request for proposals from higher education institutions for recruiting and training new teachers of the visually impaired without involving any BESB staff in the process. Similarly, BESB did not consult the education department when it adopted its "Learning Media Assessment (LMA),"a tool teachers of the visually impaired can use to assess which learning media (e.g., regular print, large print, Braille, or auditory) best meets the needs of a student with vision-related disabilities. BESB also adopted its standardized form teachers of the visually impaired can use to track individual student progress in key compensatory skill areas without SDE input. To facilitate collaboration between the agencies in the future, the program review committee recommends a representative from the special education staff of the state education department, designated by the commissioner of education, be added as an ex officio member to the BESB advisory board. While the BESB board is only an advisory body, its meetings provide a forum for regularly discussing vision education issues and an opportunity for the two agencies to formally share information.
AGENCY RESPONSE: We support the recommendation that would add an ex officio representative of SDE to the agency's Board of Directors.
4. The committee also recommends that the Board of Education and Services for the Blind and State Department of Education work together to develop and issue to local districts, policy and best practices guidelines related to education services for children with vision-related disabilities. Promoting quality education services at the local level requires a strong partnership between the two state agencies. BESB has the expertise to design and assess educational policies and programs for children who are blind or visually impaired and SDE has the authority to oversee local implementation of educational mandates.
AGENCY RESPONSE: We generally support the vision of closer collaboration between the agency and SDE. To clarify BESB's role and responsibility as the lead agency in serving children who are blind or visually impaired, we recommend the following language: The Board of Education and Services for the Blind, in consultation with the State Department of Education, shall develop and issue to local school districts policy and best practices guidelines related to educational services and achievement for children with vision-related disabilities.
5. During the last legislative session, an advisory council on Braille literacy was created to focus attention on issues related to the ability of children who are blind or visually impaired to read and write. The program review committee found the new council, with some modifications of its mandate, can also assist BESB in fulfilling its leadership role for vision education. The advisory council's current duties, while centered on issues of Braille literacy, already encompass broader aspects of educational services for children who are blind or visually impaired, such as caseloads, teacher qualifications, and state funding policies. The review and assessment function the council is intended to perform for Braille services could be expanded to all education services provided to children who are blind or visually impaired. The result would be greater oversight and accountability for the whole system. To accomplish this purpose, the program review committee recommends the Braille literacy advisory council's responsibilities be amended to include evaluating and reporting on: the array of education services available to children with vision-related disabilities; access to services, materials, equipment and technology; and outcomes of the services provided.
AGENCY RESPONSE: We support the recommendation to integrate various issues and otherwise expand upon the tasks before the Braille Literacy Advisory Council. To clarify without delineating the Council's role, we recommend the following language: Amend the Braille Literacy Advisory Council's responsibilities to include evaluating and reporting on the educational services and goods available to children with vision-related disabilities.
6. The committee also recommends the name of the council be changed to the Advisory Council on Education Services.
AGENCY RESPONSE: We support a change in the name of the Council to clarify its role. We suggest that the new name might specifically reference "visual impairments" and/or "blindness."
7. It is recommended the membership of the council be increased to include a parent of a child who is blind or visually impaired and has additional disabilities and a teacher who specializes in providing vision-related education services to multiply disabled students.
AGENCY RESPONSE: For clarification, we suggest the following language: ". . . to include a parent of a child who is blind or visually impaired and has additional disabilities and an education consultant employed by the Board of Education and Services for the Blind who specializes in providing vision-related education services to students with multiple disabilities."
8. The program review committee concluded BESB should continue to offer the services of its vision education professionals to local districts provided the unfairness of the current system is addressed. To make access to BESB teaching staff equitable, the program review committee recommends the agency provide its teachers to districts on a fee-for-service basis starting in the 2002-03 school year.
AGENCY RESPONSE: The agency supports the recommendation to provide educational consultants to school districts on a fee-for-service basis.
9. The committee also found the agency needs to address the lack of access to its teacher services during the summer months, especially for clients of the Birth-to-Three program. At present, all teachers work under contract that is for the period September 1 to June 30. While it is not likely the entire teaching staff is needed all year, some coverage is required for the summer months. Teachers of the visually impaired must be available to conduct timely assessments of all newly referred children and to consult whenever a student's early intervention or special education program needs modification. In addition, the lack of continuous service is a potential federal compliance issue for BESB's Birth-to-Three program. The program review committee recommends BESB pursue contract revisions to ensure the availability of teachers of the visually impaired services all 12 months of the year during its next collective bargaining negotiations. It is further recommended the agency make teacher services available year-round for its Birth-to-Three program, through collective bargaining negotiations or other arrangements, before June 30, 2001.
AGENCY RESPONSE: The agency currently is working with the relevant collective bargaining group to provide educational consultants during the summer months. To promote the goal of year-round availability of teachers while taking into account issues of funding and contract negotiation, the agency requests the following language: The committee recommends that BESB pursue contract revisions or other arrangements to promote the availability of educational consultants for blind and visually impaired services for children (including those served in the Birth-to-Three program) throughout the year.
