seaac financial accountability position paper

8/9/2019 SEAAC Financial Accountability Position Paper

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More Transparency and Greater Accountabi

for Special Education Funding

Position Paper

January 23, 2013


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Executive Summary

The law grants every special education student a full allocation for basic education because they are in f

education students, AND additional monies specifically for the “excess cost” to provide an appropriate e

Washington State legislators have established clear statutory requirements for the calculation, and use,

special education in our K-12 education system. These laws have been upheld by the State’s highest co

upon our District’s leadership and financial experts to be cognizant of these laws and heed them.

Our school board directors, specifically Michael DeBell , assert with regularity that special education cos

increasing at an unacceptable rate. SEAAC’s investigation of District and OSPI financial data shows that

cost accounting DOES NOT track the individual and total BEA expenditures for our students. Further, w

education costs per student have, in fact, been decreasing not growing unbounded. Special education a

argue that the quality of services provided students with disabilities has also decreased, with reduced s

inexpert special educators. A recent State audit found that building administrators use special educatio

general education expenses: salaries for dual-certificated educators teaching social studies, math and la

special education students (most with high-incidence - mild learning – disabilities) in these classes were

benefit of a general education in a regular classroom AND quality special education services. Instead of

special and general education, students with disabilities receive nothing more than access to a dual-cer

result of this practice is that students with disabilities 1) don’t receive excess services intended for them

into classes with reduced content and 3) shift to become the responsibility of low incidence, reducing t

students with low incidence disabilities.

1. Stop Inflammatory Statements Regarding Special Education Costs

Portrayal of our students as “hogs at the trough” negatively impacts their educational experience. When port

are scapegoated for all the financial problems in the district and blamed for services not provided in general.

2.

Affirm that Students with Disabilities are General Education Students Regardless of Their P

As general education students, students with disabilities are entitled to general education funding and opport

disabilities should be able to participate in every part of education.

3. Ensure That Special Education Funding Goes to Students with Disabilities.

Fix the practices like those at Ballard High School, where students receive only special education or general e

Classes with general education students ARE general education classes, even if they contain a few special stud

4. Affirm that Students with Disabilities are Entitled to Levy Funds and Participation in Levy-F

Students with disabilities should benefit from levy funds as all other. Levy funding should not be a way to circ

to special education students.

5. Improve the Method of Tracking Costs to Educate our Children

Track where our students receive education so that we may know the true cost of their education.

information, it should be relatively easy to use to accurately reflect the commitments of IEP teams

6.

Educate Every District Staffer Involved in Planning, Managing, and Delivering our StudentsAll staff responsible for program delivery should understand that our students need both general education an

Further they should ensure that all educational opportunities are accessible and available to students with disa

7. Increase Transparency

In addition to tracking and accurately accounting for the costs of students with disabilities, the district should

information crystal clear to the community.


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More Transparency and Greater Accountability for Special Educat

Table of Contents

Executive Summary ......................................................................................................

Table of Contents .....................................................................................................

1. Issue Statement .......................................................................................................

2. Consultation ...........................................................................................................

3.

Introduction ............................................................................................................

a.

OSPI Report 1220 ......................................................................................................

4.

Problem Scope .........................................................................................................

a.

Table 1 – State Funding per SPS Student ..................................................................

b.

Table 2 – FY11 Expenditures and Funding Source .....................................................

c.

Table 3 – Budgeted versus Actual Expenditures at 91 Buildings ...............................

d.

Table 4 – Ballard HS students counts in subjects w/ dual-certificated “special educ

5.

Recommendations and Solutions .............................................................................

Appendix 1 – OSPI “Excess Cost” Methodology

Appendix 2 - Supreme Court of Washington Case No 82961-6

Appendix 3 – Superior Court of Washington Case 04-2-02000-7

Appendix 4 – A Citizen’s Guide to Washington State K-12 Finance 2012

Appendix 5 – Primer on School Finance (cont.)

Appendix 6 – FY13 SPS Special Education State Revenue

Appendix 7 – 10-years F196 and S275 Special Education Cost Data

Appendix 8 Five year History of SPS Programs 21 24 26 and 29


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More Transparency and Greater Accountability for Special Education Fundin

1. Issue Statement

Special education students in Seattle Public Schools (District) bring, by virtue of their enrollment, both s

generated entitlement funds for their basic education (Basic Education Allocation or BEA) AND an “exce

for their special education. For many years, parents have questioned the use of their students’ funding

from administrators “we don’t have money for that” or “special education is not sufficiently funded!” D

pronouncements, it would appear that the District does not provide, nor have, a true picture of: a) wha

general and special education costs; and b) what our students’ BEA and excess cost revenue is spent on

questions are vital to demonstrate financial accountability and compliance with state and federal law. T

Education Advisory and Advocacy Council (SEAAC) calls on the District to improve its financial accountin

systems, such that its adherence to the law will be clearly evident.

2. Consultation

Information and data for this report was derived from numerous sources. We used references from the

provided by SPS Budget Director Joe Paperman and Senior Budget Analyst Warner Danielson.

3. Introduction

Washington State law has been interpreted by the courts as follows:

Special education students are basic education students first;

As a class, special education students are entitled to the full basic education allocation (BEA) Special education students are basic education students for the entire school day

School districts have challenged the sufficiency and purpose of funding for special education, arguing th

provided by the state for Program 21 (Special education, Funds 3121 and 4121) includes ALL that is allo

education students’ basic education. The districts failed to make their case. A Supreme Court decision

import rejected the arguments of school districts that challenged the way Washington State funds spec

School Districts’ Alliance for Adequate Funding of Special Education v. The State of Washington1, the cou

courts’ ruling that Special education students are entitled to their full BEA2 and excess funding from theextent a school district cannot provide an appropriate education for special education students…throug

apportionment allocation.”3

The Office of the Superintendent of Public Instruction developed the excess cost accounting methodolo

Appendix 1) is to ensure that special education students, as a class, receive basic education support, to w


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In rejecting plaintiffs’ appeal, the Supreme Court of Washington affirmed that:

Special education students shall receive their appropriate share of basic education support fro

staff when served in the regular classroom

When special education students are served outside the regular classroom, basic education do

partially support special education services they receive.4

Furthermore, in another significant Supreme Court decision5, the Legislature was required to define a “b

education,” and sufficiently and amply fund it. The Legislature now defines “basic education” as the fol

