BILL ANALYSIS                                                                                                                                                                                                    






                          SENATE COMMITTEE ON EDUCATION
                               Gloria Romero, Chair
                            2009-2010 Regular Session
                                         

          BILL NO:       SB 1059
          AUTHOR:        Liu
          AMENDED:       April 5, 2010
          FISCAL COMM:   Yes            HEARING DATE:  April 21, 2010
          URGENCY:       No             CONSULTANT:Lynn Lorber

           SUBJECT  :   District of residence: foster youth in juvenile  
          hall with special education needs.

           KEY POLICY ISSUES

           Should a county office of education be financially  
          responsible for the provision of a free appropriate public  
          education to foster youth with special education needs who  
          have been detained in a juvenile hall and are subsequently  
          placed in a residential treatment facility?

          Should the county office of education be responsible for  
          transitioning such a pupil to a new educational placement if  
          the pupil's individualized education program team  
          subsequently determines a less-restrictive environment would  
          meet the pupil's needs?

          Should the county office of education be responsible for the  
          residential treatment facility placement if the juvenile  
          court no longer has jurisdiction over the pupil?

          Should the basis for determining the residency of a pupil  
          described above (and therefore which local education agency  
          is responsible for providing a free appropriate public  
          education) be the residency of the pupil's surrogate parent?

           SUMMARY  

          This bill requires a county office of education to be  
          financially responsible for the provision of a free  
          appropriate public education to a foster youth with special  
          education needs who has been detained in a juvenile hall and  
          is subsequently placed in a residential treatment facility.

           BACKGROUND  




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          Current law:

          1)   Provides that a pupil complies with the residency  
               requirements for school attendance in a school district,  
               if he or she is any of the following:

                  a)        A pupil placed within the boundaries of  
                    that school district in a group home or foster  
                    home.
                  b)        A pupil for whom interdistrict attendance  
                    has been approved.
                  c)        An emancipated pupil whose residence is  
                    located within the boundaries of that school  
                    district.
                  d)        A pupil who lives in the home of a  
                    caregiving adult that is located within the  
                    boundaries of that school district.
                  e)        A pupil residing in a state hospital  
                    located within the boundaries of that school  
                    district.  
                  f)        Until July 1, 2012, a school district may  
                    deem a pupil to have complied with the residency  
                    requirements in the district if at least one parent  
                    is physically employed within the boundaries of  
                    that district.  (Education Code  48204)

          2)   Requires the county board of education to administer and  
               operate juvenile court schools.  (EC  48645.2)

          3)   Requires, when an assessment determines that a pupil is  
               seriously emotionally disturbed and any member of the  
               individualized education program (IEP) team recommends  
               residential placement based on relevant assessment  
               information, the IEP team to be expanded to include a  
               representative of the county mental health department.  
               (Government Code  7572.5.)  

          4)   Requires the Superintendent of Public Instruction to  
               ensure that local education agencies provide special  
               education and those related services and designated  
               instruction and services contained in a pupil's IEP that  
               are necessary for the pupil to benefit educationally  
               from his or her instructional program.  (GC  7573.)  

          5)   Provides that the involvement of an administrator of the  
               special education local plan area (SELPA) in the IEP  
               team discussion of where to place the pupil shall in no  



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               way obligate a public education agency to pay for the  
               residential costs and the cost of non-educational  
               services for a pupil placed in a group home or foster  
               family home.  (GC  7579)  

          6)   Requires a local educational agency to appoint a  
               surrogate parent for a pupil under one or more of the  
               following circumstances:

                  a)        The pupil is a dependent or ward of the  
                    court, has no responsible adult to represent him or  
                    her, and either has an IEP in place or has been  
                    referred for assessment of special needs.
                  b)        No parent for the pupil can be identified.
                  c)        The local educational agency, after  
                    reasonable efforts, cannot discover the location of  
                    a parent.  (GC  7579.5)

          7)   Provides that the surrogate parent shall serve as the  
               pupil's parent and shall have the rights relative to the  
               pupil's education that a parent has.  The surrogate  
               parent may represent the pupil in matters relating to  
               special education and related services, including the  
               identification, assessment, instructional planning and  
               development, educational placement, reviewing 
               and revising the IEP, and in all other matters relating  
               to the provision of a free appropriate public education  
               of the pupil.  (GC  7579.5)

          State regulations require the local education agency to be  
          financially responsible for:

          1)   The transportation of a pupil with a disability to and  
               from the mental health services specified in the pupil's  
               IPE.

