BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 976
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          Date of Hearing:   January 13, 2010

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                   AB 976 (Arambula) - As Amended:  January 4, 2010
           
          SUBJECT  :   Public schools: alternative education: accountability

           SUMMARY  :  Prohibits a school district or county office of  
          education (COE) from offering independent study (IS) to a pupil  
          if the school district or COE determines that the pupil is  
          performing below state standards, as specified.  Specifically,  
           this bill  :   

          1)Prohibits a school district or COE from offering IS to a pupil  
            if the school district or COE determines that the pupil is  
            performing below state standards and provides for an exception  
            for a pupil who is:

             a)   Employed;
             b)   Pregnant or is a parent and is caring for a child or  
               children;
             c)   Obliged to be off campus for his or her safety; or
             d)   Obliged to be off campus due to a medical or  
               psychological condition.

          2)Requires a school district, prior to referring a pupil to IS  
            pursuant to an alternative education program, to provide the  
            pupil and his or her parent or guardian with a listing of all  
            other alternative education options and a description of the  
            requirements that the pupil must fulfill to return to the  
            school of origin.

          3)Provides that if independent study is the only appropriate  
            alternative for a pupil, that a statement declining all other  
            options shall be signed by the pupil, his or her parent or  
            guardian and a school official. 

          4)Prohibits IS from being the primary referral alternative when  
            a pupil is referred to an alternative education program. 

          5)Authorizes the California Department of Education (CDE) to  
            prohibit a school district or county office of education from  
            continuing to enroll a pupil in IS if the pupil performs below  
            average state standards and does not make significant  








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            progress. 

           EXISTING LAW:   

          1)Authorizes a school district or county office of education to  
            offer IS to meet the educational needs of pupils, and provides  
            that educational opportunities offered through IS may include,  
            but shall not be limited to, the following: 

             a)   Special assignments extending the content of regular  
               courses of instruction;

             b)   Individualized study in a particular area of interest or  
               in a subject not currently available in the regular school  
               curriculum;

             c)   Individualized alternative education designed to teach  
               the knowledge and skills of the core curriculum, and  
               provides that IS shall not be provided as an alternative  
               curriculum;

             d)   Continuing and special study during travel; and

             e)   Volunteer community service activities that support and  
               strengthen pupil achievement.

          2)Requires, as a condition of receiving apportionments for IS,  
            school districts to adopt and implement written policies  
            pursuant to rules and regulations adopted by the  
            Superintendent of Public Instruction (SPI), that include, but  
            are not limited to all of the following:

             a)   The maximum length of time, by grade level and type of  
               program, that may elapse between the time an IS assignment  
               is made and the date of completion by a pupil;

             b)   The number of missed assignments to be allowed before an  
               evaluation is conducted to determine whether it is in the  
               best interests of the pupil to remain in IS, or whether he  
               or she should return to the regular school program; and

             c)   A requirement that a current written agreement for each  
               IS pupil is maintained on file that includes, but is not  
               limited to, a statement in each agreement that IS is an  
               optional educational alternative in which no pupil may be  








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               required to participate, and other specified components. 

          3)Requires each written agreement to be signed, prior to the  
            commencement of IS, by the pupil, the pupil's parent, legal  
            guardian, or caregiver, if the pupil is less than 18 years of  
            age, the certificated employee who has been designated as  
            having responsibility for the general supervision of IS, and  
            all persons who have direct responsibility for providing  
            assistance to the pupil. 

          4)Requires the IS by each pupil or student be coordinated,  
            evaluated, and under the general supervision of an employee of  
            the school district or county office of education who  
            possesses a valid certification document, as specified.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :  Independent study is an alternative instructional  
          strategy, not an alternative curriculum that offers a level of  
          flexibility to meet individual student needs, interests, and  
          styles of learning.  Independent study is available as a  
          voluntary option, and current law requires that prior to the  
          commencement of IS, a written agreement be signed by the pupil,  
          his or her parent, guardian, or caregiver, the supervising  
          teacher and any other individual having direct responsibility  
          for providing assistance to the pupil.  The agreement outlines  
          the instructional plan for the pupil and the supervision that is  
          to be provided for that pupil to complete the work outlined in  
          the agreement. 

