BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 661
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          Date of Hearing:   April 29, 2009

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                Kevin De Leon, Chair

               AB 661 (Torlakson) - As Introduced:  February 25, 2009 

          Policy Committee:                               
          EducationVote:10-0

          Urgency:     Yes                  State Mandated Local Program:  
          No     Reimbursable:              No

           SUMMARY  

          This bill implements the Behavioral Intervention Plan (BIP)  
          mandate claim settlement by allocating one-time and on-going  
          GF/98 funding via the special education funding model to Special  
          Education Local Plan Areas (SELPAs).  Specifically, this bill:  

          1)Allocates $65 million as an augmentation to the 2009 Budget  
            Act, with the intention that this be an annual appropriation  
            and $85 million one-time, beginning in the 2010-11 fiscal year  
            (FY) until the 2016-17 FY, for a total of $510 million GF/98  
            to pay school districts' prior year BIP mandate claims, dating  
            back to 1993-94.  

          2)Requires the Superintendent of Public Instruction (SPI) to  
            conduct a series of calculations that result in a permanent  
            increase, beginning in the 2009-10 FY, to the annual average  
            daily attendance (ADA) calculated for SELPAs, including those  
            special education programs served by the Los Angeles Juvenile  
            Court and Community School/Division of Alternative Education  
            SELPA.  This increase is the result of the $65 million GF/98  
            (on-going) appropriated annually to SELPAs for the BIP mandate  
            settlement.  

          3)Requires the SPI to increase the statewide target per ADA for  
            special education funding for the 2009-10 FY by the amount of  
            funding determined above.  

          4)Appropriates $85 million from the GF/98 on a one-time basis in  
            each of the 2011-12 to 2016-17 FYs to the SPI for allocation  
            to school districts on a per-pupil basis, as specified.  This  
            measure further requires the amount allocated to each district  








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            be the same in all subsequent FYs as it is in the first FY.  

           FISCAL EFFECT  

          1)Appropriates $65 million GF/98 annually to school districts  
            for the annual cost of the BIP mandate.   

          2)Appropriates $85 million one-time GF/98 for six FYs (beginning  
            in 2011-12), for a total of $510 million GF/98, to pay school  
            districts' prior year BIP mandate claims, dating back to  
            1993-94.  

          3)Appropriates $10 million from the GF/98 to the SPI for  
            allocation on a one-time basis to county offices of education  
            (COEs) and SELPAs and requires the funds to be in addition to  
            the level of any COLA provided to COEs and SELPAs in the  
            annual budget act.  This bill further requires that the  
            minimum allocation to COEs be at least $5,000.    

          4)GF/98 cost pressure, likely in the tens of millions, for  
            increased COLA costs due to the $65 million annual  
            appropriation built into the base of the special education  
            funding model.  

           SUMMARY CONTINUED  : 

          1)Authorizes the state to allocate an amount in excess of $85  
            million GF/98 in any of the relevant FYs for the purpose of  
            discharging the obligation in advance of the period designated  
            by this measure, as long as the total amount appropriated is  
            $510 million GF/98.  This amount is required to be in addition  
            to any cost-of-living (COLA) adjustment provided to school  
            districts in the annual budget act and is designated to pay  
            off prior year BIP mandate claims.    

          2)Prohibits the $85 million GF/98 one-time payment from  
            occurring if Proposition 98 is determined to be in a "Test 3  
            year" (i.e., slow per capita personal income growth).  This  
            measure further specifies that if the appropriation is not  
            made due to a Test 3 year, it is to be made in the immediate  
            following FY, as specified.  

           COMMENTS  

           1)Background  .  The federal Individuals with Disabilities  








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            Education Act (IDEA) delineates rights and services for  
            persons with disabilities.  Specially, IDEA requires pupils to  
            have a right to a free and appropriate public education  
            (FAPE).  As a result, school districts are responsible for  
            providing special education and related services pursuant to  
            an Individualized Education Program (IEP), which is developed  
            by a team with special education expertise and knowledge of a  
            child's particular needs.  

            As part of the IEP process, AB 2586 (Hughes), Chapter 959,  
            Statutes of 1990, attempted to regulate the use of behavioral  
            interventions and encourage the application of positive  
            behavioral strategies with special education students. Chapter  
            959 required the State Board of Education (SBE) to adopt  
            regulations that accomplished the following: (a) specified the  
            types of behavioral interventions districts could and could  
            not use; (b) required IEPs to include, if appropriate, a  
            description of positive interventions; and (c) established  
            guidelines for emergency interventions.  

            Many consider the regulations that were adopted by the SBE to  
            exceed the intent of Chapter 959.  For example, the  
            regulations require school districts to conduct one particular  
            type of behavioral assessment (i.e., a "functional"  
            assessment) followed by a particular type of BIP (i.e., a  
            systematic positive BIP) for any special education student  
            exhibiting serious behavior problems that interfered with the  
            implementation of his or her IEP. In addition, the regulations  
            require districts to train staff in these strategies.  

