BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 826
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          Date of Hearing:   April 29, 2009

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                AB 826 (Buchanan) - As Introduced:  February 26, 2009
           
          SUBJECT  : Special education: local plan areas: funding

           SUMMARY : Makes changes, commencing in 2009-10, in calculations  
          made by the Superintendent of Public Instruction (SPI) related  
          to the treatment of property taxes and federal funds in  
          determining funding allocations for special education local plan  
          areas (SELPAs).   Specifically,  this bill  :

          1)Removes the total amount of property taxes for a SELPA from  
            the calculation of the base special education funding  
            entitlement for that SELPA.

          2)Removes the total amount of federal funds allocated to a SELPA  
            from the calculation of the base special education funding  
            entitlement for that SELPA.

           EXISTING LAW  :

          1)Establishes SELPAs as the entity responsible for distributing  
            state allocated special education funding to school districts  
            and for coordinating services to students with disabilities.

          2)Provides support for special education through a combination  
            of federal and state funds.

          3)Allocates state, federal and local funding to each SELPA based  
            on a historical rate per average daily attendance (ADA) which  
            was substantially equalized by 2001, the total ADA in the  
            SELPA, growth and cost of living adjustments (COLA),  
            additional adjustments for equalization, and a special  
            disabilities adjustment to offset the fact that pupils with  
            high cost/low incidence disabilities are not uniformly  
            distributed across SELPAs.

          4)Prohibits, under federal law, states from using federal funds  
            to pay for any adjustment for COLA or growth that is required  
            by state law.

           FISCAL EFFECT  : Unknown








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           COMMENTS  : The disabilities that qualify a student for special  
          education vary widely, from a mild speech or learning disability  
          to conditions that require specialized, individual care that  
          goes well beyond classroom instruction. About half of students  
          enrolled in special education have a learning disability, and  
          another quarter have a speech or language impairment. These  
          conditions qualify a student for extra assistance but, in  
          general, have a moderate impact on the cost of education. Much  
          more dramatic are the costs of educating the other quarter of  
          students with more serious disabilities, including mental  
          retardation; visual, orthopedic, or other health impairments;  
          emotional disturbance; loss of hearing and/or sight; traumatic  
          brain injuries; or multiple disabilities.

          Funds for special education services are distributed to  
          districts through SELPAs; in addition, SELPAs coordinate  
          services for students with disabilities from infancy to age 22.  
          The member districts of a SELPA agree on how the required  
          services will be provided and how to allocate funding to each  
          district based on the programs it operates and the students it  
          serves.
          A SELPA may include several school districts or simply coincide  
          with a particular school district or county boundary. In rare  
          cases, a particularly large school district may have more than  
          one SELPA.

          In the Supplemental Report to the 1994-95 Budget Act, the  
          Legislature directed the California Department of Education, the  
          Legislative Analyst's Office and the Department of Finance  
          collaborate to address some of the concerns with the special  
          education funding model; specifically they were instructed to  
          review special education finance laws and propose a new system  
          that would be more fair, flexible, and less complex.  Over the  
          next year and a half the agencies held discussions; this  
          resulted in a series of recommendations submitted in a draft  
          report, issued in spring 1995, and a final report submitted  
          later that year.  Many of the recommendations contained in the  
          reports were incorporated into AB 602 (Davis), Chapter 854,  
          Statutes of 1997, which changed California's special education  
          funding from a resource-based to a census-based approach, which  
          allocates funds according to the total ADA in the school  
          districts within a SELPA, rather than on the number of  
          identified special education students.  The intent behind this  
          change was to provide comparable special education funding to  








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          SELPAs with comparable enrollment; under this ADA-based  
          approach, two SELPAs with the same overall average daily  
          attendance are generally treated the same for funding purposes.

          The state provides a minimum basic special education allocation  
          based on each SELPA's per- ADA funding rate that was  
          historically established.  Over time these per-ADA rates have  
          been substantially equalized.  The funding model also includes  
          provision for making adjustments for growth and COLA, in  
          addition to equalization.  Tying funding for students with  
          disabilities to a SELPA's total ADA was partly based on the  
          assumption that students with disabilities are roughly uniformly  
          distributed across districts and SELPAs.  This assumption  
          generally holds, except in the case of certain high cost/low  
          incidence disabilities; the funding model accounts for this by  
          providing an adjustment for SELPAs based on the number of  
          students with these disabilities.

          Special education is funded with a combination of state, federal  
          and local funds.  The state and federal governments together  
          provided approximately $4.3 billion in the 2007-08 fiscal year  
          for special education.  This funding, which goes first to the  
          SELPA and then is distributed out to districts, does not cover  
          the full cost of educating students with disabilities. Local  
          school districts are expected to provide a share from property  
          tax and other revenues, including the base revenue limit funding  
          that districts receive for students with disabilities in the  
          same way as for all other students.  The primary funding problem  
          facing special education stems from shortfall in funding  
          provided by the federal government relative to the commitment  
          that was historically made.  In the initial authorization of the  
          Individuals with Disabilities Education Act (IDEA) Congress  
          recognized the mandates that were being imposed on states and  
          local educational agencies (LEAs), and stated a goal that the  
          federal government would provide forty percent of the funding  
          necessary to meet these mandates.  Estimates of the federal  
          contribution to special education funding in recent years have  
          ranged from thirteen to twenty-five percent - clearly short of  
          the forty percent commitment.  The burden for making up this  
          shortfall has fallen on the states and LEAs which must comply  
          with the mandates.  This situation has been exacerbated by rapid  
          growth in the number of students with disabilities, particularly  
          those with higher cost disabilities such as autism.