10. The program review committee recommends the statutes be revised to authorize the agency to provide services from education consultants of the visually impaired on a fee-for-service basis to any school district in state. Legislation should also be enacted to establish a self-sustaining account to receive fees from districts and pay costs related to supplying teacher services. The committee believes making BESB function more like a regional education service center can correct current inequities and increase the availability of teacher services to all districts. In addition, changing the structure for providing agency services can also free up existing General Fund resources for other agency purposes that support quality education services for children who are blind or visually impaired.
AGENCY RESPONSE: We support this recommendation, provided that the changes are cost neutral or promote cost savings for the agency.
11. The program review committee recommends the state funds formerly allocated for BESB teacher costs be used to augment the agency's centralized resources and support services.
AGENCY RESPONSE: If the statutes are amended to establish a fee-for-service approach to service delivery and a self-sustaining account, then the agency would support the use of existing resources, previously made available for educational consultants' salaries, to help fund centralized resources and support services offered to towns under this approach, including additional staffing needs (such as rehabilitation technologists, rehabilitation teachers, mobility instructors, and clerical support). The costs associated with these related services that would be made available to all towns should not rest solely with those towns that choose to hire BESB educational consultants. Accordingly, the agency would have to establish a tiered fee schedule to ensure the equitable apportionment of these costs. For purposes of clarity the agency recommends the following language: State funds formerly allocated for costs associated with agency educational consultants should be used to augment the agency's centralized resources, such as rehabilitation technology and technologists, rehabilitation teaching, mobility instructors, and related clerical support. The agency should establish an equitable, tiered fee schedule for these services to ensure that towns that avail themselves of services from BESB educational consultants do not bear an inequitable share of the cost of providing these support services.
12. The program review committee found the severe shortage of teachers of the visually impaired in Connecticut and nationwide has strained the resources of BESB's teaching staff and limited student access to instructional services throughout the state. The program review committee concluded these various initiatives, if effectively coordinated, can begin to address the state's teacher shortage problem. The previous committee recommendations to add an education department representative to the BESB board and to expand the role of the advisory council should promote interagency communication and cooperation on this and other vision education issues. However, it is also recommended SDE officially include BESB education staff in planning, evaluating, and monitoring the activities undertaken through its federal teacher training grant project.
AGENCY RESPONSE: The agency enthusiastically supports this recommendation.
13. The committee further recommends the department, in consultation with BESB, determine the number of teachers and other personnel, such as orientation and mobility specialists, that are required to meet the education needs of children with vision-related disabilities in Connecticut at present and over the next ten years and report its results to the advisory council by July 1, 2001. A long-range needs assessment should be the basis for the state's strategies for ensuring children who are blind or visually impaired have ready access to education services. The critical first step for effective planning has been overlooked by both state agencies to date.
AGENCY RESPONSE: To clarify BESB's role as the lead agency in this area, and to ensure a complete review and assessment of current and projected needs, the agency recommends the following language: In consultation with the State Department of Education, BESB shall determine the number of teachers and other personnel, such as orientation and mobility specialists and related support staff, who are required to meet the educational needs of children with vision-related disabilities in Connecticut.
14. The state, through BESB, currently reimburses local school districts for certain special education costs related to serving students with vision disabilities. Towns can receive an annual per-pupil grant capped at $6,400 for students who are legally blind or visually impaired and $11,000 for children with vision and other disabilities. Over the past five fiscal years, total state aid provided to towns through BESB averaged about $7.5 million per year. The program review committee found the present funding mechanism is not only cumbersome but ineffective in supporting the specialized services and materials needed by students who are blind or visually impaired. The program review committee found much of the funding BESB provides to towns appears to subsidize basic special education expenses rather than the specialized instruction or materials required by students with vision-related disabilities. Most agency funding - almost 80 percent during the last school year - offsets either: 1) local expenditures for tuition at out-of-district placements, which primarily serve multiply disabled students; or 2) the salaries of district special classroom teachers and aides who work with students who are blind or visually impaired. A substantial amount of agency funding supports special education services for students whose primary disability is not vision-related.
Based on this finding, the program review committee considered proposing BESB grant resources be added to the appropriation made for state special education grants. In effect, state support to local districts for exceptional special education costs would not change in total although individual towns might get more or less state funding than they did under the separate BESB grant. The program review committee believes dedicated funding can be an effective way to promote the quality and accessibility of education services for children with vision-related disabilities. However, to achieve these goals, major changes to the current funding structure are needed. First, the funding process must be simpler to administer. Second, funding policies must more flexible and directed at the unique education needs of students who are blind or visually impaired.
