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California State Auditor Report Number : 2015-112

Student Mental Health Services
Some Students’ Services Were Affected by a New State Law, and the State Needs to Analyze Student Outcomes and Track Service Costs

Response to the Audit




Response From the California Department of Education

December 15, 2015

Elaine M. Howle, State Auditor
California State Auditor
555 Capitol Mall, Suite 300
Sacramento, CA 95814

Subject: Report No. 2015-112 - California School District Mental Health Funds and Services

The California Department of Education (Education) appreciates the opportunity to provide written comments and proposed corrective actions to the recommendations outlined in the California State Auditor’s (CSA) Audit Report No. 2015-112 regarding California School District Mental Health Funds and Services.

Chapter 1 - Recommendation No. 1:

Recommendation:

The Legislature should amend state law to require Education to report annually, beginning March 2017, regarding the outcomes for students receiving mental health services in the six key areas we identified. The report to the Legislature should include outcome data for the most recently completed school year and should compare the outcomes for students receiving mental health services with the outcomes for other special education students. Subsequent reports should also identify any trends in outcome data from one year to the next. Education should also provide comments in the report on the trends that it identifies and any actions it plans to take to improve the outcomes for students who receive mental health services.

Education’s Comments and Corrective Actions
1

This recommendation is to the Legislature; however, Education provides the following comments for consideration. Local Education Agencies (LEAs) submit data to Education as required by the federal Individuals with Disabilities Education Act (IDEA) and corresponding state law. Data reported by the LEAs is used to calculate Annual Performance Report (APR) measures on a statewide basis, which include the six key areas noted on page 34 of the report. In addition, Education generates indicator reports which allows each LEA to evaluate annual performance measures and determine if statewide targets for each measure were met.

2

Although LEAs report data to Education on all students in special education, including those students receiving mental health services as part of their Individualized Education Program (IEP), Education does not and is not required by state or federal law to calculate performance and/or outcome measures for any particular subgroup of special education students. Therefore, if the Legislature requires Education to compile the additional reports within the specified timeline, additional funding would be required to support the increase in staff resources necessary for disaggregating data to distinguish students in special education receiving mental health services, and analyzing that data for each of the identified six key areas.

3

Education also does not concur with this recommendation which specifies that the Legislature require Education to provide comments on any trends identified when compiling the requested data and stipulate actions Education would take to improve outcomes for students in special education who receive mental health services.

3

Commenting on any trends that are identified in comparing the requested data from year to year and proposing action to improve outcomes assumes that, from the aggregate data, Education would be able to accurately pinpoint underlying issues associated with a lack of progress toward the statewide target in the six key areas for these students. Although analyzing aggregate data to ascertain general trends in outcomes for students in special education who are also receiving mental health services may be a useful endeavor for informational purposes, the data does not provide the level of detail necessary for Education to extrapolate a root cause of poor performance on statewide targets. Therefore, Education’s conclusions on various trends and proposed actions for improvement would only be speculation because student outcomes can be affected by a vast array of variables, many related to individualized circumstances for each student, which are not represented by the aggregate data Education collects. Consequently, Education is concerned that implementing this recommendation could result in drawing erroneous, misleading conclusions that are not appropriately anchored in germane, indicative data.

Chapter 1 – Recommendation No. 2:

To ensure that all LEAs comply with federal special education requirements, Education should require them to include reasons for any changes to student placement or services directly in a student’s IEP document.

Education’s Comments and Corrective Actions
4

Education does not concur with this recommendation. Although the IDEA requires LEAs to provide “prior written notice,” or PWN, when proposing or refusing to initiate or change the identification, evaluation, or educational placement of the child or the provision of a free, appropriate public education to a child; required elements of the IEP do not include documenting the reason why an IEP service level or placement changed.

4

In addition, the IDEA mandates that states minimize the number of state rules, regulations, and policies to which LEAs are subjected, and report to LEAs and the USDOE on any state rules, regulations or policies that constitute “State-imposed requirements” not required by the IDEA. Furthermore, state mandates that exceed federal IDEA requirements may result in LEAs seeking reimbursement from the state.

Chapter 1 - Recommendation No. 3:

To enable it to review additional areas of its special education program for quality assurance, Education should collect information about the frequency of the provision of each service contained in all students’ IEPs. Education should then use this information to annually review the frequency of mental health services and follow up with SELPAs when it observes a significant reduction in the frequency of services.