General Apportionment (RCW 28A.150.260

Special Education (RCW 28A.150.370)

Transportation (RCW28A.160.150)

Learning Assistance Program (RCW 28.A.165)

Bilingual (RCW 28A.180)

Institutions (RCW 28A,190)

Highly Capable Program

Full-Day Kindergarten

This lists places special education squarely in the definition of basic education. Likewise, the court has r

not decouple special education funding from BEA funding. In other words, both sources of funding fol

whatever setting they receive their education.6

The Legislature specifically correlated special education funding to the BEA allocation with a multiplier (

Report 1220 (page 5) shows how 93.09% of the BEA rate for special education, times the number of Spe

K-12 enrollment (and a few minor adjustments) produces the value for Revenue Code 4121, one of the

Purpose funds. It is often said that a Special education student bring twice the funding (193%) of a regu

she brings her FULL allocation for General Apportionment and her excess cost allocation. (A primer on

student’s 2013 General Apportionment is derived is in Appendices 4 and 5.)

Report 1220 also demonstrates how a portion of the General Apportionment generated by special educ

set aside in Revenue Code 3121 (a subset of the State General Purpose funds). This represents the % of

receiving general education in the special education classroom, as is the case for students in self-contai

(The WSECM assumes basic education dollars follow the special education student when outside the re

partially support special education services they receive). The sum of codes 3121 and 4121 add up to th

for Special Education Program 21.

Parents have been informed that Revenue Code 3121 represents ALL monies that our children bring wit

education, however this is where the some lose sight of the General Apportionment revenues garnered

The courts have been crystal clear on this point Our students are due their full BEA including that por


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4. Problem Scope

A. The District considers the revenue in Code 3121 as ALL that our students get for their general educ

not recognize the millions of dollars in Revenue Code 3100 that is generated due to our students’ eB. Without reference to the relationship between revenue codes 3121 and 4121, the former School B

others regularly decry costs for special education as “out of control” and consuming increasing amo

revenues. This is used as the basis to complain about funding, as if our students are not entitled to

any other student.

C. The district’s report to OSPI, F196, shows that Program 1, General Education, also consumes levy p

okay to spend levy proceeds on Program 1 and not Program 21? General education students are n

their use of levy funds.

D.

Parents are subjected to the inaccurate claims made by the District administration that educating o

costing more than their “fair share”. This feeds an intolerant attitude, particularly among building

it leads to prioritizing keeping costs down, over providing training for staff and services on a child’s

E. District financial reporting does not track where our students’ General Apportionment is spent, if n

of general education support in the regular classroom.

F. Building budgets are based upon our students enrollment (and the weighted staffing standards WS

established, principals can spend as they see fit, without oversight. Some, as at Ballard High Schoo

restricted use funds to fit their version of “delivery of services”. Who will hold building administrat

must we rely on the State Auditor?

G. The ICS delivery model brought with it poor quality services AND high cost. The changes to the WS

for K-5 seats in the regular classroom that may not be filled, if those students are in fact in a self-co

most of the day.

On Item A: As explained above, the General Apportionment allocation for Special Education is intended

cost” of general education in the special education setting. ALL Special education students are GENERA

STUDENTS FIRST (and entitled to any and all funding available for general education). The vast majorit

education students (70%) are in the regular classroom for most of the day.

Table 1. State Funding per SPS Student

Basic Education Allocation Rates Amo

Guaranteed Entitlement per Student

[Total Guaranteed Entitlement]/[Enroll Total] $5,06

Total BEA per SpEd student x .9309

[Total Salary BEA]+[Total Benefits BEA]+[Substitutes BEA]+[MSOC BEA per Student] no CTE $4,68

Total Funding available for a SpEd students general and special education $9,74

Appendix 6 shows how much TOTAL revenue special education students bring the district: $60,783,760

revenues for Apportionment (codes 3100 and 3121) and Special Education (Code 4121) combined. Our

nearly $30,500,000 for their general education which corresponds to the maximum 12.7% the state allo


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to expand to include more grades in K-5. In the interim, services have been degraded and children have

impacted.7

Furthermore, families often hear that the Federal government should “fully fund” special education, as

an unfunded mandate. First of all, the mandate for special education in the state of Washington predat

the full obligation of special education falls squarely on the state of Washington. Secondly, the Federa

IDEA because disabled children were being denied their civil right to a free and appropriate education li

children. Likewise, the Federal government passed the Civil Rights law, ADA, and Title IX. Should we lo

government to fund: the education of black children; removal of barriers to access, and girls soccer? Th

federal government will fund special education suggests a belief that education of our children is not a d

the school district. It implies that our students are not entitled to a basic education like all other studen

Appendices 8 and 9 contain two reports. OSPI’s Report of the District’s 5 year Special Education expend(Programs 21-29) shows that, as a percentage of total district costs, special education spending has dec

years in a row. This decrease has been in spite of increasing special education enrollment. Further, OS

Program 21 overages on a per student basis have steadily declined, most recently by 6% in FY11. So, co

within the administration or board may believe, special education coasts are not out of control; in fact,

they have decreased.

On Item C: Table 2 shows data from the district last fiscal year filing (FY11) based on the F-196 submitt

Table 2. FY11 Expenditures and Funding Source

Resource to Program Expenditure

FY11 F196

Program

Expenditures

State

Resources

Federal

Resources

Other (levy)

Resources

%

t

01 Basic Education $253,654,164 $163,024,326 $147,870 $90,481,966

21 Special Education, Supplemental $60,767,209 $40,576,426 $13,977 $20,176,806

Program 1 requires MORE levy proceeds as a percentage of expenditures, than Program 21. Basic deniadisabilities deserve a share of levy proceeds like all other students, leaves the public with the impressio

are not worthy of a share of taxes collected, not even a smaller share.

Additionally, there is a failure to note that general education draws on levy funds as well. Perhaps this

use of these funds, that art and music classes are more necessary than reading and writing proficiency,

support. ALL students require additional funds from the operations and maintenance levy to fill the rev

education for every student. When students with disabilities are specifically cited as drawing on the levy

them for the problems of insufficient funding.

