My “First 100
Days” if I was Appointed the New OSEP Director
Dear Colleagues,
This is
clearly a pivotal time for our country—politically, on all social and economic
fronts, relative to our national and international security and standing, and,
of course, as it relates to education, our students, our schools, and our
many staff.
With the
incoming Trump administration, the selection of Betsy DeVos as the new (once
confirmed) U.S. Secretary of Education, and the new Elementary and Secondary
Education Act (ESEA/ESSA), our educational philosophies, policies,
procedures, and practices are sure to change.
And, I
have been thinking a lot about this over the past month. . . and, actually,
over the past handful of years.
And so,
today, I would like to discuss:
The agenda
that would guide my first 100 days if I was appointed the Director of the U.S. Office of Special
Education Programs (OSEP).
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Why We Need a NEW
OSEP Agenda
Clearly, the
focus here is on the agenda needed
by whoever assumes this position, and not on the person him or
herself.
And, a new agenda is desperately needed . . . to
improve, to integrate, and to strengthen special education services, supports,
and strategies in this country.
This is because
the current agenda is flawed, is rooted in power and politics, and has lost its
“students-first” focus.
In
short: OSEP and special education
services in this country need a shake-up.
Indeed:
* OSEP has
been run largely by same senior staff. . . or senior-influenced staff. . . for
too long.
* Many of
OSEP’s systemic frameworks and processes have never been field-tested or
validated before they have been introduced and advocated in the field. . . OSEP
and some of its grantees are literally “making it up as they go along.”
* Many of OSEP’s
beliefs, ideas, and approaches have become singularly entrenched . . . and this
entrenchment has created a “group-think” whereby OSEP rejects new or innovative
approaches that do not “fit its mold.”
* OSEP’s
professional relationships (and grant awards)—across the country—with universities,
national associations, “non-profit” Research & Development companies, and
other “Thought Leaders” are similarly entrenched. . .
* Which is
why the same universities, professors, and non-profits seem to consistently
receive the largest and most influential competitive and non-competitive
grants. . . the same individuals are on each other’s OSEP-funded Technical
Assistance (TA) Center Boards and Advisory Groups. . . and the same individuals
keep presenting at the same national conferences from year to year.
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All of
this has resulted in special education decisions that have lost their
transparency and objectivity; special education discussions that are controlled
and need to be “politically correct;” and special education training and
practices that have lost their innovative edge.
And
this will not change unless there is a new Agenda and a new
Director who both understands the incestuous system that has been
created and has the permission (and guts) to change it.
In
addition. . .
Did you
know that: The special education
units within each state’s department of education (who receive federal special
education funds that then are passed on to the districts in each state) are
strongly “encouraged” to use (only) OSEP-funded (and “vetted”) TA Centers for
needed technical assistance?
Did you
know that: Virtually all of the
Presidentially-appointed OSEP Directors have been former state special
education directors?
Did you
know that: OSEP awards many of its
largest grants to a small number of “non-profit” Research and Development companies
through the federal government’s “business opportunity” procurement website,
and that these powerful companies are complicit in setting the nation’s special
education agenda?
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All of
this (once again) has created, sustained, and institutionalized an OSEP agenda
that began almost 10 years before the Individuals with Disabilities Act
(IDEA) was reauthorized in 2004.
And to
support its agenda . . . as I have often written in my Blog. . . OSEP has
created a big club . . . that most of us can’t get into.
In fact,
this continually reminds me of George Carlin’s famous commentary (rant) on
education. But the “big businesses” that
are referenced in Carlin’s clip, are—today—selected universities,
university professors, national associations, and the “non-profit” Research
& Development companies noted above.
As
Carlin said:
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What the NEW OSEP
Agenda Should Include
Now that
we’ve (hopefully) established the reasons why a new OSEP agenda is needed, I
would like to detail this “New Agenda.”
It starts with a “Statement of Philosophy and Purpose,” and proceeds
through a series of actions that should occur during the new OSEP Director’s
first 100 days in office.
Here we
go:
Statement
of Philosophy/Purpose
Within the bounds of the recently
reauthorized Elementary and Secondary Education Act (ESEA) and the
current Individuals with Disabilities Education Act (IDEA), and in
support of the (new) Secretary of Education and other U.S. Department of
Education officials, the Office of Special Education Programs should pursue an
agenda that maximizes the academic and social, emotional, and behavioral
progress, accomplishments, and proficiency of all students with
disabilities.
The ultimate goal is the high school
graduation of each student with a general education degree, and the skills
needed to pursue higher education and/or a well-paying job of their choice—such
that they are able to live full and independent lives.
