LADY PATTON and ANGELA TYRONE
KRIS BRAUD
LORIE LORENZ
JANET MORA
NOAH WARTELLE

Introduction
A team of six monitors conducted an on-site visit on October 30-November 2, 2006, as a component of the Continuous Improvement and Focused Monitoring Process (CIFMP). Franklin
Parish School System was selected under the Focused category of monitoring called
Disproportionality in Initial Identification of students with disabilities. Franklin Parish School
System was identified for on-site monitoring from within the local education agencies (LEAs) in the state monitoring system’s Population Group 1, (LEAs with an October 1 general education student count of 0-3,999 students). One LEA from each of the four population groups in
Louisiana was chosen for on-site monitoring during the 2006-07 school year in the focus monitoring category of Disproportionality. The other three LEAs identified for on-site monitoring in this focus indicator area include Terrebonne Parish, Sabine Parish and St. Charles
Parish. The focus of the on-site monitoring team’s investigation was to determine whether the school system’s policies, procedures or practices are contributing to overidentification or disproportionate representation of children with disabilities by race and ethnicity, including particular exceptionality classifications.
The focused monitoring process of the state’s CIFMP involves four steps:
1.
Develop compliance hypotheses based on available data.
2.
Develop investigative methodologies to test the hypotheses.
3.
Conduct investigation.
4.
Draw conclusions regarding compliance with statutory and regulatory requirements.
Demographic and performance information regarding FRANKLIN Parish School System can be found in the State Special Education Data Profile publication and the school performance profiles located on the department’s website at www.louisianaschools.net/lde/specialp.
Monitoring Strategies, Methods and Activities
Review of 83 student records, including random and purposeful reviews of students’ IEPs, evaluation reports, report cards, and class schedules.
Review of the Special Education Policies and Procedures Handbook and forms currently in use.
Review of disciplinary records at school sites and central office.
Review of professional development activities.
Interviews with 42 school-site personnel, including administrators, regular educators, and special educators.
Interviews with 6 central office personnel.
Observations of services being provided to students through on-site visits to schools, including 1 elementary school, 3 middle schools, and 2 high schools.
Gather information from 6 parents who attended a parent focus group meeting.
Interviews by telephone with 4 parents, including follow-up calls to parents who attended the parent focus group meeting.
Parent Focus Group Meeting
A parent focus group meeting was conducted on October 30, 2006, at 5:30 p.m. This meeting was only open to parents and monitoring team members. Two employees from the offices of
Families Helping Families of The Crossroads of Louisiana served as meeting facilitators.
Follow-up telephone interviews were also conducted. Comments and notes taken during the parent meeting were considered in the investigative process.
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Validation of Data on Disciplinary Removals
Validation on site of data being reported to the state and federal government by the Franklin
Parish School System was also a monitoring activity. Purposeful review of 13 discipline records for students with disabilities removed from school for the 2005-06 school year revealed the following information about Franklin Parish School System:
1.
The tracking system is not accurate and consistent at the central office and at the school building levels for students removed from school.
2.
Services were not provided to students after the tenth day of removal from school to enable the students to advance toward IEP goals.
The school system must maintain and assure the accuracy of the special education student data.
The school system must maintain accurate records, including ongoing monitoring of the accuracy of records at each school pertaining to the suspensions and expulsions of individual students with disabilities.
IEP Review: Transition Services for Youth Ages 16 and Older
The Louisiana Department of Education collects data on adolescent transition services for reporting in the 2008 Annual Performance Report (APR) to the federal government and reporting for a 2006-07 Performance Indicator to the Louisiana State Legislature. In Franklin Parish
School System, 50 percent of the records (6 out of 12 records) reviewed of youth ages 16 and above were found to have coordinated, measurable, annual IEP goals and transition services that will reasonably enable students to meet post-secondary goals.
Focus Topic: Disproportionality/Initial Identification Trends
Initial identification trend data for the past three years indicated that Franklin Parish has disproportionate identification of black students in special education. The chart below indicates the overall disproportionate initial identification risk ratio of black students for the past three years. According to the Louisiana State Performance Plan, a risk ratio of greater than 1.5 is considered significant.