According to the FY11 F196, , the District spent $90M or 81.7% of the O&M levy proceeds applied to pro

cover for inadequate funding for basic education. Likewise for special education students, $20M is requ

total levy amount spent for programs 1 and 21. Special education enrollment is capped at 12.7% enroll

The revenues our students bring to the school subsidize the expenditures for the activities for all other s


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Special education students are often “tracked” in limited classes for the convenience of district

(see Item F and Table 4)

Special education students are denied access to many programs such as language immersion a

education simply because the district declines to offer support in those programs and buildings

On Item D: The district does not track the time special education students spend in special education se

individual basis. Tallies for the amounts of time spent in every restricted setting are simply not tracked.

because that information in necessary to determine how much of the General Apportionment funding s

towards each restricted special education setting. Instead, it is being used to pay general education tea

among other things. Restricted settings include special education self-contained/inclusion classrooms,

locations other than a general education classroom setting. During these periods in restricted education

disabled student's entire General Apportionment funding (and expenditures) should be accounted for aeducation settings. Instead, that funding and expenditure remains in the general education setting even

is not present to receive the benefit. In other words, the Special education student got a “seat” in the r

but s/he doesn’t get to use it.

Since the district does not, and, it seems, cannot track where a student is receiving instruction, the distr

adequately account for the students' General Apportionment funding. Instead, the district counts this a

charges special education funding sources for services that should be considered General Apportionme

erroneous accounting practice makes it appear like Program 21 costs are out of control when in fact, th

On Item E: Under the new WSS, K-4 students with disabilities are funded with full general education sea

applaud the presumed intent to include students with disabilities in general education, the funding mec

unintended consequence. Rather than funding disabled students for what they actually need and use in

schools are incented to have disability programs AND THEN NOT make this seat available to the student

When this is done, disability programs in a building simply fund reduced class size for other students. Th

for principals to actually include disabled students in general education, and nobody holds them accoun

essence, disability related funding is again funding benefits for other people while students with disabil

the funding they drive to a building. Many principals note that fully-funded seats are necessary but not

inclusion. Appropriate staffing levels are not provided to allow students the inclusion they need, and oft

their IEPs.

As noted above, district financial accounting does not track where our students’ BEA is spent. Once bud

the schools, building staff are free to charge expenses to any cost center with little oversight. So, even t

bring their State allocation for Maintenance, Supplies, and Operating Costs (MSOC), our special educatio

often without books and without supplies. Conversely, if a special education student is in frequent in-h

how is their BEA being used to ensure they continue to receive the benefit of general education? How a

held accountable for expenditure of our students BEA?

It would appear District financial accounting is not transparent. Parents requested the FY12 financial re

closing the books for the fiscal year. The actuals are shown on Table 3 below. In subsequent meetings

we are told that the expenditures for Program 21 do not include $7M for Time Response and Incentive


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On Item F: Examination of 91 schools’ FY12 Budget vs Actual expenditures (at closing) reveals that, in t

underspent their special education budgets by $7.7M or 13%, while under-spending on general educati

Special education budget went to the buildings, but was not applied where it should. Where did it go, a

benefit?

Table 3. FY12 Budgeted versus Actual Expenditures at 91 Buildings

Category (FY12) Budgeted Expended %

Program 1 - GenEd $ 222,340,589 $ 220,135,261

Program 21 - SpEd $ 60,104,964 $ 52,421,861

A clear example of this lack of accountability is the State Auditor’s finding at Ballard High School. For a n

Ballard’s principals have incorrectly charged 100% of the salaries of dual-certificated teachers to Progra

Education, even though they teach subjects like U.S. History or American Government and Economics to

and special education students. Granted, the classes have special education students enrolled – as ALL

classes do and should. Simply because a teacher is dually certified in subject matter and special educat

special education students in their classroom, does NOT make that a special education classroom. Tho

being denied the benefit of their basic education allocation when they are denied access to general edu

Furthermore, the “excess cost” funding these high-incidence students bring with them, is being used to

regular education staff salaries; and b) benefit general education students with remedial coursework.

Ballard’s “creative accounting”, though lauded as “out of the box” thinking by some district administrat

by the State Auditor’s Office in a recent audit8. Unfortunately, the latter applied a simplistic approach a

serious impropriety. Much like Solomon’s advice to “split the baby”, the SAO recommended charging th

teachers’ salaries 50-50 to Program 1 and Program 21. This is NOT compliant with the State’s “excess co

The SAO recommendation does not even comply with the old excess cost accounting methodology whic

to use the previous year’s LRE (least restrictive environment) to compute Special education FTEs in the

(The WSECM supercedes the old 1077 method, shown in Appendix 10, which was deemed by a 2007 Go

Accounting Ad Hoc Committee, as nontransparent and inaccurate.)

The Committee’s report, transmitted on January 15, 2007, (Appendix 11, which built upon the Joint Leg

Review Committee, JLARC, Report 06-39) provides the following specific direction on Pg 3:

The proposed method has two objectives. First, to ensure that special education eligible students, as a c

full share of general apportionment (basic education) funding before accessing the state excess cost fun

simplify and consistently apply the cost accounting necessary to achieve the first objective by shifting the

cost accounting function from the local school district to the state apportionment office.

The proposed accounting method will:

a) Shift a portion of basic education revenue to the special education program based on students’

equivalency (FTE) in the special education setting; and


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The basic education revenue shifted to the special education program, revenue 3121, is intended to esta

amount of spending of state program 21 before the school district accesses the excess revenues, revenu

the excess cost formula (.9309 of general apportionment revenue).

The method is referred to as the Washington State Excess Cost Accounting Method (WSECM).

Specifically:

1. Districts would continue to use the 1077 to generate student FTEs served in the special educatio

number will be specific/unique for each school district. (Currently of the approximate113,000 school-age

specially designed instruction and generating general apportionment revenue, ~70% of full-time equival

served in the regular education setting; ~30% of FTE students are served in the special education setting

2. Based on the split of FTE described above, OSPI would split general apportionment funds associstudents eligible for special education into three categories:

a. General apportionment for the regular education classroom (current account code 310

b. General apportionment for the special education setting (new account code 3121);

c. Indirect support for utilities, administration, district-wide services, etc.

3. Districts will code their staff and appropriate expenses related to providing specially designe

special education program (emphasis added).

4. Districts will first expend the general apportionment funding (emphasis added) associated wit

3121 and then expend excess cost funding attributed to revenue code 4121.

Clearly, Ballard’s creative accounting has served to supplant its Special education students’ BEA and gen

funding by paying for their general education teachers with the students’ “excess” funding for specially-

instruction. Where are our students’ regular classroom teachers when the students are “served” and tr

“special education” classrooms all day? The auditor’s recommendation was deficient and not supporte

legislative budget provisions, OSPI regulations and Supreme Court rulings.