          2)   The transportation of a pupil to and from the  
               residential placement as specified in the IEP.

          3)   The special education instruction, non-mental health  
               related services, and designated instruction and  
               services agreed upon in the non-public, non-sectarian  
               school services contract or a public program arranged  
               with another special education local plan area or local  
               education agency.  (California Code of Regulations   
               60200)




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          Federal regulations require:

          1)   A recipient of federal Individuals with Disabilities  
               Education Act (IDEA) funds that operates a public  
               elementary or secondary education program or activity to  
               provide a free appropriate public education to each  
               qualified handicapped person who is in the recipient's  
               jurisdiction, regardless of the nature or severity of  
               the person's handicap.  This section authorizes a  
               recipient to place or refer a handicapped person for  
               aid, benefits, or services other than those that it  
               operates or provides, and specifies that the recipient  
               remains responsible for ensuring that the requirements  
               of federal IDEA regulations are met with respect to any  
               handicapped person so placed or referred.  (Code of  
               Federal Regulations  104.33)

          2)   A placement in a public or private residential program,  
               including non-medial care and room and board, to be at  
               no cost to the parents of the child if such placement is  
               necessary to provide special education and related  
               services to a child with a disability.  (CFR  300.104)

           ANALYSIS  

           This bill  requires a county office of education to be  
          financially responsible for the provision of a free  
          appropriate public education to foster youth with special  
          education needs who have been detained in a juvenile hall and  
          are subsequently placed in a residential treatment facility.   
          Specifically, this bill:

          1)   Declares that, for any pupil placed in a foster home or  
               group home, the school district in which the pupil  
               resides is the district of residence, and it is that  
               school district that is responsible for providing the  
               pupil with a free appropriate public education (FAPE).



          2)   Declares that, for a pupil in a juvenile court school,  
               the county board of education is the district of  
               residence and is responsible for the provision of FAPE  
               for individuals with exceptional needs.

          3)   Requires the county board of education, as part of  
               providing FAPE, to pay and provide for residential  



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               placement, any other related service, benefit or aid,  
               whether located inside or outside of the juvenile court  
               school. 

          4)   Requires the county board of education to remain the  
               district of residence when a pupil is placed at a  
               residential placement, even after the disposition 
                     of the pupil's delinquency case and through the  
          duration of the residential              
                     placement.  

          5)   Requires the county office of education to be  
               responsible for transitioning the pupil into a  
               subsequent educational placement if a determination is  
               made by the pupil's individualized education program  
               (IEP) team that a less-restrictive environment (than the  
               residential treatment facility) is appropriate for the  
               pupil.  This bill authorizes the subsequent placement to  
               be a public school or a non-public school certified by  
               the California Department of Education, and 
               requires the county office of education to develop an  
               IEP that includes a transition plan to the new  
               educational placement.

          6)   Requires, if a dispute arises regarding which local  
               education agency is responsible for providing FAPE, the  
               county board of education to be responsible for the  
               educational placement and services determined by the IEP  
               team until the dispute is resolved.

          7)   Authorizes the county board of education to seek  
               reimbursement from public agencies that fail to accept  
               timely responsibility for a pupil described in this  
               bill.

          8)   Declares that the residence of a surrogate parent or  
               judicially appointed person to act as the "parent" for a  
               pupil receiving special education does not determine the  
               school district of residence.  

           STAFF COMMENTS  

           1)   Need for the bill  :  According to the author, the lack of  
               clarity in existing law can make it difficult to  
               determine which local education agency is legally  
               responsible to provide services for foster youth with  
               special education needs who are detained in juvenile  



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               hall.  One of the problems resulting from this  
               uncertainty is that a school district that the child may  
               never have attended could be held responsible for the  
               provision of services.  Disputes are costly and time  
               consuming, and these pupils are not receiving necessary  
               services until the dispute is resolved.