Education’s Comments and Corrective Actions
5

Education does not concur with this recommendation. Education questions the value of collecting data on the frequency of provision of mental health services and analyzing aggregate results to identify LEAs for follow-up. Given that decisions on the type and frequency of services students receive are made by IEP teams for individual students, and that individual student populations and student needs change regularly, changes in type and frequency of services are to be expected.

5
6

Education does, however, concur with the auditor’s report that aggregated results “allow for limited conclusions of how students were affected by AB 114.” Similarly, aggregated frequency data, drawn from thousands of discrete IEP team decisions concerning individual students, provide little insight on the relative effectiveness of any LEA’s IEP development process or service delivery system.

2
7

Nevertheless, should the Legislature determine that Education’s collection of frequency data on mental health services would be of benefit to the state, Education would need additional resources to develop calculation methodologies, provide training and technical assistance to LEAs, and to review and validate data. In addition, it would be necessary for Education to develop procedures for LEAs regarding; (1) submittal of data reports; (2) completion of aggregation and analysis tasks necessary to review changes in frequency of services; and (3) identification of LEAs experiencing significant reductions in frequency of services.

Chapter 1 - Recommendation No. 4:

To ensure that LEAs comply with federal requirements, Education should require all LEAs to use the IEP document to communicate the rationale for residential treatment and any potential harmful effects of such placement.

Education’s Comments and Corrective Actions
8

Education does not concur with this recommendation due to concerns for exceeding federal requirements. Specifically, the IDEA contains a detailed description of the federally required elements of the IEP; these required elements do not include documenting the rationale for residential treatment.

OSEP commentary on the LRE regulations states that, consistent with the PWN requirement in 34 C.F.R. 300.503, parents must be "informed" of the placement options that were actually considered and the reasons why those options were rejected (71 Federal Register 46588 (August 14, 2006)). Under federal law an LEA can choose, but is not required to provide its PWN regarding any change of placement in the IEP document itself. Furthermore, as stated by OSEP, "There is nothing in the Act that requires a detailed explanation in children’s IEPs of why their educational needs or educational placements cannot be met in the location the parents request" (71 Federal Register 46588).

State law does require that the IEP document the rationale for placement in other than the pupil’s school and classroom in which the pupil would attend if the pupil were not disabled.

Chapter 1 - Recommendation No. 5:

Education should analyze and report to the Legislature, by May 30, 2016, on the outcomes for students receiving mental health services statewide, including outcomes across the six performance indicators we identified, in order to demonstrate whether those services are effective. Once it has reported this statewide information, Education should provide each LEA throughout the State a report regarding the outcomes for the students the LEA served.

Education’s Comments and Corrective Actions
9

Education does not concur with this recommendation. Education is concerned that statewide data on outcomes for students in special education receiving mental health services in the identified six performance indicators may erroneously measure the effectiveness of the mental health services received by those students.

9

Student performance on the six performance indicators identified by the CSA relies on numerous factors related to each individual student’s circumstances. This level of detail is not captured in the aggregate data received by Education. For example, if an LEA does not meet the statewide target for graduation rate for students in special education receiving mental health services, Education cannot conclude with any certainty that the deficient percentage is due to those students receiving ineffective mental health services.

9

Furthermore, the effectiveness or appropriateness of mental health services is only one of many factors that may impact whether or not a student graduates or otherwise progresses. Students in special education often receive an array of related services; it would be inappropriate to attribute such significance and causality to one particular group of services they receive based on aggregate statewide data and/or aggregate LEA level data. Although the aggregate data Education collects can be useful for identifying general trends in student outcomes and for prompting LEAs to examine their programs in certain areas, this data should not be used to determine the effectiveness of mental health services provided across the state.

Chapter 2 - Recommendation No. 1:

To ensure that the State knows the amount LEAs spend to provide mental health services for student IEPs, before the start of the 2017-18 fiscal year, Education should develop, and require all LEAs to follow, an accounting methodology to track and report expenditures related to special education mental health services.

Education’s Comments and Corrective Actions
10

Education does not concur with this recommendation. Education is concerned that, (1) establishing new codes to track mental health costs could result in Education losing other information that it currently collects; and (2) additional burden or costs that LEAs may incur to track expenditures to this level of specificity could outweigh the perceived benefits of having this information.

Chapter 2 - Recommendation No. 2:

To ensure that LEAs provide mental health services as required, Education should, on an annual basis, identify LEAs with accumulated balances of mental health funding and analyze whether the LEA has had a corresponding drop in mental health service levels. For all LEAs that Education determines have both an accumulated balance and a corresponding drop in services, Education should follow up with the LEA to determine whether the LEA is meeting its obligations to provide mental health services to students as part of the special education program.