The district’s Budget Book includes Ballard’s initial budget details, including acknowledgement that spec

students supply 20% of the school’s entire budget. Actual FY12 Program 21 costs were 17% of total sch

Where was the other 3% expended if not for SDI and services? Why did administrators inform parents

transition services that there were “no funds” to supply a study space for these students? A recent OSP

has faulted Ballard’s principal for NOT providing resources like space, computers and supplies for Specia

transition students enrolled in Ballard’s program.

Finally, Ballard’s enrollment of Special education students calls for 75 periods (at varying levels of suppocollective bargaining and the WSS). The funding formula negotiated in the collective bargaining agreem

into essentially three basic categories of need: SM1, 2 and 4. Students are placed into this leveled syste

intensity of the service they require. At the secondary level, teachers are assigned and FUNDED full time

following ratios:


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(11-12 Ballard students enrolled at SM4 level 46/8 * 6 periods = 34 SM4 sped periods.

Number of SpEd Periods = 75

But, from the BHS course schedule we see only 48 periods of special education are actually made availadisabilities (Appendix 12). Of these, five periods have only 3-6 high incidence students each (Page 14).

budgeted but not provided to students with disabilities. This represents 36% of the monies budgeted f

at Ballard. . It means that 27 periods of special education funding are being misappropriated for gener

other students enjoy reduced class sizes because special education funding is available to them, and tha

students are clustered in but a few general education classes. It means the other Ballard general educa

teaching the same subjects, have 7% or fewer special education students in their classes, far less than th

school (see Page 9). This is not a mere oversight, nor an inconsequential loss. Students at other district

their BEA and “excess costs” funding similarly misused or withheld. These conditions convey bad faith a

exclusion to special education families.

Is it any wonder Ballard has a unique video production program, Maritime Academy, BioTechnology Aca

VocEd etc? All funded from the General Fund (with the exception of a $25K grant). Where does the mo

pay for these enrichments? Ballard HS is a textbook case of how an administrator can use his discretion

privileged projects benefitting the few, while our Special education students are denied access to these

tracked in classrooms with little rigor and low expectations.

On Item G: The District’s ill-conceived Integrated Comprehensive Services roll-out (ICS) has led to incre

numerous reasons, the District elected not to follow the recommendations in its own 2008 peer-review

education. It assumed the temporary infusion of Federal ARRA stimulus funds would carry the costs of

implementation. These costs included changes to the WSS that essentially purchased a general educati

student, whether some Special education students in self-contained programs occupied those seats. N

gone, the District has buildings with both ICS AND “grandfathered” programs, doubling the cost.

Perhaps worse than the increase in costs is the deterioration of special education services. Where Leve

once served at ratios of 1:8:2 and allowed access to regular classrooms, they are now unsupported in “e

rooms at 1:18:1: the alternative is self-contained. This presents a Hobson’s choice to families who wantreceive services, but also be included to the maximum extent possible. Simply because administrators c

a program or “service delivery model” does not change the level of support that low-incidence students

by law, receive.

5. Recommendations and Solutions

The District can lay out a more constructive path with greater accountability and the support of special

by implementing the following steps:

Cease and Desist Derogatory Statements regarding Special Education Costs - District officials sho

inaccurate and divisive statements regarding provision for our students’ education and services. As som

on recent newspaper articles illustrate, there is vast ignorance about the capabilities and promise our c

Similar ignorance is exhibited at school level, where staff and parents complain about the “burden” of e


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Educate every District staffer involved in planning, managing, and delivering our students’ edu

must educate district/building administrators and teachers that our students bring their full BEA wherev

general education. Furthermore, train staff that Special education funding shall be used ONLY for the p

students’ special education and related services. Provide staff a copy of this position paper, if necessarymore fully understand the statutory and legal underpinnings of these points of fact.

Increase Transparency - The District must restore trust with families after a damaging audit f inding th

long misuse of Special education students’ funding. Building administrators must: a) budget and staff ac

of services listed on IEPs; and b) account for expenditure of the “excess cost” funding for those services

should be available during the budgeting process, and on demand throughout the fiscal year. The Distr

should review ALL charges to Special education cost centers, to guard against further misuse of funds se

“excess cost” of our students’ FAPE.

Improve the Method of Tracking Costs to Educate our Children – District financial staff can take a

businesslike, approach to accounting for the costs to provide our students’ education. Once an IEP is co

possible to assemble projected costs to provide the services listed. Use standard or unit costs per minu

As noted in the JLARC report10

:

The IEP would then become not only a service plan, but an itemized record of every special edu

expenses. This methodology is the most like to capture coasts in their fullest form and would bresponsive to changes in the special education population and needs…

This methodology would be extremely good at capturing costs because it would do so at the le

special education student.

As it stands now, the District takes a “Total Cost” approach, which reveals little information for sound p

assessment and decisionmaking.

To determine appropriate funding streams, and therefore the viability of those funding streams, we

understanding of where students receive their education. All the funding streams for students with d

supposed to follow the student to any environment that they receive services during the day. Withou

of where students receive services, there can be no accounting for the use of the appropriate funding

Fortunately, the district maintains IEPonline which has this specific information. The amount of time

his special education setting is known, and appropriate amounts of BEA can be applied and account f

This information is not completely accurate because IEPs are not always fully implemented or followe

Stop the Improper Practice at Ballard High School – Our students’ excess cost funding is being used

education “remedial” courses at Ballard. They do not meet the letter or spirit of the definition for spec

District leaders and non-Special education staff don’t know that and don’t want to know that. Frankly, t

deprives our students of equitable access to regular education staff and coursework. District leadership

this misuse of funds intended for our students IEP services.


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Keep Special education funds in the Building, NOT at Central Administration – At FY12 closing, n

charged to Central Special education cost centers (not including transportation). This includes, of cours

OT/PT, Nursing and Adaptive PE. However, that amount represents over 50% of the amount actually sp

Records show approximately $1.3M is spent on supervision and Legal (primarily outside counsel). Thesused to hire the staff needed to support students in classrooms.

Recognize Building Administrators who Provide Quality Services, Not Cost Cutting – At FY12 clo

schools analyzed spent LESS on Special education than originally budgeted. Conversely, 87 of the schoo

GenEd than originally budgeted. This partially explains the phenomenon (not uncommon) when princip

students the services in IEPs, claiming poverty. Recognize and reward administrators who follow the law

services and support on our students IEPs.

