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Monday, November 3, 2014

SPED C-CAP UPDATE from the temporary SPS superintendent

Special Education – We met today with OSPI and US Department of Education staff to review progress on the Corrective Action Plan.

Outcomes included:

1. Need to correct IEPs by November 14th in order to qualify for all the funding for which we are eligible.
2. Concerns about lack of interface between IEP online and PowerSchool causing too much handwork and errors.
3. Putting procedures and organization structures in place to ensure that staff/parents know where to get good information.
4. Stabilize leadership for Special Education and other departments.
5. Provide added supports to assist Wyeth and Michaela to put out fires, oversee the entire special education program and fix compliance issues.
6. Address communications by letting staff know of our corrective action compliance and addressing parent concerns.

As you see there's NOTHING of substance in the plan. Number 5 is code for HIRE MORE CENTRAL OFFICE STAFF. Number 6 WTF is Nyland trying to say?

Needless to say SPS has no chance of making the June 30th deadline with 15 citizen complaints and 19 due process hearings request pending the only thing SPS can do is conspire with OSPI to fraudulently become compliant.  Don't let them do this!

Tuesday, October 21, 2014

Office of Civil Rights on Bully Guidance

Bullying disproportionately impacts students with disabilities and must be addressed in every single case


Washington, DC – As part of National Bullying Prevention Awareness Month, the U.S. Education Department’s Office for Civil Rights (OCR) today issued guidance to schools reminding them that bullying is wrong and must not be tolerated – including against America’s 6.5 million students with disabilities. In response COPAA releases the following statement:

“The strong leadership and guidance of The Office of Civil Rights is timely and meaningful.  By acknowledging the disproportionate impact of bullying on students with disabilities the U.S. Department of Education is creating enhanced and heightened awareness as well as putting schools on notice that every vulnerable child – especially those with disabilities as qualifying under The Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act of 1973 (Section 504) – are to be protected by the adults responsible for them.  The Dear Colleague is quite clear in explaining to schools that no time should elapse, nor should a child’s safety and well-being be disregarded when an incident is suspected or may have occurred" said Denise Marshall, Executive Director.

The OCR Letter goes a long way in informing schools of their responsibilities under Section 504 and Title II of the Americans With Disabilities Act. OCR also articulated what the elements are for proving an administrative complaint for violation of Section 504's Free Appropriate Public Education (FAPE) requirements.  Selene Almazan, COPAA Legal Director, reminds COPAA members and colleagues: "While very useful tool for advocates and families, the standard for the Courts remains deliberate indifference and that remains a large hurdle.  That said, it is good to see the seriousness with which they are treating the issue and gratifying to see the standard for delivery of FAPE spelled out."  

Data and experience show that children with disabilities are too often the target of bullying and harassment – whether it be through overt physical behavior or verbal, emotional, or social behaviors – and schools, together with families must strive to ensure that every child feels safe and supported at school, on the bus, during recess/lunch and other extracurricular activities.  COPAA thanks the Department and Assistant Secretary Lhamon for sending an unequivocal message that schools must do everything possible to protect access to a FAPE for every student with a disability and ensure both suspected and known violations are investigated and dealt with in accordance to the law.

For more information and the guidance:  
Bullying of Students with Disabilities Addressed in Guidance to America’s Schools
  


Tuesday, October 14, 2014

It's been 69 days since Exectutive Special Education Director McWilliams was placed in a time out.

Really,  69 days on PAID leave! What is she doing with all the free time?

Is SPS thinking we will forget what McWilliams did and didn't do? Perhaps they are thinking she could just lie low for a few months then come back like nothing happened.