Education’s Comments and Corrective Actions

Education concurs with this recommendation. Education will continue to develop and implement monitoring processes to identify LEAs with accumulated balances of mental health funding and to determine whether LEAs have incurred an annual decrease in mental health service levels.

Chapter 2 - Recommendation No. 3:

Education should require all LEAs and SELPAs that hold contracts for mental health service providers to annually obtain and retain copies of contractor personnel lists and the credentials or licenses for contractor personnel who provide mental health services to students in their respective LEA or SELPA.

Education’s Comments and Corrective Actions

Education concurs with this recommendation. Education’s certification process includes a review of staff background checks and personnel qualifications for staff employed by nonpublic schools and nonpublic agencies through current certification processes. Requiring LEAs to maintain their own records of contractor qualifications would provide assurance that contractors not holding nonpublic school or nonpublic agency certification are appropriately qualified to provide services for which they are contracted.

Chapter 2 - Recommendation No. 4:

To ensure that the State provides special education and related services to all eligible students, Education should investigate the difference between the estimated number of school aged children statewide who have a severe emotional disturbance and the number receiving mental health services through an IEP and determine the reason for such a discrepancy. Education should then take any steps necessary to assist LEAs in identifying and providing services to children who are severely emotionally disturbed.

Education’s Comments and Corrective Actions
11

Education does not concur with this recommendation. Based on the current required data, Education cannot determine what percentage of students receive mental health services overall from all sources in the community. It is not clear what percentage of students may have experienced a short-term emotional disturbance, perhaps resulting from a traumatic event, which may or may not qualify a student for special education services. Therefore, additional information would be needed such as the type, duration, and extent of cases involved in the estimated population.

11

For example, Education found no detail concerning the California HealthCare Foundation’s estimate that 7.6% of California children suffer from a severe emotional disturbance. Without such information it is difficult to determine what percentage of those children have a disability and, because of that disability, need special education and related services to enable them to receive a free, appropriate public education (FAPE). More information would be needed concerning the basis of the 7.6% estimate, including the type, duration, and extent of cases involved in the estimated population.

13
12

This 7.6% estimate is not substantiated by data from the Desert Mountain SELPA, which is one of the SELPAs widely considered as having the broadest base of mental health services. The Desert Mountain SELPA is the primary mental health service provider in its geographic area of San Bernardino County. It is the primary contractor for the San Bernardino Mental Health Plan in the Mojave Desert area. It serves all students eligible for mental health services, not just those with IEPs. In 2014-15, the Desert Mountain SELPA reported providing mental health services to 6,578 students. They also reported serving 116,713 students in general education. This generates a percentage of only 5.6 percent. But this is an over-generalized statistic. It is important to note that of the 6,578 students receiving mental health services, 1,728 were students with IEPs. Clearly, not all students requiring mental health services are considered eligible for special education and related services. Further, the Desert Mountain SELPA serves a total of 13,352 students with IEPs. In their experience, approximately 12.9 percent of students with IEPs receive mental health services. Applying that percentage to a statewide population of 717,961, results in an estimate of 92,918 students receiving IEP based mental health services. This is consistent with the 93,485 students with IEPs reported receiving mental health services statewide in December 2014.

14

Education currently takes steps to ensure that LEAs provide special education and related services to all eligible students. Education monitors LEAs for effective policies and procedures through comprehensive LEA monitoring processes. In instances in which Education finds local procedures lacking, Education requires corrective action and provides technical assistance. These measures are effective as the auditors reported that the LEAs reviewed are successfully fulfilling Child Find requirements.

If you have any questions regarding Education’s comments or corrective actions, please contact Chris Drouin, Interim Director, Special Education Division, by e-mail at cdrouin@cde.ca.gov, or by phone at 916-445-4602.

Sincerely,

Michelle Zumot Chief Deputy Superintendent of Public Instruction

MZ:kl




Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE CALIFORNIA DEPARTMENT OF EDUCATION

To provide clarity and perspective, we are commenting on the California Department of Education’s (Education) response to our audit. The numbers below correspond to the numbers we have placed in the margin of Education’s response.

1

The page numbers on Education’s redacted draft copy of the audit report do not correspond to the page numbers of the final audit report. The content Education refers to appears in Chapter 1 of this report, which can be found here.