Respectfully submitted,

SEAAC


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OSPI Citizen Complaint 12-50 Table 4

Ballard HS student counts in subjects w/ dual-certificated "special educators"

Period

Subject/Teacher

GenEd SpEd GenEd SpEd GenEd SpEd GenEd SpEd GenEd SpEd GenEd SpEd Total SpEd % Tot

Language Arts

Blish 21 0 19 2 21 4 6 10%Calderwood 30 1 29 1 25 2 26 1 Prep 23 0 5 4%

Coe 29 0 28 4 25 0 23 2 24 1 7 5%

Foster 22 1 23 2 28 2 5 7%

Kelly 31 0 31 0 30 0 29 1 1 1%

MacDougall 22 0 24 0 29 1 1 1%

Reardon 27 1 28 0 25 0 32 0 25 0 1 1%

Riley 23 3 25 2 22 3 8 11%

Smith 26 0 17 0 31 0 0 0%

Spencer 30 0 18 0 26 0 30 3 28 1 4 3%

Bolen 12 15 3 18 4 0 2 14 13 11 10 47 85%

Tucker 18 9 4 19 9 24 6 19 7 35 44%

Mathematics

Bower 24 0 26 5 28 0 32 0 24 5 10 7%

Broom 24 0 26 5 28 0 32 0 24 5 10 7%

Cartales 30 1 27 3 19 5 9 12%

Clem 28 1 26 0 17 0 1 1%

Day 33 1 35 0 17 8 11 1 36 1 11 8%

Drabek 33 0 25 4 31 1 17 1 31 0 1 1%

Guerrero 16 2 17 2 30 2 29 2 22 3 11 10%

Kimes 24 2 24 0 30 1 32 1 34 1 5 3%

Nutting 27 3 27 0 20 0 3 4%

Rus 22 0 27 0 29 0 24 3 25 0 3 2%

Vertucci 20 5 6 17 11 20 8 2 5 35 59%Social Studies

Feise 26 1 29 2 26 5 29 1 29 1 10 7%

Green 27 0 29 2 27 1 32 0 29 0 3 2%

Hale 28 3 34 0 24 2 24 1 25 0 6 4%

Hering 32 0 25 6 30 1 7 8%

Kemp 26 4 32 0 29 4 22 3 11 10%

Locklin 23 2 30 2 26 0 31 0 18 3 7 5%

McArdie 24 0 34 0 32 0 28 0 0 0%

Thompson 21 3 26 3 29 1 30 1 32 1 9 7%

Nygaard 19 12 15 12 4 13 13 15 12 53 85%

Washington 24 5 28 0 24 0 21 8 6 19 20%

4 5 6

Prep

Prep

1 2 3

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

Prep

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Exhibit 8

Washington State Public School Districts

Special Education - Programs 21, 24, 26, and 29

(Source: Office of Superintendent of Public Instruction F-196 Annual Financial Statements)

SEATTLE SCHOOL DISTRICT

17001

Enter County District number above.

See the CCDDD w orksheet for an alphabetical list of County District numbers.

Enter 99999 for State Summary.

Special Education Fiscal Year % to Fiscal Year % to Fiscal Year % to Fiscal Year % to

Programs 21, 24, 26, and 29 2010-2011 Total 2009-2010 Total 2008-2009 Total 2007-2008 Tota

99 Total All Special Education Programs

Enter an individual Special Education program number in the yellow shaded cell (21-29).

Enter 99 in the yellow shaded cell to display the total of all programs included in Special Education (21-29).

E di B A i i


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Expenditure By Activity

21 Activity 21 - Instruction Supervision

2 Salary & Benefits 981,360 1.46% 3,088,388 4.52% 2,782,833 3.99% 2,752,495 4.

5 NERC 1,177,528 1.75% 1,181,482 1.73% 1,355,920 1.95% 1,022,609 1.

22 Activity 22 - Learning Resources

2 Salary & Benefits

5 NERC 321 0.00%

23 Activity 23 - Principal's Office

2 Salary & Benefits

5 NERC

24 Activity 24 - Guidance and Counseling

2 Salary & Benefits

5 NERC 202 0.00% 312 0.00%

25 Activity 25 - Pupil Management & Safety

2 Salary & Benefits

5 NERC

26 Activity 26 - Health Related Services

2 Salary & Benefits 13,354,881 19.90% 15,519,280 22.69% 15,085,961 21.65% 13,354,262 20.

5 NERC 194,891 0.29% 410,154 0.60% 405,355 0.58% 457,940 0.

27 Activity 27 - Teaching

2 Salary & Benefits 48,922,971 72.90% 45,472,875 66.49% 47,775,664 68.56% 46,406,229 69.

5 NERC 2,480,972 3.70% 2,723,287 3.98% 2,279,460 3.27% 2,751,524 4.

28 Activity 28 - Extracurricular

2 Salary & Benefits

5 NERC

29 Activity 29 - Payments to School Districts

5 NERC

Total Special Ed. Salary & Benefits 63,259,213 94.26% 64,080,542 93.69% 65,644,458 94.20% 62,512,986 93.

Total Special Ed. NERCs 3,853,593 5.74% 4,314,923 6.31% 4,041,368 5.80% 4,232,073 6.

Total Special Education 67,112,806 12.7% 68,395,465 12.9% 69,685,826 13.2% 66,745,060 1decrease decrease increase incr

Total District Expend. (all Programs) 529,640,330 531,774,465 528,663,176 481,243,117

% Special Ed. to Total District Expend. 12.67% 12.86% 13.18% 13.87%

134,674.25 132,200.75 129,802.60 127,685.18

Total State Special Ed. Per Pupil 8,680.23 8,436.69 9044.66 8,600.54

6,522.50

less than 09

10 6,359.00

less than

08-09 6,177.50

more than

07-08 6,058.74

more

0

Total District Special Ed. Per Pupil 10,289.43 95.7% 10,755.70 95.3% 11,280.59 102.4% 11,016.33 11

*Special Education enrollment includes headcount for birth-to-five programs as reported to OSPI.

*Total District Special Education

Enrollment

*Total State Special Ed. Enrollment

Exhibit 8

Washington State Public School Districts

Special Education - Program 21

(Source: Office of Superintendent of Public Instruction F-196 Annual Financial Statements)

SEATTLE SCHOOL DISTRICT

17001Enter County District number above.

