SCIS TUITION METHODOLOGY MEETING – SED REVEALS POTENTIAL RECOMMENDATIONS
On March 1, 2018, SED held a meeting of the SCIS Tuition Methodology workgroup to discuss a new funding methodology that will be considered for Preschool Inclusion Classes. Suzanne Bolling started the meeting by informing the group that any of the recommendations being presented were just that: recommendations and they did not represent any final decision or determination. Suzanne explained that there are many layers of approvals that need to be given and that SED is simply presenting options for consideration. Any of the options discussed at the meeting will be subject to stakeholder review, must be approved by their principals in SED including the Deputy and Assistant Commissioner, the Commissioner and the Board of Regents. In addition to DOB and possibly the legislature depending on the changes. Suzanne said that SED will offer both short-term and long-term solutions. They include changes to the rate-setting methodology, new SCIS models, budget-based rate methodology based on staffing standards, and the creation of policies and guidelines that will encourage inclusion options for preschool students with disabilities in early childhood settings.
· Improvements to separate funding structures: Tuition growth for existing providers to provide relief and avoid program closures.
· Rate Reform: Using the “higher of two years for the purposes of calculating the total cost screen plus growth – using 2 years would address an anomaly year of lower care days, a decline in enrollment etc.
· Revenue Offset: Address revenue offset to reflect SCIS program operations and separate funding structures. (Determine the cost of what a 4410 program cannot pay for, i.e., typical student education costs.)
· Improvements to existing models: Single entity operating SCIS Program – they would report all expenses
· Collaborating Programs: SED would establish increased reporting requirements for collaborating programs and require contract identify any costs related to program operations. SED will consider potential revenue offset as actual revenue received for typical students – (SED would require that the 4410 programs document all efforts to get funds for the cost of typical students) SED will “pro-rata” reduction of revenue offset based on staffing standards or approved ratios.
· SED proposes to move away from the current OCFS offset daycare rate and evaluate targeted shared instructional staff based on the new staffing standards or the approved ratio based on the new SCIS class ratios. The “pro-rata” would be based on the identification of shared instructional staff costs. SED would assign a per share cost for all of the typical students in the class.
New Inclusion Models
SED provided a description of the three new inclusion models or levels for SCIS Classrooms. Their goal for these three new levels would provide for greater flexibility in the required numbers of typical students.
Secondary Inclusion Program – Daily support with intermittent services to support students with IEP’s. These students would have fewer management needs and receive minimal or no related services. This would be a typical early childhood class with a maximum of 18 students, 1 Certified Teacher in Early Childhood with support from a special education teacher for either .25 FTE or .50 FTE during the day based on the number of students with IEP’s and a certified teacher assistant or aide depending on students. The aide could function as a teacher under daycare. SED proposes that the class could have a 50% – 70% ratio of typical students; 30-50% for students with IEP’s; 6-9 students with IEP’s.
Intermediate Inclusion Program – this model would serve students with moderate needs and include a full time certified early childhood teacher and a full-time special education teacher and a certified teacher assistant and aide. The certified teacher could also be dually certified in early childhood and special education. The class would have a maximum of 16 students and SED proposes between 50-70% would be typical students; 30-50% of the class would be students with IEP’s, between 5-8 students.
Primary Inclusion Program –this model would serve students with the highest levels of need and provide intensive small group instruction and enhanced staffing. This class would have a full time certified special education teacher and a certified teacher assistant and one aide. SED proposes that this class would have a maximum of 14 and that 60-70% of the students would be typically developing; 30-40% would be students with IEP’s, between 6-7 students.
SED also said that they will allow up to two additional students with a variance but will limit the variances for students after October 15th to children already enrolled in the class but who were identified as a student with a disability.
Budget Based Rates in SCIS
SED discussed the development of budget-based rates that would be created by comparing all other regional providers and evaluating all of the expense categories. If a provider deviated significantly from the regional averages they would be subject to review and need to justify “why”.
SED also proposed a set of “inclusion staffing standards” that would be aligned with the approved inclusion program models and used to determine a budget-based rate. SED provided a handout that listed all of the CFR position title codes including some new proposed positions and a determination of time allocation for each title code. Ms. Bolling said that she was working on developing an Excel Worksheet that would be based on the allocations per position title code. The provider would enter data for each category and the Excel Sheet will give the provider the exact number of allocated staff per position title code. This would allow providers to submit funding for staff. Providers would be able to sub-allocate between categories to find efficiencies and offer a more flexible use of funds. Budget based rates would allow the provider to determine the staff they needed based on the staffing allocation parameters. Compliance would be based on the performance of required functions rather than “where did the money go”. If a program failed to meet the performance requirements they would have to justify the spending and may need to reallocate staff.
Budget Based Funding would be based on projections of students and may be subject to changes if the number of students with IEP’s changed from year to year or enrollment changed significantly. It would be based on the maximum class size, ratios of students with IEP’s and the IEP mandates. SED could consider allowing providers to maintain a surplus of tuition revenue but this would be subject to limits and review.
Questions remain about budget-based rates:
1. What cycle would be utilized for budget-based rate making and rebasing?
2. What additional information/data must be captured on the CFR or fiscal reports to support this methodology?
3. What information should be used to determine the salary and fringe data for each position title code? What should the cost proxies be – current 4410 salary data, BEDS data?
4. What cost proxies would be used for clinician salaries?
SED discussed a set of new Inclusion Principles for existing Early Childhood Programs to expand inclusive opportunities for preschool students with disabilities. They would include:
· Updated guidance on placement for preschool students in the least restrictive environment.
· Require early childhood programs to adopt inclusion principles so that SCIS students would have equal access to all classroom benefits.
· SCIS students would be served in state-administered pre-k directly or dually enrolled and “count as both students with IEP’s and Pre-K students. (Need Federal approval)
· School Districts would be allowed to serve SCIS students in district-operated state Pre-k programs without needing to get separate SED approval.
Timeline for the Implementation of the new SCIS methodology:
· Presentation at the Board of Regents Meeting on March 12th
· SED must submit recommendations for new SCIS tuition methodology to Division of Budget on April 1st.
· Many of the proposals will require multiple levels of approval. Some will require regulatory or legislative changes.
We asked Ms. Bolling what immediate relief will be provided to the current SCIS providers who are struggling to survive. She said that tuition growth and addressing the revenue offset will help sustain providers.
There will be a detailed discussion and review of this meeting at the March Education Committee Meeting.