To accomplish this goal, OSEP needs to
change its mission from being an organization that all state SEAs are
responsible to, to being an organization that supports state LEAs to be
successful on behalf of all students with disabilities.
Functionally, this means that OSEP
should/will provide more supports and technical assistance to the states and
their districts and schools, while decreasing unneeded oversight and
supervisory activities—thus, decreasing the burden on state LEAs to document,
defend, and rationalize their special education initiatives and activities.
In doing this, the hope (supported and
encouraged by OSEP) is that states will increase their creativity and
entrepreneurship such that more and different effective interventions for
students with disabilities will be developed, validated, and disseminated.
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Needed
Directions/Actions
1. Given the
recently reauthorized Elementary and Secondary Education Act (ESEA),
there is an immediate need for comprehensive discussions at the U.S. Department
of Education level (after the Presidential inauguration, and once the
transition to a new Secretary has been completed) focusing on how to integrate
ESEA and the current Individuals with Disabilities Education Act (IDEA)
so that they are complementary and help to create part of the multi-tiered
services and support options required by ESEA.
* These discussions need to include cross-national
and state-specific discussions with a wide variety of constituencies and
stakeholders—that go beyond those traditionally used by OSEP for planning
and feedback.
* These discussions need to put aside OSEP’s
current MTSS framework—which is not required by IDEA (see #4 below).
* These discussions need to functionally
differentiate the 13 different disability areas. For too long, special education services have
been evaluated as a single composite (or sub-population) of these different
disability areas—even though different schools, districts, and states have
different percentages of these students across the preschool through high
school levels.
_
_ _ _ _
2. The above discussions, planning, and
activities need to be integrated into a systematic needs assessment, resource
analysis, and strategic planning process that will result (a) in a short-term
path to immediately improving the services and supports to students with
disabilities—as delivered at the school, district, community, and state levels;
and (b) a longer-term plan that, in collaboration with Congress, will be successfully
embedded in a reauthorization of IDEA.
_
_ _ _ _
3. In
preparation and as part of the reauthorization process, a comprehensive review
is needed of OSEP’s State Performance Plan (SPP) and Annual Performance Report
(APR) process—specifically to decrease the data collection burden on the states
(SEAs) and districts (LEAs), and to eliminate data collection requirements that
go beyond the law.
As part of this recalibration process:
* The more effective use of technology needs
to be explored and evaluated—including ways to use the “cloud” for national
data warehousing and analysis, and
* Indicator 17—involving the “State Systemic
Improvement Plan” (SISEP), in particular—needs to be re-evaluated for likely
elimination.
_
_ _ _ _
4. A comprehensive review of all Part D
funding grants (as well as all non-competitive OSEP-funded grants and grant
programs) needs to be conducted to determine whether (a) grants are being (have
been) awarded in areas that are consistent with the new ESEA and the projected
new IDEA; (b) grants are being (have been) selected through an open, honest,
and objective review process, and in ways that are fully consistent with IDEA
and federal law; and (c) the frameworks and workplans built into awarded grants
are (have been) diverse and independent to the degree that they do not reflect
a single-focused monopoly of ideas and research-to-practice approaches.
* For the past fifteen years or more, OSEP
staff have allowed a misinterpretation in the wording in IDEA that has resulted
in the funding of Technical Assistance (TA) Centers that embody OSEP’s own
national research-to-practice agenda.
This has resulted, for example, in the
funding of TA centers focused on (in capital letters) Response-to-Intervention
(RtI), Multi-Tiered Support Services (MTSS), and Positive Interventions and
Supports (PBIS)—even though these terms appear in IDEA as lower case terms
and without acronyms. (Actually, the term “Response-to-Intervention”
does not appear in IDEA at all.)
In ignoring this misinterpretation, OSEP
staff have advanced a single-focused research-to-practice agenda—often to the
exclusion of other evidence- and research-based approaches.
* Beyond this (as noted above), OSEP has
funded TA center grants where many of the same professionals are sitting on
each other’s Advisory Boards, or are actually written into each other’s grant
activities.
This has created (a) at least the appearance
of a conflict of interest; (b) a single-focused (almost monopolistic) research-to-practice
agenda that has dominated the field (restricting divergent thinking and innovative
practices); and (c) an incestuous research and grant competition process that
has narrowed the range of effective practices needed by students with
disabilities.
_
_ _ _ _
5. A comprehensive review of all OSEP staff,
along with the organization of the Office, is needed. Many OSEP staff have served for extensive
periods of time and, as such, there is a need to investigate (and address, as
needed) whether their longevity has created a debilitating “group-think” within
the Office such that creativity, objectivity, and innovation (on behalf of all
students and students with disabilities) has been compromised.
