Maplewood Schools / Kids South Orange

Letter: Special Ed Parent Group ‘Disappointed’ by SOMSD New 504 Regulations

Updated August 20, 2017, 10;17 p.m.: Originally, the article incorrectly stated that the Board of Education had released the new 504 regulations. The regulations were released by Superintendent of Schools Dr. John Ramos.

After a very lengthy review and discussion process — that culminated last fall in new regulations for 504 plans for students in the South Orange – Maplewood School District, Superintendent of School Dr. John Ramos has finally released the new regulations. However, the special education parent group, which has closely monitored and assisted the process all along, is “disappointed” that they do not go far enough in addressing some of the issues that have plagued the 504 process for many years.

The South Orange-Maplewood Board of Education adopted the new Section 504 policy in September. At the July BOE meeting, parents and officials expressed frustration that policy regulations and procedures had not been finalized and communicated to ensure proper execution when the 2017-18 school years commences.

The Section 504 plan contains regulations to ensure that children with disabilities receive proper accommodations and access in elementary or secondary institutions.

“We have repeatedly been told that the regulations were being ‘finalized’ and would be provided to us shortly. Although the deadline for issuing the regulations expired more than seven months ago, we have yet to see any draft or proposal,” Erin Siders, President of the Special Education Parents Advisory Committee (SEPAC) said during the public comments section of the July monthly meeting.

Read more about that meeting in this Village Green article.

Recently, SEPAC sent a letter to the BOE expressing disappointment with the new regulations, which they say “fall far short” of being comprehensive.

See the full text of their letter below.

“Despite the extremely long time it took to create the regulations, implementation plans for significant portions of the Policy have not yet been created,” reads the letter. “It concerns us that we will be starting the new school year without documented procedures for adhering to much of the Policy. We also feel there is opportunity to make improvements to portions of the regulations that have been created in order to enhance their effectiveness. Time is of the essence.”

Mike Donoghue of SEPAC told Village Green that some individual Board members had acknowledged receipt of the letter and it was passed along to Interim Superintendent Thomas Ficarra. “As we expressed in the letter, we have asked that the policy be in the monthly Board agendas until it is fully implemented, so we hope to hear a public response [at Monday’s BOE meeting],” said Donoghue. SEPAC members will likely make a brief statement about the letter then, he said.

In response, district spokeswoman Suzanne Turner provided the following comment to The Village Green:

“We appreciate the thoughtful feedback from SEPAC.  Dr. Lauren Reisenauer, Executive Director of Special Services and Youth Development, met with several SEPAC representatives earlier this week to discuss their concerns and recommendations.  As with any process, we are always interested in feedback and are committed to continuous improvement.

Regulations are in place for the start of the 2017-2018 school year.  Among our new initiatives for 2017-2018 is the purchase of and transition to a new, federally approved Student Information System (“SIS”), which should help SOMSD ensure that we are addressing the unique needs of students.

Once we have implemented the new regulations and the new SIS is in place, we will assess our progress on implementing the 504 policy and identify any areas that need further refinement.  We will invite parents/guardians and SEPAC to provide feedback as part of that process.”

SOMSD will continue to work with SEPAC throughout the school year to address families’ concerns about 504s, IEPs, and any other issues affecting students with disabilities or special needs.”

BOE President Elizabeth Baker clarified that while the Board sets policy and monitors implementation, is does not issue nor implement regulations.
“While much of the policy was written so that additional regulations were not needed before it could be implemented, there were certain areas where the Superintendent was directed to issue certain implementing  regulations.  Outgoing Superintendent Dr. Ramos issued those regulations, without prior consultation with the Board…the Board did not issue the regulations.”
Baker said it was positive step that at least the preliminary regulations were issued, and the new software is very promising. “However the Board in its policy governance role will be monitoring implementation of the policy to ensure fidelity to both its letter and its spirit, and we appreciate SEPAC’s advocacy on behalf of students with disabilities and its commitment to working with the Board and administration to ensure the highest quality services and supports for students with disabilities.”

August 10, 2017

Dear Members of the Board,

We would like to again thank you for your work in adopting the 504 Policy last Fall and for passing the resolution to have the required regulations made public by July 28. As you know, District Administration made materials public on July 27 in accordance with your resolution, but approximately 8 months past the due date specified in the Policy.

While we heard Dr. Ramos state at the July Board meeting that the regulations are final and not open to comments or changes, SEPAC nonetheless views the provided documents as a starting point from which to create robust processes that are fully responsive to the Policy. All good regulation should be subject to continual monitoring and improvement, and it is in that spirit that we offer the recommendations set out in the tables below.

Overall, we are disappointed with what was provided. The materials mainly consist of various processing forms and a very brief overview and flowchart of the referral, evaluation and plan documentation processes. While that is all necessary and useful, it falls far short of being a fulsome set of regulations.

Despite the extremely long time it took to create the regulations, implementation plans for significant portions of the Policy have not yet been created. It concerns us that we will be starting the new school year without documented procedures for adhering to much of the Policy. We also feel there is opportunity to make improvements to portions of the regulations that have been created in order to enhance their effectiveness.

Time is of the essence. We were hopeful that the 2017-18 school year might begin with a fully implemented Policy, but it appears there is still much work to do. We urge you to make this a top priority for the Administration, and as we did in our last statement, we ask that you make this Policy a part of the agenda at each monthly Board meeting until the it is fully implemented.

Please do not hesitate to contact us if you would like to discuss our recommendations.

Sincerely,
Mike Donoghue & Mike Thompson

On Behalf of the SEPAC Executive Board Erin Siders, President
Reesa Salomon, Vice President

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