As described in prior Monitor reports throughout the 2018-19 school year, the purpose of student specific corrective action (SSCA) is to identify and provide a remedy for students with disabilities who were impacted during the 2016-17 and/or 2017-18 school years by special education procedural changes and “locks and blocks" in CPS' electronic IEP system in one or more of the five areas identified by the ISBE Public Inquiry:
- Paraprofessional support (aide)
- Transportation services (bus)
- Extended school year (ESY) (IEP summer services)
- Placement in a therapeutic day school (placement in special education school)
- Identification of a student with a specific learning disability (LD)
Identification of Students Potentially Impacted
With ISBE review and approval, CPS utilized SSM data to identify a class of students who were potentially impacted in one or more of the five areas listed above. Approximately 9,500 students were identified as potentially impacted. CPS was overly inclusive in their data pulls and analysis to ensure that potentially impacted students are not overlooked.
In September, and as required by P.A. 101-0515 described above, CPS notified parents/guardians of the proposed SSCA process. Three different types of notices were disseminated:
- A letter to specific parents/guardians of students identified by the ODLSS data run (~9,500) as being potentially impacted and thus requiring an SSCA meeting,
- An additional letter to all other parents of active/current students with disabilities with information regarding the SSCA process, and
- A notice to
all CPS parents/guardians regarding the SSCA process, via website notification and “backpack notice."
All forms of notification state that a parent/guardian may request that their child be considered for student specific corrective action if the parent/guardian believes their child was impacted by a denial and/or delay of one or more of the 5 areas of services during the 2016-17 and/or the 2017-18 school year(s).
ODLSS provided a list of the approximately 9,500 students that were identified as potentially impacted and required an SSCA meeting to each school in September 2019. In response, many schools contacted ODLSS with corrections to the list. This was especially the case for schools with programs for students who require a significantly modified curriculum (“low incidence" or “cluster" classrooms). The schools pointed out that specific students received programmatic paraprofessional support from special education classroom aides (SECAs) who are automatically assigned to all cluster classrooms. The SSM data pull was unable to distinguish these students from those who had paraprofessional support removed from their IEP's during the 2016-17 and/or 17-18 school years. As such, schools (mostly those with cluster classrooms) provided a collective list of approximately 1,000 students for whom appropriate services in one or more of the 5 identified areas were claimed to be provided during the relevant school year(s).
Currently, an ODLSS attorney, an ODLSS District Representative, and the ISBE Monitor are reviewing each student on the lists submitted to ODLSS by schools to determine whether an SSCA meeting is mandated. Of course, even if it is determined that a student does not
require an SSCA meeting, a parent/guardian may request an SSCA meeting if they believe one is necessary.
ISBE and CPS anticipated that the SSCA process would be “live" on October 1, 2019. However, details of the SSCA process were still being discussed and finalized during September, and ISBE engaged in further consultation with OSEP regarding appropriate remedies. Given that Public Act 101-0515 was passed on August 23, and the SSCA procedures had not yet been finalized and released at that time, CPS is required by the new law to publish the SSCA guidelines for a 45-day public comment period before SSCA meetings could proceed. The public comment period will end on November 23, and ISBE expects that SSCA meetings will commence shortly thereafter.
Per explicit guidance from the United States Department of Education's Office of Special Education Programs (DOE OSEP), IEP teams will be responsible for conducting the SSCA meetings, and parents/guardians may request an SSCA meeting at any time. An SSCA meeting may be held in conjunction with a student's annual IEP meeting, or it may be held as a free-standing meeting on another date. Mandatory IEP team members include the parent/guardian, local school district representative, special education teacher, general education teacher, and any other member determined to have essential knowledge regarding the student to make a fully informed decision regarding SSCA. An SSCA meeting
proceed without parent/guardian participation, which may occur via phone.
A Notice of Conference (NOC) for any IEP meeting that also includes an SSCA meeting must explicitly state the purpose of the meeting including the consideration of SSCA. A companion document to the NOC is the SSCA Document/Data Collection Checklist, which indicates the documents and/or data that will be considered and discussed at the SSCA meeting. Parents/guardians are also encouraged and allowed to bring whatever data and documentation they believe is relevant to the discussion.
At the SSCA meeting, the IEP team will determine if a denial/delay occurred in one or more of the 5 relevant areas during the relevant schools years (2016-17; 2017-18) and whether the student made expected progress in light of his/her unique circumstances. If a delay or denial occurred
and the student did not make expected progress, s/he will be eligible for remedies as determined by the IEP team.