          This federal funding shortfall, and more specifically the  








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          slowdown in federal grant increases for special education  
          through the middle part of this decade, has also led to changes  
          with respect to funding the special education COLA.  From  
          2002-03 through 2004-05, increases in the federal grant were  
          used to fund COLA and growth on the full special education  
          funding entitlement; however, this resulted in a change in  
          federal law that prohibited states from using federal funds to  
          pay for any adjustment for COLA or growth that is required by  
          state law.  Subsequent to that change, budget actions have been  
          taken to provide funding for COLA and growth on the state and  
          local portion of the special education allocations using state  
          funds, and to provide for COLA and growth on the federal portion  
          using increases in the federal grant.  Thus in years when the  
          federal government does not provide sufficient special education  
          funds to cover COLA and growth, those adjustments are not fully  
          provided for federal funds.

          It is hoped that the $1.2 billion infusion of federal funds for  
          IDEA that is being provided to California as part of the  
          American Recovery and Reinvestment Act (ARRA) over the next two  
          years will begin to make good on the federal commitment.   
          However, at this time these funds are not permanent; additional  
          Congressional action would be necessary to make these funds  
          ongoing, and thus relieve some of the funding pressure placed on  
          the state and LEAs.  Committee staff recommends that the  
          Committee and the Legislature continue past efforts to request  
          that Congress provide sufficient ongoing funding for special  
          education.

          A SELPA's total funding allocation, in much simplified terms, is  
          equal to the sum of:

          1)Base state aid that is calculated by multiplying the SELPA's  
            per-ADA rate times total ADA in the SELPA, and then  
            subtracting property tax proceeds to the SELPA and the SELPA's  
            federal allocation.  This calculation is analogous to that  
            made for district revenue limit funding, where non-state funds  
            are used toward the entitlement and state funds then provide  
            the balance.

          2)Any supplement to base funding related to increases in federal  
            aid.

          3)Any COLA adjustment to the per-ADA funding rate, which is then  
            multiplied by total ADA in the SELPA.








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          4)Any funding for growth based on growth in ADA in the SELPA.

          5)Additional funding for the Special Disabilities Adjustment.

          6)State funds provided for other specialized programs within  
            special education.

          7)Property tax proceeds to the SELPA.

          8)Federal funds allocated to the SELPA.

          This bill proposes to make changes in the calculations completed  
          in step 1) of the process above.  According to the author,  
          "Assembly Bill 826 would simplify the current special education  
          funding model (AB 602 of 1997) by removing the federal special  
          education dollars (IDEA Part B) from the AB 602 calculation.   
          This is a technical adjustment and is revenue neutral.   
          California's current special education funding formula has been  
          complicated by including the federal dollars into the  
          calculation.  Since 1980, federal special education funds have  
          been deducted from state special education entitlement funds  
          allocated to Special Education Local Plan Areas (SELPAs).  The  
          result of this practice has added an unnecessary complexity in  
          allocating federal IDEA funds to SELPAs and school agencies."   
          The bill also proposes, in the same way, to eliminate the  
          current treatment of property taxes in step 1) above.

          The author argues that this proposal constitutes a technical  
          adjustment to the model that is revenue neutral and provides for  
          simplification of the AB 602 funding model, since it is designed  
          to pull federal funding and property taxes out of the  
          calculations for determining a SELPA's base funding allocation.   
          However, in a funding system that is as complex as that used for  
          special education, even technical fixes can create consequences  
          that are far reaching in terms of total funding and the  
          distribution of funding across SELPAs.  Because of this, there  
          are a number of questions that should be answered in order for  
          the Committee to completely evaluate the effects of this bill:

          1)Does the removal of local property taxes accruing to SELPAs  
            from the calculation of the base state aid to be provided to a  
            SELPA create a fiscal impact or the potential for cost  
            pressure on the state?  









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          2)Is there a potential for distributional impacts, especially if  
            there are future changes in the distribution of property taxes  
            or federal funds, and would those impacts violate the primary  
            intent of AB 602 - to provide funding equity across SELPAs?

          3)Are there potential out-year implications with respect to  
            equalization in that the remaining entitlements to state aid  
            will be perceived to be widely variable?

          4)If any SELPA receives an increase in property tax proceeds or  
            federal funds relative to other SELPAs, will there be any  
            impact on the state aid entitlement, or will that SELPA simply  
            be better off relative to others?

          5)How does this proposal impact the calculation of growth and  
            COLA adjustments across SELPAs' entitlements, and how would  
            growth and COLA be applied to federal funds?