Therefore, the program review committee recommends the current statutory provisions on state payment of special education costs for blind or visually impaired children be repealed and replaced with language establishing a grant program for vision-related education services to be administered by the Board of Education and Services for the Blind. (a) The grant program shall be funded at an amount equal to $6,400 times the number of blind and visually impaired children in the state as determined by BESB. (b) BESB shall use the state funding to provide eligible students who are blind or visually impaired with the specialized instructional materials, including Braille and large print books, and adaptive equipment and technology they require to access their education programs. The state shall also annually provide a $2,000 entitlement to districts for the special education costs of each child who is blind or visually impaired. c) The remaining balance of grant funding shall be used to provide supplemental funding to reimburse local school districts on a proportional basis for the costs of consultation and instructional services provided by teachers of the visually impaired and other services related to providing expanded core curriculum for blind or visually impaired students including but not limited to orientation and mobility training and independent living skills. Only districts that have expended an amount greater than the total amount of entitlement funding received on educational services required for vision-related disabilities shall be eligible to apply for supplemental funding. (d) The Board of Education and Services for the Blind, in consultation with the State Department of Education, shall develop a proposed statutory funding formula for the grant program and a description of all expenses eligible for funding to present to the legislature for its consideration by January 1, 2002. The new grant program for vision education should go into effect by January 1, 2003.
AGENCY RESPONSE: This recommendation and our response constitute the most significant and important components of the committee's report. The agency supports section (a) and part of section (b) of this recommendation. Regarding section (b), the agency stresses the following: If both the General Assembly and the Administration desire to create an "entitlement" grant to towns for every child who is legally blind or visually impaired, BESB would support this approach provided that the final appropriation and/or allocation was above and beyond the funding level required by section (a). Under the number of children currently registered with BESB, this would represent an appropriation/allocation of approximately $2.4 million per year. BESB would be unable to address the children's needs for services and goods if funding under section (a) was diverted to cover this new provision. Regarding the creation of a formula to distribute remaining funds to the towns, BESB supports an approach whereby BESB would develop the formula with consultation from SDE. Our goal would be to use remaining funds to offset the fees paid by the towns under the fee-for-service approach, so that towns would receive credits as is appropriate.
15. How well the current system for serving students with vision-related disabilities achieves education goals is unknown at this time. Neither BESB nor the state education department track educational outcomes for this population. The program review committee found no data are compiled on drop-out rates, post-graduation employment rates, or literacy rates among students with vision-related disabilities. While a number of students who are blind or visually impaired participate in statewide standardized testing (the Connecticut Mastery Tests and the Connecticut Academic Achievement Test), results have not been reviewed and compared with other groups or state goals. The program review committee recommends the State Department of Education, in consultation with the Board of Education and Services for the Blind, establish, monitor, and report on outcome measures for educational services to children who are blind or visually impaired. Monitoring results should be included as part of the department's annual report on special education beginning in 2002.
AGENCY RESPONSE: The agency affirms the needs for effective benchmarks and performance measures on a statewide level. At the same time, the agency stresses that services to blind or visually impaired children were provided in Connecticut long before the creation of Special Education. While there is sometimes overlap between Special Ed and services for the blind, they are, for the most part, two very distinct and separate approaches, particularly because of the exceptional needs of children who are blind or visually impaired. The agency expresses deep concern that services for the blind would become enmeshed with or subsumed by Special Education. The agency further expresses a concern that the agencies' shared role and the agencies' distinct and separate leadership roles must remain clear. The agency recommends the following language: The State Department of Education, in collaboration with the Board of Education and Services for the Blind, shall establish, monitor, and report on outcome measures for the academic achievement of children who are blind or visually impaired. Monitoring results should be included in a distinct annual report produced by SDE on an annual basis.
16. For the first time in many years, BESB is engaged in an agency-wide planning effort. With the assistance of the Department of Administrative Services, it is developing a strategic plan for integrating and enhancing its continuum of services for all clients, including children. The process is in the initial stages and no firm schedule or methodology has been adopted. A comprehensive blueprint for carrying out the agency's education mission is critical to quality services, particularly if BESB is made the lead advocate and central resource for vision education as recommended previously. The program review committee recommends the portion of the agency's strategic plan concerning education services for children who are blind or visually impaired be completed by July 1, 2001, and be updated annually. The strategic plan should incorporate and specifically address the outcome measures developed under the prior recommendation.
AGENCY RESPONSE: The agency supports the goals reflected in this recommendation, with two caveats. First, the agency is striving for greater integration of all of its services. Accordingly, education services for children cannot be simply separated from the rest of the agency in the strategic planning process. Second, the agency's outcome measures for its services to children will not necessarily be limited to those produced with SDE.
17. To facilitate discussion and broad participation during the initial planning process, the program review committee recommends BESB, with the assistance of the State Department of Education, arrange for the National Association of State Directors of Special Education (NASDSE) to conduct one of its training seminars on improving educational services for the sensory impaired in Connecticut.
AGENCY RESPONSE: We support the recommendation for an in-service training seminar on sensory impairments, and will work toward hosting such an event prior to June 30, 2002.
