I. Introduction

A. Educational System Organization: This self-assessment will be somewhat different than that done by many of the departments because the educational system in Iowa is widely dispersed and intertwined with the system of providing services to persons with disabilities. The activities carried out by this system are the responsibility of a variety of different departments and agencies, are governed by a myriad of Federal and State laws and regulations and are funded by numerous appropriations and grant programs.

B. Overview of Educational System programs

1. State level – A significant amount of the state level responsibility for the educational system in Iowa rests with the Iowa Department of Education. Significantly, one of the major programs providing services to persons with disabilities, the Iowa Division of Vocational Rehabilitation Services, is one of the six divisions of the Department. However, the state universities, Iowa School for the Deaf, and the Iowa Sightsaving School at Vinton are governed by the Iowa Board of Regents. Vocational Rehabilitation services to persons who are blind are provided by the Iowa Department for the Blind, a separate department of state government.

Within the Department of Education are six divisions. Two of those divisions are only tangentially related to the public education system as we normally think of it. Those divisions are the State Library and Iowa Public Television. The other four divisions are: Division of Community Colleges and Workforce Preparation; Division of Financial and Information Services; Division of Early Childhood, Elementary and Secondary Education; and the Division of Vocational Rehabilitation Services.

2. Community level – Education and rehabilitation is done at the community/local. One of the difficulties is that the Department of Education has little direct authority over AEAs, LEAs, or community colleges. The Division of Vocational Rehabilitation Services, on the other hand is one statewide system, with offices in over 40 locations.

Local school boards must comply with state and federal laws, but in many things they are free to use or ignore suggestions from DE staff that do not relate to legal compliance issues. Likewise, they may or may not involve DVRS staff by referring students and inviting DVRS staff to IEP meetings. DVRS does have a counselor assigned to every public high school in Iowa.

Community colleges are governed by Boards of Directors and have much the same relationship to DE as the local school districts. DVRS has a counselor housed on campus at most of the community colleges. Only a few referrals come from community college staff, but many DVRS clients attend community colleges and need accommodations, which DVRS staff can advocate for with the colleges.

Other parts of the educational system have varying relationships with DE.

C. How the Education System services relate to the Olmstead Decision and community living for people with disabilities.

(NOTE: At this point I have dropped the difference between State level and Community level since it really does not fit the educational system where the State level has little or no control over the Community level services.)

With the exception of the Iowa School for the Deaf and the Iowa Sightsaving School, educational services are not provided in residential settings. However, if we think of the Olmstead broadly one has to ask if all educational programs involve individuals with disabilities and their advocates in planning and carrying out those programs to the fullest extent possible. One also needs to review whether those programs are designed to provide the highest level of educational services that the individuals can take advantage of, or is lack of individualization shortchanging some participants. One particular drawback is that often the different parts of the system do not see themselves as part of a system and design their programs without consideration of how what they do effects the individual when they interact with other parts of the educational system and other systems.

D. Description of existing Educational system services, programs or activities that already promote and support community living.

While the educational system is not perfect with regards to Olmstead, there are a lot of things that are done well. In some cases the practices do not quite meet the expectations of policies, but for the most part policies fully support Olmstead. Some examples of the good things that are being done by the educational system:

1. For a student who is deaf or blind, attending the residential school is a choice. Increasingly, mainstreaming those individuals in their local schools and having them continue to live with their families is the choice that is being made.

2. Accommodations are made for students with disabilities at all levels and in all parts of the educational system.

3. All decisions in the special education system are to be based on the services needed, not the cost or the difficulty of providing those services.

4. Schools no longer label special education students and services are provided in the regular classroom whenever possible.

5. The Department of Education has a medical consultant on staff to coordinate with the Department of Human Services in making the greatest use of Medicaid funds possible.

6. The Rehabilitation Act requires that clients be given informed choice with regards to the services they need and where they will receive those services.