          This bill prohibits a school district or COE from offering IS to  
          a pupil if the school district or COE determines that the pupil  
          is performing below state standards and provides for exceptions  
          for specified circumstances.  It is unclear as to how this  
          provision would be implemented.  The term "below average state  
          standards" is not a term that is used in describing a pupil's  
          performance. There are content standards that have been adopted  
          for each grade level nevertheless those standards are not used  
          for measuring performance but rather used for purposes of  
          instruction.  This bill does not provide for a definition of  
          "below average state standards" and thus could result in  
          confusion and inconsistent application throughout the state, as  
          it is not clear how a district would determine which pupils  
          would fall under this category.  









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          This provision is also inconsistent with current law prohibiting  
          the use of previous classroom performance as a criterion in  
          placing a pupil in an alternative school.  To the extent that an  
          alternative school uses IS as an instructional strategy, this  
          bill would be inconsistent with the intent of offering  
          alternative education programs to pupils who are not doing well  
          in the regular school setting and may be limiting the  
          opportunities for these pupils to stay in school.  

          This bill is based on the assumption that independent study is a  
          mandatory program and that pupils have no opportunity to exit or  
          go back to the classroom once they are in IS.  The bill fails to  
          consider that independent study is an instructional strategy  
          offered as a voluntary option and that the pupil and his or her  
          parent have to agree to IS before a pupil is enrolled.  The  
          CDE's Independent Study Manual points out that, "Participation  
          in IS must be voluntary: a choice made by the student, parent,  
          guardian, or caregiver, and the teachers-not an administrative  
          decision of last resort."  As currently drafted, this bill could  
          potentially allow the governing board of a school district to  
          overturn the decision of a parent who has agreed to his or her  
          pupil's participation in IS.  

          The bill provides specific exceptions to the above prohibition  
          for pupils who work, are pregnant or have to be off campus for  
          their safety, or for medical or psychological reasons.  While  
          this list recognizes that there are circumstances and situations  
          for which pupils, regardless of academic achievement, could  
          benefit from IS, it fails to recognize that those circumstances  
          and situations vary widely.  Depending on the pupil's situation,  
          IS could assist that pupil in making up credits or providing an  
          alternative if he or she has to be out of the classroom for  
          reasons that vary so widely that they would be impossible to  
          list.  For many at-risk students, IS may be an opportunity to  
          change direction and continue their education, nevertheless,  
          this bill establishes a "one-size-fits-all" approach that may  
          severely limit a local school district's flexibility to offer  
          its pupils a full range of educational opportunities to meet the  
          unique needs of its pupils.

          This bill further requires a school district to provide pupils  
          and their parents a listing of all alternative education options  
          available when referring pupils to an alternative education  
          program along with a description of the requirements the pupil  
          must fulfill to return to his or her school of origin; and  








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          requires the pupil, his or her parent and a school official to  
          sign a statement declining all other options if IS is "the only  
          appropriate alternative for the pupil."  There is already a  
          requirement in law for parents or guardians, pupils, the  
          supervising teacher and others to sign a written agreement prior  
          to commencement of IS, thus creating additional notification  
          requirements may be duplicative.  Furthermore, current law  
          requires the inclusion of a statement in the written agreement  
          specifying that "independent study is an optional educational  
          alternative in which no pupil may be required to participate."   
          Requiring districts to provide additional notification and  
          additional documentation could create a state-reimbursable state  
          mandate.  Considering the fiscal problems facing the state, it  
          is unclear that duplicating work for school districts would be  
          an appropriate use of the limited resources currently available  
          to them.  

          Current law also provides that IS agreements cannot be longer  
          than one semester in duration and it requires the agreement to  
          include the beginning and ending dates of the IS.  This means  
          that at the conclusion of the duration specified in the  
          agreement, either a new agreement will have to be signed by all  
          parties for continued enrollment or the placement terminates.   
          Hence, it is unclear whether it is necessary to add more  
          notification regarding requirements the pupil must fulfill to  
          return to his or her school of origin.  Additionally, it shall  
          be noted that the IS agreement does not prohibit a pupil from  
          going back to his or her school at any time.   