2

We did not perform an analysis of the level of staff that Education might require to fulfill our recommendation. Although we briefed Education multiple times on the issues we identified during the audit, Education did not present us with any information demonstrating that its existing resources would be insufficient to implement this recommendation. Accordingly, we cannot verify the accuracy of Education’s claim that, to comply with our recommendation, it would need additional resources.

3

We disagree that Education would find itself limited to speculation when reporting to the Legislature about year-to-year trends in the outcome data for students receiving mental health services. If Education were to complete the analysis we describe in our recommendation, it would compare the outcomes for students who receive mental health services to outcomes for students who do not receive mental health services. This would allow Education to determine whether the students receiving mental health services are substantially different from the rest of the special education population with regard to outcomes. If this is not the case, Education could comment that this particular subgroup of students does not appear to be performing any better or worse than the rest of their special education peers. Conversely, if Education’s analysis showed that the students who receive mental health services were substantially different in their outcomes, Education could comment that the students were performing better or worse than their special education peers and, if worse, suggest the need for additional assistance and the type of assistance to be provided to the group of students with lower outcomes. This analysis could also enable Education to create a baseline for specific cohorts of students receiving mental health services and track their progress.

4

Local educational agencies (LEAs) are already required to document their reasons for changing special education and related services or a student’s educational placement. Our recommendation would result in additional direction from Education about the specific document that LEAs must use to record that information. We question whether further direction to LEAs about the specific document they must use to meet existing requirements would increase costs.

5

In Chapter 1 of our report, we present an example of the potential benefit that an analysis of aggregate service frequency data could provide in assisting Education to oversee how effectively LEAs provide mental health services. As we explain on that page, Education could use this aggregate data to compare the frequency with which LEAs offer specific services from one year to the next. If Education observed a significant reduction in the frequency with which a LEA offered a specific service, it could then follow up with the LEA to determine the reason why services are being offered less frequently to its student population. We believe that this analysis would be of value because it could assist Education in detecting whether LEAs are systematically reducing the frequency of their services, a potential indicator that the LEA is not providing access to a free and appropriate education to its students.

6

Education uses our report language out of context and mischaracterizes our conclusion with regard to aggregate data. For the reasons discussed in Chapter 1, our conclusion that aggregate data offered us the ability to reach limited conclusions was with respect to whether a change in state law had negatively affected individual students. This is separate and distinct from whether or not aggregate data could be useful to Education in improving its oversight activities.

7

We did not direct this recommendation to the Legislature. We believe that Education should implement this recommendation and that it can and should do so without waiting for direction from the Legislature.

8

It is not clear to us why Education is concerned about exceeding federal requirements. As we indicate in our report, state regulations already require IEP teams to document their rationale for an educational placement in a setting other than the setting that the student would otherwise attend if he or she did not have a disability. Further, as we note, federal regulations require that when selecting the least restrictive environment for a student, LEAs must consider the potential harmful effects of the placement. As both requirements already exist, we believe that further direction about where to record each of these elements would not be particularly burdensome. In fact, all four special education local plan areas that we reviewed as part of this audit agreed with similar recommendations we made to them and indicated that they would be implementing those recommendations.

9

The example that Education cites is a very narrow analysis, which it appears to use to argue that it would not be able to reach conclusions about the effectiveness of LEA mental health services. If Education were to complete an analysis similar to the analysis proposed in our legislative recommendation wherein it compared the students receiving mental health services to special education students not receiving those services, Education could then reach conclusions about the effectiveness of these services. Because the only factor that would separate these two student groups would be the fact that they did or did not receive mental health services, any meaningful difference in the performance of these two groups could be attributed to the effectiveness of mental health services. As we detail in our third comment, Education could track the progress of specific cohorts of students receiving mental health services by creating a baseline that would further enable it to conclude on the effectiveness of those services.

10

We acknowledge Education’s concerns in Chapter 2 of our report. However, as we state in that Chapter, we believe that despite the challenges Education might face in implementing this recommendation, it is critical that Education be able to provide this information to the Legislature and the public. By doing so, Education would benefit the Legislature and the public by being able to report on whether the State is cost effective in providing mental health services to students with IEPs. As we note in our report, this information would be valuable to future policy and funding discussions about the special education program.

11

Education is again interpreting our recommendation too narrowly. Whether or not students receive mental health services from other sources in their community is not relevant to whether or not the students should be receiving mental health services through an IEP. Further, although in Chapter 2 of our report we cite an estimate from the California HealthCare Foundation, this is not the only available estimate of the percentage of school aged children in California who struggle with mental health related problems. We shared this fact with Education during the period of time it was reviewing our draft report. Accordingly, when implementing our recommendation, we do not expect Education to limit itself to the estimate we cited in our audit report.