7. The Division of Vocational Rehabilitation Services has assigned a VR counselor to serve the students in every high school in Iowa. These counselors often attend IEP staffings on their clients.

8. DVRS no longer runs a residential evaluation facility. All evaluations are done in community settings.

II. Self-Assessment Methodology and Barrier Identification

A. Identification and review by each Department/division of Olmstead-related policies, programs, statutes and regulations. For the most part policies, rules and regulations which govern support the provision of services in the spirit of Olmstead. Some may be silent on issues, such as the degree of student/parent involvement, where greater activity might be useful, but I have found none that directly forbad activities that would support Olmstead. Barriers identified:

1. The major barrier identified was the fact that the different parts of the educational system often do not see how their actions effect other systems, even other parts of the educational system. Some areas that demonstrate this and where thought and study should be done to fine solutions are:

a. Adult service providers often require forms of documentation related to disability before they will provide services or accommodations. They have been used to getting this material from school special education records, but with the “non-categorical” system, it is no longer available. This has an effect on VR, DHS, colleges, and others. A review of the system needs to determine who needs what Information, why they need it, how they use it, and whether something else could replace it. For example, in some states colleges will accept the certification of a VR Counselor that an individual needs accommodations, rather than requiring certain scores on certain tests.

b. Different parts of the system handle the same basic activities in different ways. For example, at the secondary level schools make the accommodations identified to be needed by the IEP team. At the post-secondary level it becomes the students responsibility to ask for the accommodations and provide evidence that they need them. If the student has not been taught self-advocacy skills they may fall between the cracks in the change of environments and end up failing.

2. A second barrier is that resource availability (time and dollars) drives many areas of practice. Lack of time may cause the school to forget to invite the VR Counselor to the IEP staffing and even if invited the VR counselor may not have the time to attend.

3. A third barrier is professionalism. This is the attitude that we are the professionals and know what should be done, so in an effort to efficiently utilize the limited resources available we make decisions instead of making the fullest efforts to involve the student and family (and other advocates).

4. The fourth barrier is the lack of understanding of the power of influence. If programs adopt the position that because they can not tell another program how to do something they can not effect change, a valuable tool for reform is lost.

B. Plan should include evaluation strategies at the department and division levels, and timelines to accomplish each activity.

(NOTE: Timelines are not included. Since we are talking about a system made up of pieces of various departments and organizations which have little or no authority over each other the timelines will need to be developed and agreed upon by groups which will be established to work on the solutions.)

1. Student/family measures of satisfaction that have been done will be assessed for possible guides to system improvement. If few or no satisfaction assessments have been done these may be designed and carried out as one of the first phases of this activity.

2. We will consult with other states with regard to how they carry out these programs, looking for good practices that could be implemented in Iowa that would improve compliance with Olmstead. 3. The different parts of the educational system will need to make a commitment to coordinating their efforts in the spirit of Olmstead.

III. Strategic Action Plan Development Process

A. Because the educational system is spread across so many different departments and levels of government it would appear that drawing people together to search for the exact problems and to develop solutions needs to come from the Governor. That group will need to look at all of the ways and places where their programs intersect and overlap in effects on individuals with disabilities. They would also need to study why they require services to be provided to persons with disabilities and determine if they could provide them in a way that was more in the spirit of Olmstead.

Individual programs that provide significant services directly to persons with disabilities, such as DVRS, could start a review of their service provision practices and the effects doing things in certain ways have on clients. For example, even thought getting applicants to fill out application forms prior to meeting with a counselor may save staff time, does it have unintended consequences that we do not recognize. Another thing that DVRS could look at would be the degree to which they involve other community players that also have contact with their clients and how the information they might be able to contribute would improve the VR outcomes.

B. Specify timelines for plan development process. Because of the need for the impetus in drawing the different parts of the system to come from the Governor it is not possible to specify a timeline. It is recommended that this be done as soon as possible. Individual programs should begin working on their internal process review immediately.