           2)   Why should a county office of education still be  
               responsible once a pupil leaves juvenile hall  ?  The  
               pupils addressed in this bill are foster youth who have  
               been detained in juvenile hall.  Once a pupil enters  
               juvenile hall, the county office of education becomes  
               the district of residence.  The pupils addressed by this  
               bill are typically in juvenile hall with "charges  
               pending" because the court believes treatment may be  
               more appropriate than detainment.  If the individualized  
               education program (IEP) team, including mental health  
               professionals, determines a residential treatment  
               facility would meet the pupil's needs, the juvenile  
               court orders the placement.  Should the county office of  
               education remain the district of residence after the  
               pupil leaves juvenile hall because it was the district  
               of residence that developed the IEP recommending  
               placement in the residential treatment facility and the  
               juvenile court ordered the placement?

           3)   Why should a county office of education be responsible  
               to transition a pupil out of the residential treatment  
               facility  ?  This bill would require the county office of  
               education to be the district of residence while the  
               pupil is placed a residential treatment facility, and  
               therefore responsible for the pupil's IEP and transition  
               plan.  Is it reasonable to require a county office of  
               education to have the responsibility to transition a  
               pupil into an educational placement twice removed from  
               the juvenile court school?

          4)   Why should a county office of education still be  
               responsible once the juvenile court no longer has  
               jurisdiction over the pupil  ?  The pupil's IEP determines  
               what instruction and related services the pupil is to  
               receive.  A pupil's IEP must conclude that a residential  
               treatment facility is the most appropriate placement for  
               the duration of that placement.  It is possible that the  
               juvenile court would relinquish its jurisdiction (drop  
               charges) while the pupil is in the residential treatment  
               facility.  However, the pupil would still have an IEP in  



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               place that determines the most appropriate placement is  
               the residential treatment facility.  Should the county  
               office of education continue to be the responsible local  
               education agency once the juvenile court no longer has  
               jurisdiction over the pupil?

           5)   Example of the problem  .  A summary of a case involving a  
               foster youth with special needs who has detained in  
               juvenile hall was submitted by proponents:  "John" has  
               special education needs and while he was detained in  
               juvenile hall both of his parents abandoned him.  The  
               Department of Mental Health recommended, and John's IEP  
               team agreed, to place John in a residential treatment  
               facility.  The county office of education refused to pay  
               for this placement, contending they are responsible to  
               provide FAPE only while John is in juvenile hall.   
               John's prior school district refused to accept  
               responsibility because John was in juvenile hall.  The  
               school district of John's mother's last known residence  
               refused to accept responsibility because John had never  
               lived at that residence.  John remained in juvenile hall  
               for one year while the county office and two school  
               districts defended themselves against a due process  
               filing submitted by a law firm.  John was eventually  
               ordered to a camp placement by the juvenile court judge.

           6)   District of residence  .  This bill declares that the  
               residence of a surrogate parent or judicially appointed  
               person to act as the "parent" for a pupil receiving  
               special education does not determine the school district  
               of residence.  Proponents point to a court case that  
               ruled the district of residence for a pupil described in  
               this bill was the school district in which the pupil's  
               surrogate parent resided.  The pupil had never resided  
               in that district or attended schools in that district.   
               Should the residence of a person with whom the pupil  
               does not reside ever determine the district of residency  
               for the pupil?

           7)   How many pupils could be affected  ?  Proponents believe  
               as few as 50-75 pupils would be affected by this bill.

           8)   Mandate  .  Legislative Counsel has flagged this bill as  
               imposing a mandate upon county offices of education.

           9)   Policy arguments  :  




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                        Proponents argue that current law creates  
                    confusion as to which local education agency is  
                    legally responsible for providing services required  
                    under the federal Individuals with Disabilities  
                    Education Act to foster youth who are detained in  
                    juvenile hall, attend juvenile court schools, and  
                    require residential placement due to their special  
                    educational needs.  As a result, these youth spend  
                    inordinate amounts of time in juvenile hall without  
                    appropriate special education services.

                        Opponents contend that the district of  
                    residence has always been the school district in  
                    which a pupil's custodial parent resides, this bill  
                    shifts costs to county offices, and would have a  
                    serious negative impact because county offices are  
                    struggling to operate those programs within the  
                    existing inadequate funding model.

           SUPPORT
           
          Augustin Egelsee, LLP
          California Association for Parent-Child Advocacy
          Center for Juvenile Law and Policy, Loyola Law School
          Mental Health Advocacy Services, Inc.
          Public Counsel Law Center

           OPPOSITION
           
          Los Angeles County Office of Education