          A provision in current law specifies that for pupils referred to  
          alternative education programs, the IS agreement must include a  
          statement specifying that instruction may be provided to the  
          pupil through IS only if the pupil is offered the alternative of  
          classroom instruction.  Furthermore, current law prohibits  
          pupils enrolled in community day schools from being placed in IS  
          and also prohibits a continuation high school from placing more  
          than 10% of its pupils in IS. 

          Lastly, this bill authorizes the CDE to prohibit a school  
          district or COE from continuing to enroll a pupil in IS if the  
          pupil performs below average state standards for his or her  
          grade level and does not make significant progress.  There are  
          several concerns with this provision: 

          1) This bill does not provide a definition of "below average  








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          state standards" hence it is unclear as to how this provision  
          will be implemented and it will result in inconsistent  
          application throughout the state.  

          2) Our existing assessment and accountability system does not  
          measure nor does it report individual pupil achievement growth,  
          hence it is unclear as to how "significant progress" will be  
          measured in order to implement this provision.  

          3) The CDE does not monitor the achievement of individual pupils  
          enrolled in specific programs.  This would add a new level of  
          work that CDE currently does not perform and will translate into  
          new costs. 

          4) Most importantly, however is the concern that this bill takes  
          away a parent's right and option to place his or her pupil in  
          IS.  A pupil can only be placed in IS once the parent or  
          guardian, the pupil and others sign the required agreement, but  
          giving CDE the authority to prohibit continued enrollment of a  
          pupil in IS would essentially give CDE the authority to overturn  
          a parent's decision to enroll his or her pupil in IS.  This  
          Committee shall consider whether it is appropriate to take away  
          the authority to continue to place a pupil in IS out of the  
          hands of that pupil's parent or guardian and instead place that  
          authority in the hands of a bureaucratic entity that has no  
          direct knowledge of the wide-ranging needs of individual pupils.  
           This bill takes away options for parents to place their pupils  
          in a program that for many students may represent a safety net. 

          IS can be used on a short-term or long-term basis and on a  
          full-time basis or in conjunction with courses taken in a  
          classroom setting.  This bill does not distinguish between the  
          two and it applies to both settings, including IS high schools.   
          Districts operate IS as a program within a school or as  
          stand-alone IS high school.  According to CDE, more than 130,765  
          full-time kindergarten through grade twelve students used IS in  
          2007-08 and in 2007-08, over 19,000 IS students graduated from  
          high school or passed a high school equivalency exam.

          Should this Committee decide to pass this bill, the bill could  
          be amended to delete subdivisions (f) and (h) and revise  
          subdivision (g) as follows: 

               (g) When a school district refers a pupil to an alternative
               education program,  independent study shall not be the  








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               primary
               referral alternative. The   the  school district shall provide  
               the pupil and
               his or her parent or guardian with a listing of all  
               alternative
               education options, as well as a description of the  
               requirements the
               pupil must fulfill in order to return to his or her school  
               of origin.
               If the only appropriate alternative for the pupil is  
               independent
               study, a statement declining all other options shall be  
               signed by
               the pupil, his or her parent or guardian, and a school  
               official.

          The author states, "Independent study is typically the first  
          alternative option offered to students, when students do not  
          perform well, and threaten the schools' ranking. Independent  
          study should not be the first option, it should be the second or  
          third option presented to parents."

           Arguments in opposition  : The San Diego County Office of  
          Education (SDCOE) writes, "This bill would eliminate independent  
          study as a service option for students who are performing  
          below-average academically, meaning that only above-average  
          students could participate.  Since most students in the court  
          community are below grade level, this would eliminate this  
          option for them.  SDCOE screens students for their ability to do  
          independent work before allowing them to join the independent  
          study program."  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file. 

           Opposition 
           
          California Consortium for Independent Study
          California Continuation Education Association 
          Orange County Department of Education 
          San Diego County Office of Education 
           








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          Analysis Prepared by  :    Marisol Avi?a / ED. / (916) 319-2087