          6)Are there any unintended consequences that we might foresee  
            from making changes in a system as complex as this?

          7)Since enacting any fiscal or administrative system change in  
            the middle of a fiscal year is always a problem, is there any  
            benefit that accrues to special education students from  
            implementing this change on January 1, 2010; if there is such  
            benefit, does it outweigh the costs, in terms of disruption or  
            errors in the allocation of funding, that are incurred by  
            making a mid-fiscal year change?

          8)This bill proposes to change components that have been part of  
            the calculation of special education entitlements since 1980,  
            when the previous funding model created by the California  
            Master Plan for Special Education was implemented, have there  
            been changes in other policy or in special education funding  
            that have brought this change to some level of urgency?

          9)How is this proposal integrated with other bills passed by  
            this Committee that could lead to changes in the overall  
            funding system, including how funding for special education is  
            determined?

          The process that led to the implementation of the current AB 602  
          model started with budget discussions during the 1993-94  
          Legislative session and before.  These discussions led to the  
          Supplemental Report action in the 1994-95 Budget Act, the work  








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          of the CDE, LAO, and DOF over the next year and a half, the  
          issuance of their final report in December 1995, and the passage  
          of AB 602 in 1997 which phased-in the new model over the next  
          two years and called for additional study by CDE, LAO and DOF.   
          This process was so inclusive and studied that very few changes  
          have been made to the AB 602 funding model in the twelve years  
          since the bill was enacted.  In addition, the discussion and  
          planning that went into AB 602 still left two issues about which  
          the Legislature had questions; in both of these cases, the issue  
          of the incidence of high cost disabilities with respect to the  
          Special Disabilities Adjustment and issues surrounding nonpublic  
          schools or agencies, the Legislature directed that an outside  
          research entity be commissioned to study the issue and make  
          recommendations.  More recently in 2001, the Legislature  
          directed the CDE to commission an outside research entity to  
          study an aspect of the funding model that was providing an  
          incentive to place children with disabilities who resided in  
          group home settings in nonpublic schools to receive their  
          educational services; the research firm analyzed the issue, and  
          provided recommendations that led to statutory changes in that  
          component of the special education funding model.  It is clear  
          that the Legislature has been very deliberative when considering  
          changes to the special education funding model.  The proposal  
          made in this bill calls for changes in this long standing model  
          to be made commencing in the 2009-10 fiscal year, without the  
          benefit of further study.

          Committee staff recommendation: Due to the questions remaining  
          above, Committee staff recommends that the Committee hold this  
          bill as a two-year bill to be heard in January.  Staff also  
          recommends that the Chair and the author jointly request the  
          CDE, LAO, and DOF to again collaborate to address some of the  
          concerns with the special education funding model brought up by  
          the author.  In particular this collaborative group should  
          examine and analyze the specific proposals made in this bill  
          with respect to the questions raised in this analysis and any  
          other potential consequences, and report their findings and any  
          recommendations back to the Chair and the author.  These efforts  
          should provide for more deliberative actions by the Committee  
          and the Legislature in January.

          Previous legislation:  
          AB 1115 (Strom-Martin), Chapter 78, Statutes of  1999, makes a  
          change to the current formula for calculating the special  
          education COLA, so that differences in funding due to different  








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          incidence rates for specific high-cost disabilities are  
          considered in the COLA calculation.  SB1468 (Rosenthal), Chapter  
          846, Statutes of 1998, revises the calculation of special  
          education funding to account for the new definition of ADA that  
          excludes excused absences for ADA calculations.  AB 598 (Davis),  
          Chapter 89, Statutes of 1998, makes numerous technical and  
          conforming amendments to existing provisions of law to implement  
          the revision and equalization of special education funding  
          formulas that was enacted by AB 602.  AB 602 (Davis), Chapter  
          854, Statutes of 1997, implements a new special education  
          funding system and provides a one-time equity adjustment for the  
          1997-98 fiscal year.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Association of California School Administrators
          California State PTA
          California Association of School Business Officials
          California Association of School Psychologists
          Coalition for Adequate Funding for Special Education
          Cutler-Orosi Joint Unified School District
          El Dorado County SELPA
          El Dorado County Charter SELPA
          Exeter Public Schools
          Farmersville Unified School District
          Fillmore Unified School District
          Fremont Unified School District
          Kern County Superintendent of Schools
          Las Virgenes Unified School District
          Moreno Valley Unified School District
          Nevada County SELPA
          North Inland Special Education Region
          Riverside County SELPA
          San Joaquin County Office of Education
          Santa Clara County Office of Education
          Santa Cruz City Schools
          San Ramon Valley Unified School District
          Sierra Sands Unified School District
          South Orange County SELPA
          SELPA Administrators
          Three Rivers Union School District
          Tulare County/District SELPA
          Vallejo City Unified School District








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          Vallejo SELPA
          Visalia Unified School District
          West Contra Costa Unified School District
          West End SELPA
          West San Gabriel Valley SELPA

           Opposition 
           
          None on file
           
          Analysis Prepared by  :    Gerald Shelton / ED. / (916) 319-2087