YEAR
2003-2004
2004-2005
RISK RATIO
1.70
0.71
2005-2006 2.08
The school system was notified prior to the on-site visit that a disproportionately high percentage of African-American students were being identified with the exceptionality of Specific Learning
Disability when compared with the state average for this exceptionality. Using a risk ratio method for identifying LEAs that might have compliance problems, Franklin Parish was found to have a calculated risk ratio of 2.08 for African-American students being identified as having a
Specific Learning Disability, which is significantly above the risk ratio of 1.5 set by the
Louisiana Department of Education in its definition of disproportionality. Twenty-one cases were reviewed by monitoring team members while on-site in the school system. The team did not find during its investigation that the school system followed different pre-referral practices or different individual evaluation practices based on a student’s race or ethnicity that would lead to
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misidentification of children as disabled or race/ethnicity-based practices that would lead to the overidentification of African-American students as having a Specific Learning Disability.
During its monitoring activities in Franklin Parish School System, specific evidence of systemic non-compliance was found in the following areas:
 §401.B., C., E.3. FAPE (519.E.1 Discipline Procedures. Services are not provided to students with disabilities after the tenth day of disciplinary removal.)
 §490.A. Maintenance of Special Education Student Data
 §401.B. FAPE (444.B.1. There is not sufficient implementation of positive behavior intervention strategies and supports to address inappropriate behaviors.)
Note: The Student-Specific Findings of Non-Compliance pages in this report contain confidential information and should be deleted from the report when copies are made for the general public.
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Reg. Ref. #
§401.B.
FAPE, including
444.B.1.
IEP Content
§490.
Maintenance of Special
Educational
Student Data
Description of
Finding
The school system is failing to provide strategies for positive behavioral intervention and supports, which are required components of FAPE for each student whose behavior impedes his or her learning or that of others.
The school system does not assure the accuracy of the required elements for each student record.
Supporting Evidence Comments
Review of 12 behavior management plans from five schools found that 11 out of 12 plans did not have evidence that the plans had been revised based on the performance of the student. One student had no behavior plan, although warranted. Six of the 12 plans had no baseline data on the inappropriate behavior being displayed by the students. Six of the 12 did not document the following: an action plan included teaching social skills; positive consequences and who, when and how the positive reinforces will be provided. There was no documentation that school personnel involved had been trained to implement the plans.
In 6 out of 12 of the behavior plans reviewed, although the plans were developed, tracking sheets were blank. No systematic data were entered to verify progress in change of behavior.
Discipline tracking records maintained in four out of seven schools did not match the discipline tracking records maintained by the special education central office.
In interviews with four Central Office staff and four principals, it was revealed that the school system does not utilize a process for recording individual infractions independent of the Central Office tracking.
Schools rely on the Central Office personnel to notify them of disciplinary removal data for students. The Special Education Tracking system did not have cumulative data on removal days for students with disabilities.
Days of student disciplinary removal were not calculated nor maintained for the 2005-2006 school year. As a result, students who exceeded ten days or more of removal from school received no IEP services.
Maintenance tracking for discipline infractions for
2006-2007 was reviewed.
This tracking was assigned to a Special Education
Pupil Appraisal Staff member.
Individual folders for schools are maintained as well as student discipline records.
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Reg. Ref. #
§401.B.,C.,
E.3., including
519.E.1
Description of
Finding
Services were not provided to the extent necessary to enable students to progress appropriately in the general curriculum and to advance appropriately toward achieving the goals for students who had been removed from his or her usual placement for more than ten school days in a school year.
Supporting Evidence
Purposeful review of the records of 12 students who had been suspended from school for more than ten days during the 2005-06 school year revealed no documentation that services had been provided after the tenth day of removal. Individual Education Programs (IEPs) did not contain documentation of students receiving services after the tenth day of removal.
In purposeful interviews with the Supervisor of Welfare and Attendance and the Director of Special Education, both stated that the Central Office records were not reconciled with school discipline data. The Welfare and
Attendance Supervisor reviewed the high school records and concluded that they were not accurate or consistent with Central Office records.
In interviews with four school staff, it was stated that schools contact
Central Office to verify accuracy of individual school discipline tracking.
One school did not maintain individual tracking. Two Central Office staff stated that weekly tracking of individual students’ days of removal was not reviewed during the 2005-2006 school year, and that students with more than ten days of exclusion from their usual placements did not receive services.
Comments
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