_
_ _ _ _
6. A comprehensive review is needed of our
nation’s special education recruitment, retention, professional development,
and skill levels relative to all teachers, administrators, and related services
personnel. This review should analyze
the different roles and functions that these different educators should have in
serving students with disabilities, how they are being trained and maintained,
and what their efficacy and student-focused outcomes are.
* Beyond the fact that we do not have enough
qualified special education teachers and staff currently in training, my
experience across the country is that the instructional and intervention skill
levels of many special education practitioners need to be upgraded. This is not the fault of these practitioners. Indeed, they only know what they know and
have been trained to do—both at pre-service and post-credentialing levels.
* Thus, this review needs to look at teacher
training, how these teachers are credentialed at the state level, and what they
need to do to maintain those credentials over time. In addition to what currently is working
in these areas, we need to look at how other businesses train and maintain the
quality of their work forces—so that successful non-educational models can be
introduced to the field.
_
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7. Integrated into a number of the needs
assessments and analyses above, a comprehensive review is needed to explore the
health, mental health, and wellness factors and variables that impact the educational
outcomes of all students—but, especially, those with disabilities.
* The services and supports that schools
provide to students with disabilities (as well as at-risk, medically fragile,
emotionally traumatized, academically struggling, and behaviorally challenging
students) often ignore these health, mental health, and wellness perspectives. This is both a training and practice issue—as
well as staff knowledge and skill issue.
* And so, national, state, and community
evaluation and strategic plans need to be developed and implemented so that
existing health, mental health, and wellness professionals are present in our
communities, and available to our schools.
Current school-based and school-linked mental health systems are not
working, and are padding the pockets (especially) of private mental health
corporations when they are running these programs.
We
also need more well-trained child and adolescent practitioners who
understand the school and schooling process, and how to support special
education personnel and their classroom-based interventions. Even though these specialists may be
community-based, we need to find ways to attract, fund, and place these
professionals directly in our schools for students in need.
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8. Finally, in concert with #7 above, a
comprehensive review of the Continuum of Care, Wraparound, and School-to-Work
Transition programs for students with disabilities and/or significant
mental or behavioral health concerns is needed—at the national and individual
state levels. Regardless of the amount of
time and effort being expended in coordinating and implementing these programs,
they are not working for our students and young adults.
To
be successful, this review and the resulting plans and implementation
activities require far more responsible and outcome-based efforts across
numerous federal, state, and local departments, programs, and
organizations. For example (while the
specific titles may vary), effective and accountable coordination is needed by
Health & Human Services, Child and Adolescent Mental Health, Labor, Office
of Vocational Rehabilitation, Office of Disability, and Education-related
departments, agencies, programs, and other advocacy and social service groups.
To
a large degree, many regions and communities’ Continuum of Care and
related Wraparound programs are not working in this country. The Continuum of Care state
programs—often guided by and funded by federal resources—are not well-serving
children and adolescents with serious emotional or behavioral health diagnoses
whose families need help to successfully and safely maintain them in their
homes, schools, and/or communities.
The
Wraparound programs—that use team-based approaches—are not effectively
braiding the many programs and resources referenced immediately above to
support families with complex family and individual child or adolescent needs.
Finally,
the School-to-Work Transition programs—focused on ensuring that students
with disabilities and other special needs have the training, skills, and
readiness to be fully and gainfully employed—are not accomplishing their
goals. These programs need to effectively
provide vocational assessment and rehabilitation, on-the-job and employment
training, and mentoring and follow-through systems and components. Especially given the unemployment rate for
individuals with disabilities, and the number who need financial support in
order to live independently, we need to take a hard look at where we are in
this area, and where we need to be.
Summary.
Using top-down and bottom-up collaborative
approaches, we need to bring health, behavioral mental health, educational, labor,
social service, business, and other advocacy leaders together—reinforcing and
enhancing what is now working in these areas, while creating and building new,
compatible systems that work more successfully.
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The
Characteristics Needed by the Next OSEP Director
Given the
discussion above, I would like to suggest the most-essential characteristics
that the next OSEP Director needs to have:
* Be a
Scientist-Practitioner. The next
OSEP Director needs to understand the research and practice related to the
psychology of learning and cognition, normal and abnormal development, social
and emotional behavior, culture and ecology, curriculum and instruction, and
group and organizational change.
S/he needs to have been a field-based
practitioner—not just in one district or state, but in multiple districts and
states.