See the CCDDD worksheet for an alphabetical list of County District numbers.

Enter 99999 for State Summary.

Special Education - Program 21 Fiscal Year % to Fiscal Year % to Fiscal Year % to Fisc

2010-2011 Total 2009-2010 Total 2008-2009 Total 200Expenditure By Activity

Activity 21 - Instruction Supervision

Salary & Benefits 421,050 0.74% 690,842 1.21% 553,805 0.93%

NERC 1,169,625 2.06% 1,155,205 2.03% 1,322,331 2.23%

Activity 22 - Learning Resources

Salary & Benefits

NERC 321 0.00%


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C 3 0 00%

Activity 23 - Principal's Office

Salary & Benefits

NERC

Activity 24 - Guidance & Counseling

Salary & Benefits

NERC 202 0.00% 312 0.00%

Activity 25 - Pupil Management & SafetySalary & Benefits

NERC

Activity 26 - Health/Related Services

Salary & Benefits 10,857,412 19.15% 13,166,572 23.08% 12,766,981 21.49% 1

NERC 15,029 0.03% 265,995 0.47% 103,437 0.17%

Activity 27 - Teaching

Salary & Benefits 43,251,024 76.27% 40,599,340 71.18% 43,612,324 73.40% 4

NERC 990,923 1.75% 1,162,414 2.04% 1,059,979 1.78%

Activity 28 - Extracurricular

Salary & Benefits

NERC

Activity 29 - Payments to School Districts

NERC

Total Program 21 Salary & Benefits 54,529,486.55 96.16% 54,456,753.74 95.47% 56,933,110.34 95.82% 54,7Total Program 21 NERCs 2,175,778.90 3.84% 2,583,613.82 4.53% 2,486,379.14 4.18% 2,3

Total Special Education 56,705,265.45 57,040,367.56 59,419,489.48 57,0

Total Dist. Expend. (all Programs) 529,640,330 531,774,465 528,663,176 48

% of Program 21 to All Expenditures 10.71% 10.73% 11.24%

*Total Special Education Enrollment 6,522.50 6,359.00 6,177.50

Total Special Education Per Pupil 8,693.79 8,970.02 9,618.70

Revenue 3121 - Special Education - General Apportionment

Total 3121 Revenue 8,472,070 8,422,604 8,375,957

Revenue 3121 % to Program 21 Expend. 14.94% 14.77% 14.10%

Revenue Per Pupil 1,298.90 1,324.52 1,355.88

Revenue 4121 - Special EducationTotal 4121 Revenue 31,466,561 30,953,412 30,879,944 2


Revenue Per Pupil 4,824.31 4,867.65 4,998.78

Revenue 4321 - Special Education - Other State Agencies

Total 4321 Revenue


Revenue Per Pupil 0.00 0.00 0.00

Revenue 6121 - Special Education - Medicaid Reimbursements

Total 6121 Revenue 1,505 536,033




Total 6221 RevenueRevenue 6221 % to Program 21 Expend. 0.00% 0.00% 0.00%



Total 6321 Revenue 245,863 554,458

Revenue 6321 % to Program 21 Expend 0 43% 0 97% 0 00%

EXCESS COST ACCOUNTING FOR SPECIAL EDUCAT

PURPOSE

The purpose of the special education excess cost accounting methodology is to ensure thaeducation students as a class receive basic education support to which all students are ent

special education revenues are used to supplement basic education support.

The 1077 method provides a uniform statewide method of allocating basic education suppoeducation services. This uniformity will permit comparison of school district special educatand expenditures, and help identify districts in need of state special education safety net fu


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ACCOUNTING DEFINITION

The Accounting Manual for Public School Districts in the State of Washington defines spec

excess costs as follows:

“Excess costs” are those expenditures for special education and related services for s

education students that exceed the amount needed to provide a basic education to tho

students.

ASSUMPTIONS OF THE 1077 METHOD

The 1077 method relies on each school district’s December federal child count Report 1077

Implementation of Least Restrictive Environment Requirement to determine the amount of sprovided to special education students outside the regular classroom.

This methodology assumes that:

• Special education students receive their appropriate share of basic education supbasic education staff when served in the regular classroom.

• When special education students are served outside the regular classroom, basicdollars follow them to partially support special education services they receive.

• The amount of basic education support that follows students is approximated by p

FTE certificated staff unit to each 20 FTE students.• The resulting level of basic education support is provided for special education se

charging a portion of each special education teacher to basic education.

• Nonemployee related costs (NERC) and administrative costs are charged to the seducation program only to the extent they exceed the costs of regular education.

Federally-funded special education services are also supplemental and are charged to the education program consistent with federal guidance. (See OMB Circular A-87 and SPI Bul04.)

REQUIRED EXCESS COST METHODOLOGY (1077 METHOD)

All school districts are required to use the following method to determine the special educacosts allocated to basic education Key elements of this methodology are:


School districts are to use this method consistently for budgeting (Report F-195), streporting (Report S-275), annual financial reporting (Report F-196), and safety net ap

1. Identify all employees serving the special needs of special education studentand current school years. These services include:

• Services required by student individualized education programs (IEPs).

• Evaluation of students for special education services.

• Direct administrative and clerical support for special education staff and studen


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pp p

2. Determine the special education full-time equivalent (FTE) of each employee’follows:

• Select a typical week of service.

• Determine the amount of time the employee provides special education service

• Divide by the employee’s total hours of employment.

• For federally funded employees use time and effort distribution or other approv(See OMB Circular A-87 and SPI Bulletin No. 006-04.)

A 1.0 FTE indicates that the employee serves only special education students.

3. Identify special education FTEs that are “pure excess cost.”

“Pure Excess Cost” FTEs

Special education administratorsDuty roots 11–25

Certain certificated teachers:

♦ Prekindergarten teachers

♦ Teachers charged fully to federal special educationprograms using approved federal methodology

Duty roots 31, 32, 33, 52, and 63

Educational staff associates (ESAs) Duty roots 40–49 Classified staffDuty roots 90–99

4. Charge the “pure excess cost” FTEs to the following special education progr

• Program 21 Special Education—Supplemental—State.

• Program 24 Special Education—Supplemental—Federal.

• Program 29 Special Education—Other Federal.