12

We are not aware of the methodology by which Education arrived at the amounts it presents throughout this paragraph, and therefore we cannot verify the accuracy of the assertions it provided or conclude whether this information is relevant to our recommendation. Nevertheless, we stand by our recommendation that Education investigate the difference between the estimated number of school aged children statewide who have a severe emotional disturbance and the number receiving mental health services through an IEP and determine the reason for such a discrepancy.

13

We state in of our report that not all students with disabilities will qualify for special education or related services, including mental health services. However, we also believe that this is an insufficient explanation on its own for why such a large gap exists between the estimated number of children with a severe emotional disturbance and those with mental health services listed in their IEP.

14

Education cites the results of our review of child find efforts at the four LEAs we reviewed as evidence that its oversight of child find efforts is effective statewide, which is misleading and does not reduce the importance of our recommendation that Education investigate the discrepancy between the number of children statewide with a severe emotional disturbance and the number receiving mental health services through an IEP.


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Response From Mt. Diablo Unified School District

December 15, 2015

Ms. Elaine M. Howle, CPA
State Auditor
Sacramento, CA

Dear Ms. Howle:

We are in receipt of the redacted copy of the report of the audit requested by the Joint Legislative Audit Committee concerning student mental health services. We appreciate the opportunity to engage in the dialogue regarding these important programs for our students.

Our team reviewed the findings and the recommendations in the report and as such we support the recommendations and will implement them as written.

Very truly yours,

Wendi Aghily, Ed.D.
Director, Special Education/SELP A 925-682-8000 x 4047
aghilyw@mdusd .org


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Response From Long Beach Unified School District

December 15, 2015

Elaine M. Howle, CPA
State Auditor
Bureau of State Audits
555 Capitol Mall, Suite 300
Sacramento, CA 95814

Re: 2015-112 - California School Districts—Mental Health Funds and Services

Dear Ms. Howle:

The Long Beach Unified School District (“District”) appreciates the opportunity to provide the following written response to the audit findings and recommendations before the audit report is issued publicly.

1

On behalf of the District, I would like to thank your staff for such a comprehensive review in terms of the impact and outcomes for students with disabilities after the enactment of Assembly Bill 114 (114). The District appreciates the auditor’s recognition of the important work the District has completed to improve special education programs while balancing resources for all students within the Long Beach community. The District looks forward to applying the recommendations outlined in the final audit report so that future students may benefit from improved and streamlined practices and procedures.

If you have any questions regarding the District’s comments or corrective actions, please feel free to contact me at (562) 997-8051.

Respectfully,

Chris M. Gutierrez-Lohrman, Ed.D.
Director, Special Education & SELPA
Long Beach Unified School District

Cc: Christopher Steinhauser, Superintendent of Schools
Tiffany Brown, Ed.D., Assistant Superintendent, Office of School Support Services




Comments

CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM LONG BEACH UNIFIED SCHOOL DISTRICT

To provide clarity and perspective, we are commenting on Long Beach Unified School District’s (Long Beach) response to our audit. The number below corresponds to the number we have placed in the margin of Long Beach’s response.

1

We reach no conclusions in our report regarding whether Long Beach improved its special education program in the years that followed Assembly Bill 114 taking effect, nor do we comment on Long Beach’s administration of the special education program in relation to its efforts to serve students outside of its special education program.


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Response From Riverside County Special Education Local Plan Area

December 15, 2015

Elaine M. Howle, CPA, California State Auditor
c/o Bob Harris, Team Leader, BobH@auditor.ca.gov

Re: 2015-112 - California School Districts—Mental Health Funds and Services

We want to thank your staff for being so collaborative throughout this mental health audit process. Below are our comments about the recommendations:

1

We recognize that the purpose and scope of the mental health audit was specific. However, we want to state our beliefs that we have improved the range, frequency, and location of mental health related services to students. More students are being effectively served under the AB 114 educational model than were served under AB 3632. Most importantly, staff and parents have increased their skills for supporting students with social, emotional and behavioral challenges in the least restrictive setting. We continue to work on our systems to be more proactive, data driven, linked across agencies, and student outcome focused.

Please thank your staff for working collaboratively with us. Please feel free to call or email if you have any additional questions or comments.

Sincerely,

Sue Balt, Ph.D., Executive Director, Riverside County SELPA




Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM RIVERSIDE COUNTY SPECIAL EDUCATION LOCAL PLAN AREA

To provide clarity and perspective, we are commenting on Riverside County Special Education Local Plan Area’s (Riverside) response to our audit. The numbers below correspond to the numbers we have placed in the margin of Riverside’s response.