In consultation with the DOE OSEP, a menu of potential SSCA remedies will be included on the SSCA NOC Checklist. The remedies are detailed in the draft
SSCA guidance document found on the ODLSS website under the
CPS Policies and Procedures page.
A simplified list of the
potential SSCA remedies as of October 23, 2019 follows:
Tutoring services – after school or via Summer Academy
Extended School Year (ESY) – if the student does not already qualify for ESY, or additional weeks if the student is already eligible for ESY.
Access to a Chromebook with a read/write/math extension program
Reimbursement – if the parent/guardian transported his/her child to/from school via car or the CTA
Related services – if the student missed 10 or more consecutive school days due to a delay/denial of transportation and did not receive related services during that time.
Placement in a therapeutic day school
The IEP team, including the parent/guardian, will determine which remedy or combination of remedies is appropriate to adequately address the impact of a delay/denial of services based on the child's unique circumstances.
If a parent/guardian or staff member does not believe that any of the potential remedies or combination thereof will be adequate, they must inform the school's case manager so that an ODLSS District Representative may attend the SSCA meeting to discuss other remedy options. An ODLSS D.R. is an LEA (Local Educational Agency) representative who is knowledgeable about the availability of the District's resources, as required by the IDEA, at an IEP meeting. A request for an ODLSS D.R.'s attendance may occur prior to the SSCA meeting or during an SSCA meeting, whereupon the meeting will be reconvened with a D.R. in attendance. The
ODLSS draft Procedural Manual indicates that this meeting must be reconvened within 15 school days. (See p. 88)
Principals, Assistant Principals, Network Chiefs, and ODLSS District Representatives
CPS/ODLSS provided mandatory training on the SSCA process during the 2019 CPS Law Conference (July 17-18, 23-26). The ISBE Monitor attended these sessions to provide clarification and/or additional directives when necessary.
ODLSS provided mandatory SSCA training sessions to CPS case managers during the 2019 Case Manager Kick-Off (August 26, 27, 28, and 30). The Monitor also attended these sessions to provide additional guidance. A make-up session was held on September 17.
Related Service Providers and ODLSS Central Office Staff
ODLSS provided a detailed overview of the SSCA process to ODLSS clinicians and central office staff prior to the first week of the 2019-20 school year.
ODLSS and ISBE offered SSCA training sessions to parents/guardians at schools in six geographical areas across Chicago at the September Parent University workshops. Daytime workshops were held on September 11, 13, 24, 26, and 27, 2019, and an evening session occurred on September 19, 2019. School locations included Richards High School, Cleveland Elementary School, Washington High School, Juarez High School, Bouchet Elementary School, and Bogan High School. Additional sessions will be scheduled throughout the school year, as well as conducted upon request via schools and/or parents.
Training materials for the Parent University SSCA workshops can be found on the ISBE Monitor website under “Trainings & Webinars."
ODLSS will record an SSCA training webinar that will be accessible to all CPS staff throughout the school year in order to assist them with the SSCA process, given that students' annual review meetings occur during every month of the school year.
SSCA Compliance Monitoring
During the 2019-20 school year, ISBE will review student specific corrective action IEP documents from each CPS Network to review IEP teams' SSCA determinations and analysis. The Monitor will focus on schools that have high numbers of students who were identified by ODLSS as potentially impacted via SSM data pulled during the summer, as described above under “Identification of Students Potentially Impacted."
The Monitor will also coordinate IEP reviews with the centralized ODLSS SSCA team, which is projected to consist of an ODLSS DR, an ODLSS attorney, an administrative assistant, and the ODLSS Parent Involvement Specialists. This team will be reviewing SSCA meeting compliance and decisions, as well as providing technical assistance to IEP teams and support to parents/guardians during the SSCA process. The Monitor will also focus on schools, if any, that parents, advocates, and/or CPS staff identify as problematic in their SSCA decision-making process or IEP team processes in general.
The Monitor retains the authority to overturn IEP team decisions granting or denying remedial opportunities, or she may direct the IEP team to conduct further analysis. The Monitor will also follow CPS' tracking of SSCA meetings and team decisions. It is anticipated that this tracking process will be accomplished by reviewing SSM reports that indicate which SSCA meetings have occurred at each school and across the District.
SSCA Questions, Reports, Issues
All stakeholders are encouraged to contact the ISBE Monitor and/or ODLSS regarding any questions, concerns, and issues with SSCA via