5. Identify all other teachers as “part basic education” funded.

“Part Basic Education” FTE Teachers

All certificated teachers* except:


A. Obtain the prior year’s Federal Child Count Form SPI 1077 ImplementationRestrictive Environment Requirement (use December 2005 for the 2006–2calculations).

B. Calculate an approximate full-time equivalent (FTE) of students served in tclassroom by summing the following:

• The number of 6–11 year old students in Table 1 times 92 percent.

• The number of 12–21 year old students in Table 1 times 87 percent.

Th b f t d t i T bl 2 ti 64 t


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• The number of students in Table 2 times 64 percent.

• The number of students in Table 3 times 13 percent.

C. Subtract the number of students from step B from the total number of stude

1, 2, and 3. This gives the approximate FTE of special education studentsoutside the regular classroom.

D. Divide the number of students from step C by 20. This is the assumed numeducation FTE staff needed to serve special education students outside thclassroom.

E. Determine the total “part basic education” FTE teachers for the prior schooroots 31, 32, 33, 52, and 63) in step 5. (Include both basic education Prog

and 45 and special education Program 21 parts in the total.)

F. Divide the result of step D by the result of step E to get the percent of eacheducation” FTE teacher to be charged to basic education in the current yea

G. For each current year “part basic education” FTE teacher identified in step percentage derived in step F to basic education (Programs 01, 31, or 45) aremainder to special education (Program 21).

Illustration for 2006–2007 School Year

A. The district’s Form 1077 from December 2005 is summarized as follows:

Percent of day in

regular class

Ages

6–11

Ages

12–17

Ages

18–21 To

Table 1 80%–100% 137 61 — 19Table 2 40%–79% 75 91 16 18Table 3 0%–39% 25 58 13 9Grand Total 47

B. Calculate approximate FTE students in the regular classroom:

• Table 1 ages 6–11 = 137 students * 92% = 126.04

• Table 1 ages 12 21 = 61 students * 87% = 53 07


E. The district identified 30 “part-basic education” FTE teachers for the prior yearin step 5 of the step-by-step methodology. (Include the total FTE including boand special education parts.)

F. 8.40 / 30 = 28.0% (Round to one decimal.) If this ratio is over 100% the distrallocate 100% of the “part basic education” FTE teachers to basic education aallocate additional “pure excess cost” certificated FTE staff to basic education

G Charge 28 0% of each current year (2006–2007) “part basic education” FTE te


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G. Charge 28.0% of each current year (2006–2007) part basic education FTE teeducation. Charge the remaining 72% to special education.

7. Excess cost accounting principles also apply to supplemental contracts.

Supplemental contract costs may be all basic ed costs, part basic ed costs, or puredepending upon the services provided.

8. Contractual payments for special education services are to be allocated betweenspecial education programs if:

• The services are provided by employees defined as “part basic education” in s

• The district is receiving basic education funding for the student for the time of s

9. Charge other nonemployee related costs (NERC) to special education programs

• Costs are directly traceable to enhanced services for special education studen• Costs are required by the IEP.

• For other costs, determine what portion is in excess of the costs required for bastudents and staff. (Costs that are “part basic education” may be allocated basreasonable methodology. It is not necessary to divide each transaction as longcumulative NERC expenditures are reasonably divided.)

10. Special Education Excess Cost Worksheet – Form 1077

• For your convenience, the 1077 worksheet for FY 2006–2007 has been posted

School Apportionment and Financial Services website.• To calculate a district’s split coding percentage based on 2005 Federal child co

simply:o Key in the district’s county district number in highlighted Cell G3.o Federal child count data for the district will auto-populate.o In Cell L17, Step E, enter the district’s special education pool for 200

is the total FTEness of certificated special education teachers who aProgram 21, Activity 27, Duty Roots 31, 32, 33, 52, and 63 PLUS thetheir FTEness that has been split coded to Program 01. Do not inc

kindergarten teachers! o Completing steps 1 and 3 (above) will generate the split coding perc

charged to Basic Education (Program 01) and Special Education (Pr

Recommendations to the Governor and Legislature re: SEducation Excess Cost Accounting

Excess Cost Accounting Ad Hoc CommitteeMary Alice Heuschel (Renton)Fred Row (Renton)Trip Goodall (Deer Park)Carol Gray (Vancouver)Sue Curtis (Anacortes)Christie Perkins (Coalition)

Kris Lenke (Puyallup)Dennis Mathews (ESD 112)Doug Matson (W. Valley, SpBrian Aiken (Fife)John Molohon (ESD 113)Mike Merlino (Evergreen Cl


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Christie Perkins (Coalition)Michelle Corker-Curry (Seattle)

Mike Merlino (Evergreen, ClNeil Sullivan (Spokane)

OSPI StaffJennifer Priddy, Doug Gill, Calvin Brodie, Mary Ellen Parrish, John Bresko, MSabin, Kim Thompson

Mandate of CommitteeThe following operating budget language governs the mandate of committeeand recommend a Special Education Excess Cost Accounting method:“…conduct further evaluation of issues raised in the recently completed joint leg isla

and review committee report on the accounting of special education excess costs. amounts provided in the subsection, the office of the superintendent of public instruconvene a work group to evaluate modifying or replacing the current 1077 methodowork group will deliver a report to the appropriate committees of the legislature, inc

joint legislative audit and review committee, and the office of financial managemen1, 2007. The work group will take into consideration recommendations of the Washlearns steering committee.”

As background, the related JLARC recommendations follow:

JLARC Report Recommendation # 2The Superintendent of Public Instruction, with the assistance of istakeholders, should examine whether the current excess cost methodolobe improved through various modifications to the 1077 Special EducationCost Worksheet.

JLARC Report Recommendation # 3The Office of Superintendent of Public Instruction should provide clear guidainstruction, and periodic training on how to accurately and appropriately:

A. Complete the 1077 Least Restrictive Environment child counts throug


JLARC Report Recommendation # 4The Office of Superintendent of Public Instruction should require school distreport the full costs of serving their special education students (i.e., both baseducation and special education programs separately).

Committee ProcessThe committee met four times during November through January, reviewing


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The committee met four times during November through January, reviewing

JLARC report,

Washington Learns K-12 Advisory Committee recommendations,

Background information on the current 1077 process, and Strengths and weaknesses of the current 1077 method.

Further, the committee discussed new methods, the exact calculations of sumethods, and the advantages and pitfalls of such methods.