1

In advance of providing Riverside with a draft copy of this audit report, we shared our recommendation that Riverside develop a process for ensuring individualized education program (IEP) teams record the reasons for changes to student services or educational placement. The first time Riverside mentioned this procedure to us was in its response letter. We look forward to hearing more about Riverside’s efforts to address our recommendation in its 60-day response to this audit.

2

During the time period that Riverside reviewed a draft copy of this audit report, it provided us a spreadsheet it stated it would use to track whether it collected license and credential information from all of its contractors. We mention this spreadsheet in our report. We look forward to hearing about Riverside’s progress in implementing our recommendation in its 60-day response to this audit.


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Response From Murrieta Valley Unified School District

December 15, 2015

Elaine M. Howle, CPA
California State Auditor

Re:       Response to DRAFT Mental Health Audit Report

Dear Ms. Howle:

Thank you for sharing a copy of the Draft Mental Health Audit Report.

MVUSD is pleased to find out that it meets requirements and implements best practices in the area of child find and identification processes, meets requirements in the areas of mental health staff qualifications and parent complaint options.

MVUSD agrees with the recommendation made by the state auditors in the area of monitoring special education student outcomes. Tracking outcomes for the subset of students receiving mental health services will offer valuable information and assist in evaluating the effectiveness of the district’s mental health programs.

In conclusion, MVUSD appreciates the collaborative nature of the mental health audit and has found this process to be a positive learning experience.

Sincerely,

Zhanna Preston, Ed.D.

Executive Director of Special Education


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Response From South East Consortium for Special Education

December 15, 2015

Elaine Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Dear Ms. Howle,

I am writing this letter in response to the recommendations listed on the redacted draft copies of the report provided by the California State Auditor to South East SELPA. The recommendations pertinent to the SELPA that are listed on the redacted draft report are as follows:

To better communicate this information to parents and future IEP teams, South East should develop a process to ensure IEP teams document, in student IEP documents, the reasons for any changes in services, including changes to mental health services, and student placement.

1
To ensure that they comply with federal requirements, South East should develop a process to ensure that IEP teams document, in student IEP documents, the rationale for residential treatment and any potential harmful effects of such placement.
1
To ensure that they can demonstrate that the contracted personnel who provide mental health services are qualified, East Side and South East should annually obtain and retain copies of contractor personnel lists and the credentials or licenses for personnel who provide mental health services in the LEA or SELPA.

If you have any questions regarding this response, please contact me at lmapagu@mpesd.org or at 408-223-3776.

Sincerely,

Leo Mapagu
Director
South East Consortium SELPA




Comments

CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM SOUTH EAST CONSORTIUM FOR SPECIAL EDUCATION

To provide clarity and perspective, we are commenting on South East Consortium for Special Education’s (South East) response to our audit. The number below corresponds to the number we have placed in the margin of South East’s response.

1

It is generally not our practice to include specific references to the law or regulation that underlie our recommendations. We believe that in this case the additional detail suggested by South East is not necessary for understanding the recommendations we made to the special education local plan areas we reviewed.



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Response From East Side Union High School District

December 15, 2015

Elaine M. Howle
State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

RE: East Side Union High School District's Response to Draft Report State Mental Health Audit

Dear Ms. Howle:

This letter will serve as the response of the East Side Union High School District (ESUHSD) to the draft report on Mental Health Services. We wish to acknowledge that the staff from your office has been through and respectful during this process, and we appreciate their diligent work in this process.

The East Side Union High School District is in agreement with, and agrees to implement, the two recommendations found in the Mental Health Audit Report:

  1. To better understand the effectiveness of the mental health services in their special education programs, East Side should use the six Education's performance indicators we identified to perform analysis annually on the subset of students receiving mental health services, (p. 7 of draft report)
  2. To ensure that they can demonstrate that the contracted personnel who provide mental health services are qualified, East Side and South East should annually obtain and retain copies of contractor personnel lists and the credentials or licenses for personnel who provide mental health services to students in the LEA or SELPA (pp. 15-16).

Please let me know if you have any questions.

Sincerely,

Barbara J. Moore, Ed.D., CCC-SLP
Director, Special Services, ESUHSD
mooreb@esuhsd.org
(408) 347-5171 - office

cc: Chris Funk, Superintendent
Glenn VanderZee, Assistant Superintendent, Instructional Services




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