            In 1994, three local education agencies (LEAs) (San Diego  
            Unified School District, Butte County Office of Education, and  
            San Joaquin County Office of Education) filed a mandate test  
            claim charging that the BIP related requirements constituted a  
            reimbursable state mandate.  The Commission on State Mandates  
            (CSM) ruled that Chapter 959 "on its face, does not impose any  
            reimbursable state mandated activities."  However, the  
            regulations adopted by SBE, under the authority of Chapter  
            959, constitute a state reimbursable mandate.  

            In 2000, the CSM heard the test claim and ruled in favor of  
            the three LEAs.  The Department of Finance (DOF) appealed this  
            decision.  Rather than continue to pursue the appeal, DOF  
            reached a settlement with the three LEAs in December 2008.   
            This bill, sponsored by the California School Board  








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            Association, implements this settlement agreement.  

            This committee notes that the Legislature is not a party to  
            this settlement agreement and is not under any obligation to  
            agree to its terms.  However, under the agreement, funding is  
            required to be appropriated and this authority lies solely  
            with the legislative branch.    

           2)The terms of BIP mandate settlement  state that school  
            districts receive $65 million GF/98 annually to defray the  
            ongoing cost of BIPs, in addition to a lump sum payment of  
            roughly $510 million GF/98 to settle the outstanding claims.  
            The $65 million GF/98 on-going payment is built into the base  
            of the special education funding model.  These amounts are  
            based on results from school district and SELPA surveys  
            conducted by DOF.  

            The settlement agreement also requires that by February 28,  
            2009, 85% of all LEAs sign a document that waives their rights  
            to contest the settlement and to file any BIP mandated cost  
            claims.  As of April 2009, 96% of LEAs have submitted this  
            document within the time frame, which represents 5.7 million  
            ADA or 99.5% of the special education funding model ADA for  
            the 2007-08 FY.  

           3)The Legislative Analyst Office (LAO) Alternative  .  Since the  
            enactment of Chapter 959, federal law has included the use of  
            behavioral interventions as part of the IEP process.   
            Specifically, federal law now requires IEP teams to  consider   
            behavioral interventions, including positive behavioral  
            interventions, when a student's behavior impedes his or her  
            learning or that of others. Additionally, if an IEP team  
            determines that a behavioral intervention is needed to ensure  
            a child receives a FAPE, the IEP team  must  include an  
            intervention in that child's IEP. Federal law does not  
            prescribe the type of behavioral intervention that IEP teams  
            may include.   

            As a result of this change in federal law, the LAO argues that  
            "the state could eliminate future BIP related costs by more  
            closely aligning state regulations with federal law. Under  
            this approach, IEP teams would have to  consider  positive  
            intervention strategies and would be obligated to include them  
            in an IEP when teams deem them necessary for a child to meet  
            his or her IEP goals. The state also could continue to limit  








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            the types of interventions that districts may use in an IEP  
            and in case of emergencies. It would not, however, require a  
            specific course of action be taken in all instances. Districts  
            therefore would have more discretion in addressing individual  
            behavior problems. They also would achieve savings by the  
            repeal of current assessment, training, and procedural  
            requirements. Any remaining costs could be covered by existing  
            federal and state special education funding. This approach  
            would save the state the $65 million in estimated annual  
            ongoing costs."


           4)The Governor's 2009-10 budget proposed to suspend all but  
            three K-14 mandates through 2010-11  .  In December 2008, a San  
            Diego Superior Court judge ruled that the Legislature's  
            practice of budgeting $1,000 in the annual budget act for  
            certain mandates in order to defer payment on the total claim  
            is unconstitutional. The ruling was in response to a lawsuit  
            filed in 2007 by five school districts and the California  
            School Boards Association against DOF and the State Controller  
            seeking payment of past mandate claims and to end the act of  
            deferring K-12 education mandates. 


            While constitutional separation of powers left the court with  
            the inability to force the Legislature to make budgetary  
            appropriations for K-12 mandates, its decision increases  
            pressure on the state to pay the annual ongoing cost of these  
            mandates. 

            
            The suspension of mandates relieves the state from the  
            obligation to pay for required activities.  Likewise, local  
            schools do not have to perform these activities. According to  
            the LAO, the governor's proposed suspensions would reduce  
            associated 2009-10 claims by roughly $200 million. 

            In enacting the 2009 Budget Act in February 2009, the  
            Legislature did not take action on this issue and instead  
            indicated that it would hear this item within the regular 2008  
            legislative process.  

            The Assembly Budget Subcommittee on Education voted on April  
            21, 2009 to reject this proposal.  









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           Analysis Prepared by  :    Kimberly Rodriguez / APPR. / (916)  
          319-2081