In mid-December the committee reached consensus on a proposed new excaccounting method. This method and related background detail is described

Superintendent Bergeson accepted the committee’s recommendation in full.

Standards for an Improved MethodThe committee identified several standards and requirements by which to evrecommended method:

Transparency and Ease of Understanding

Accuracy

Equitable and Fair

Incentive Neutral

In addition, the committee put a very high premium on an accounting methoreinforce the current state priority to treat every student as a basic educationfirst. To this end, the committee focused on developing a method that easilythe amount of basic education revenue that was being expended on student

designed education or instruction.

COMMITTEE RECOMMENDED STATE SPECIAL EDUCATION EXCESS CACCOUNTING METHOD


shifting the majority of the cost accounting function from the local school diststate apportionment office.

The proposed accounting method will:a) Shift a portion of basic education revenue to the special education pr

based on students’ full-time equivalency (FTE) in the special educatioand

b) Require all costs for the special education program (e.g., the full cost


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) q p p g ( g ,education teachers and program) be captured within a single programsplitting program costs between basic and special education.

The basic education revenue shifted to the special education program, revenintended to establish a minimum amount of spending of state program 21 beschool district accesses the excess revenues, revenue 4121, generated by tcost formula (.9309 of general apportionment revenue).

The method is referred to as the Washington State Excess Cost Accoun t(WSECM) .

Specifically:1. Districts would continue to use the 10771 to generate student FTEs s

special education setting. The number will be specific/unique for eacdistrict. (Currently of the approximate113,000 school-age students elispecially designed instruction and generating general apportionment ~70% of full-time equivalent students are served in the regular educa~30% of FTE students are served in the special education setting.)

2. Based on the split of FTE described above, OSPI would split generalapportionment funds associated with these students eligible for speciinto three categories:

a. General apportionment for the regular education classroom (caccount code 3100);

b. General apportionment for the special education setting (new acode 3121);

c. Indirect support for utilities, administration, district-wide service

3. Districts will code their staff and appropriate expenses related to provspecially designed instruction to the special education program.

4. Districts will first expend the general apportionment funding associate


Proposed Method measured against Standards for Improved Method

Transparency and Ease ofUnderstanding

WSECM is easier to understand because Odisplay and account for all revenues that dallocated in general apportionment and speeducation.

Because districts will not split code staff, efor special education are contained in one and easily identifiable on current OSPI rep


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y p

Accuracy Revenue splits are calculated by OSPI for district using current apportionment formula

reported student data.Equitable and Fair All students in specially designed services

included in revenue calculations (tables 1-8the extent they generate general apportionfunding.

WSECM is responsive to districts’ unique mstudents and continuum of service delivery

WSECM is consistently applied for all distr

OSPI. Special education students, as a class, rec

share of general apportionment revenues iexcess cost revenues. Districts will first exgeneral apportionment funding attributed tocode 3121.

Incentive Neutral Method reflects, but does not inf luence, a d

LRE decisions. No additional revenue is generated by a di

upon students’ placement on the 1077.

Revenue split between programs is based year 1077 tables, removing any incentive rstudent placement in the special education

Use of the prior year’s 1077 data presents and consistent basic for district to use in bu

and accounting for the school year.Other WSECM is consistent with the federal exce

threshold requirements that will govern howdi i d i l b f


JLARC Recommendations and Findings: Committee Response

JLARC Committee Re

Recommendation 1: The Legislature should decidewhether the current or alternative approach should beused.

We recommend thlegislature adopt thWSECM.

Recommendation 2: If the current method is Agree: Improving t


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maintained, the OSPI should examine modifications toimprove the accuracy of the current 1077 worksheet.

g p gaccuracy remains the new WSECM.

Recommendation 3: If the current method ismaintained, the OSPI should provide clear guidanceand instruction on how to a) complete the 1077 LeastRestrictive Environment child counts; and b) assigncosts of contracted services and non-employee relatedcosts between basic education and special educationprograms.

Agree:

a) JLARC 1077recommendation isto WSECM also.

b) Under the WSEconcerns about sp

contracted servicesemployee related cno longer relevant.

Recommendation 4: The OSPI should require schooldistricts to report the full cost of serving their specialeducation students.

Agree; WSECM wisuch reporting.

JLARC Finding: Some districts have not implementedthe current excess cost accounting method.

Upon adoption, WSbe consistently calOSPI for each distdata already reportstate.

JLARC Finding: Some districts split code staffincorrectly.

WSECM provides fspecial education a

Accordingly spilt costaff is no longer a


JLARC Committee Re

JLARC Finding: Some districts make mistakes inidentifying and reporting Least Restrictive Environmentbecause:

a. IEPs do not clearly state where services areprovided.

b Number of minutes in a location is not defined

Training by OSPI awill address identifyreporting Least ReEnvironment.


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b. Number of minutes in a location is not definedon IEP.

c. Process for determining the number of minutes

on which to base table placement is unclear tosome districts.

Items a through c result in possible incentives anddisincentives for student placement.

JLARC Finding: Current method does not addressassignment of key costs:

a. NERCs.b. Contracts.

Upon adoption of tWSECM, these co

be included in full. about assignment contracted servicesemployee related cno longer relevant.

JLARC Finding: Total cost of serving special educationeligible students is not reported; total revenue is not

accounted for.

Upon adoption of tWSECM, OSPI wil

School District AccManual, and budgeexpenditure reportstotal cost of servingtotal revenue genespecial education-estudents.

Use of the 1077 Form in the Proposed MethodThe committee has carefully considered the findings and concerns that JLARexpressed about the 1077 form report However the committee concluded t


Additional Work Products Required by OSPI to Implement Method1. Revise apportionment reports for new revenue coding (1220 report a2. Define adjustments to the K-4 calculation to mitigate unintended con

of implementing a new method.3. Modify the carryover and expenditure rules related to special educat

cost revenues for the WSECM.4. Develop a training module to ensure districts appropriately place stu

1077 tables. Address including students in LRE tables 4-8 in the WSth d


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method.5. Review the School District Accounting Manual requirements for the s

education programs, consulting the OSPI School District Accounting Committee and the Special Education Advisory Committee.

6. Revise the current special education safety net process to accommoWSECM.

7. Reconvene its Excess Costs Accounting Ad Hoc Committee during s2007-08 and 2008-09 to review and evaluate school district implemethe WSECM and report to the legislature any potential changes or mto the method.


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seaac financial accountability position paper

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