Given the history of OSEP, s/he needs to be a
related services professional. All of my
biases aside, a doctoral-level school psychologist would best fit the bill.
_ _ _ _ _
* Have Large
District or State Department of Education Experience. The new OSEP Director should have high-level
organizational experience with education and special education policy, practice,
procedures, and programming. But, once
again, s/he needs to understand how these functionally and practically affect
districts, schools, staff, and classrooms.
Too many upper administrators (as above) have lost
sight of how national policy actually affects classroom practice—and how our
students with disabilities have received fewer and less effective services
because of this loss of sensitivity.
Given the history of OSEP, the next OSEP Director should
not be a recent or current state special education director, but should
have the skills and experience needed to succeed at that level. A new perspective—one that is not beholdened
to current OSEP staff—is critically needed.
OSEP’s staff have been largely running OSEP’s
agenda and initiatives for decades. The
new Director needs to have a broad, independent, and pragmatic perspective; and
be able to change the climate, culture, organization, and staff/staffing
patterns at OSEP.
_ _ _ _ _
* Understand
Effective School and Schooling Practices.
The new OSEP Director should understand the research and practice of
effective school and schooling. . . recognizing that students with disabilities
are not disabled; instead, they have specific areas of academic and social,
emotional, and behavioral functioning that need attention so that they can be
successful in these areas.
Indeed,
students with disabilities are more like all other students than they are
different. And so, rather than coming
from a “disability—up” perspective, the new Director needs to come from an “ability-down”
perspective.
This means
that the new Director must understand all levels of curriculum and
instruction, ability and disability, modification and accommodation, assessment
and intervention, professional development and technical assistance, mentoring
and supervision, administration and shared leadership, and strategic planning
and organizational development.
Mixed in here are not just the educational
practices that make schools work, but the business practices that help schools
succeed.
The next OSEP Director should not come from
the charter school sector, but must understand the charter school and
private school worlds. The Director also
should have experience with alternative and juvenile justice schools and
programs, residential and day-schools specializing in specific student
disability areas, and at the preschool through high school (and beyond) levels.
_ _ _ _ _
* Understand
Strategic Planning, Scaling-Up, and the Process of Change. The new OSEP Director needs to understand,
have experience with, and be able to apply his or her skills to the process of
large-scale change. Thus, s/he needs to
understand that there is an already-existing research base in strategic
planning and organizational development, and the challenge is how to apply it
to education. . . at different levels of complexity.
OSEP has spent the last decade advocating a process
of scale-up and change that is untested, overly complex, and has resulted in
significant numbers of “re-starts” and “re-do’s” at the state and district
levels. It simply does not work. But, OSEP continues to throw “good money
after bad results.”
The new OSEP Director needs to conduct the audits
and evaluations recommended earlier in this message, create and implement the
strategic plans needed, “pull the plug” from grants and frameworks that do not
work, and make (special) education work in this country.
This will take guts, determination, fortitude, and
the support of many colleagues. But it
must be done. We have spent far too much
time, money, talent, and resources on approaches that do not work. . . and that
many practitioners and local/state level professionals are afraid to publicly admit
(especially to OSEP) do not work.
It is time to change. . . to an OSEP Director who knows
how to facilitate systemic change. . . and can accomplish this monumental job.
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Summary and a Call
to Action
I really
don’t want to be the next Director of the U.S. Office of Special Education
Programs.
But if it
meant getting the issues and agenda described above on Secretary DeVos’ radar,
I would certainly interview for the position.
Here’s
What We Need to Do: If you agree
with most or all of what I have outlined above, and you are willing to take
action:
* Copy, Paste, and Send the Following Tweet to President-Elect
Donald Trump, Vice President-Elect Mike Pence, U.S. Department of Education
Nominee Betsy DeVos, and Gerard Robinson—who is helping to guide the President-Elect’s
Education transition team:
How new US Special Ed Director MUST change OSEP http://bit.ly/2hgcQI4
@realDonaldTrump @MikePenceVP @BetsyDeVos @gerard_924 @DrHowieKnoff
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_
In
addition:
* Forward
this Blog Message (by link, post, or e-mail) to your colleagues and friends—especially
those who have children, adolescents, or adults with disabilities or who are
struggling academically or behaviorally in school.
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As always, I look forward to your thoughts
and comments. Feel free to contact me at
any time if there is anything that I can do to support your work.
Meanwhile, please accept my best wishes for
a wonderful and joyous holiday season. . . regardless of your cultural,
religious, or non-denominational background and beliefs. Take some time to enjoy this season, and to
commune with family and friends.
Best,
Howie