Here's a little chit chat going around between OSPI and SPS

From: Doug Gill
Sent: Tuesday, September 23, 2014 12:39 PM
To: 'Nyland, Larry L'; Randy Dorn
Cc: Tolley, Michael F; Jessee, Wyeth; Wright, Charles E; Rogers, Lesley A; kgoodsell@psesd.org; Scott Raub; Valerie Arnold
Subject: RE: Seattle Special Education Response

Dear Dr. Nyland,
Thank you for your email below accepting the conditions associated with the (1) designation of Seattle Public Schools (SPS) as a high risk grantee and (2) the withholding of $3,000,000 in federal IDEA Section 611 and 619 funding for the 2014-15 school year. I appreciate your pledge of full cooperation in this matter, and your commitment to improving special education services in Seattle.
As I indicated in my letter of September 18, our intent is to consolidate resources at the local, regional, state and national levels to assist SPS in improving district capacity to systematically provide appropriate programs and services on behalf of students eligible for special education services. I also indicated that there would be a three-tiered approach to consolidating these resources.
Step one involves monthly meetings with staff from OSPI, the PSESD and the external consultants selected by the district. I am attaching a schedule for these monthly meetings that will begin in October (see attachment).  Just as a reminder, a primary role of the external consultants is to establish benchmarks identified in the RC-CAP against which SPS progress will be measured during the school year.
As a second step, I am also instructing Scott Raub from our office to begin scheduling weekly meetings with your interim executive director of special education and whomever else you think appropriate, beginning in October as well. Mr. Raub will contact Mr. Jesse within the next few days to set up a regularly scheduled weekly on-site meeting in the district. The focus of these weekly on-site meetings will be on the overarching concerns addressed in the July TIERS report (communication, data utility, access, staff supports, etc.).
Step three involves quarterly meetings with staff from the United States Department of Education, together with our staff, PSESD staff and the external consultants, to verify that adequate progress is being made to justify periodical, incremental releases of the funding that is currently being withheld from the district during the 2014-15 school year. The dates of the quarterly visits by DOE are not yet established, but as soon as the dates are finalized, we will notify the district immediately. You should also take the opportunities within the RC-CAP to fully engage the district identified RC-CAP implementation team.
Once again, I sincerely appreciate your cooperation in this matter and am encouraged that the SPS school board has identified special education as a top priority for the 2014-15 school year. We look forward to resolving these issues in the most efficient and effective way possible so that the results that are achieved, are sustainable in the district on a long-term basis.

From: Nyland, Larry L [mailto:llnyland@seattleschools.org]
Sent: Monday, September 22, 2014 6:01 PM
To: Doug Gill; Randy Dorn
Cc: Tolley, Michael F; Jessee, Wyeth; Wright, Charles E; Rogers, Lesley A
Subject: Seattle Special Education Response

Sept. 22, 2014
Dear Dr. Gill,
Thank you for your detailed letter of September 18. We understand and share your concerns about the progress Seattle Public Schools needs to make for our students in special education. Please know that since I joined the district in June, I have been meeting with our team regularly and I am personally dedicating significant time to meeting the needs of each and every student receiving special education services.
The district accepts the conditions of the letter, and we look forward to working together on the additional oversight mechanisms, including weekly meetings with an on-site compliance officer. We are confident we will satisfy your requirements this school year.
Progress we have made
Earlier this month the Seattle School Board selected four governance priorities for the 2014-15 school year, and I am pleased that one of those priority goals is a focus on special education. We are working diligently on meeting the requirements of the Revised Comprehensive Corrective Action Plan (RCCAP). We have also worked hard to get classrooms ready for the 2014-15 school year, with materials and supplies ready to support instruction. While we have not yet been able to staff each special education classroom, we continue to make hiring those staff members a priority.
In addition, we are working on increasing the stability and capacity of the department. We have hired an additional program specialist in each region to support the special education staff at each school, and also improve our relationships with families. We are also in the process of hiring a special education ombudsman to help improve our engagement with and responsiveness to families. This is the first time in five years that we had a fully staffed central office leadership team for the special education department. Wyeth Jessee is currently serving as Interim Executive Director, stepping in to provide stable leadership while Zakiyyah McWilliams is on administrative leave.
Addressing your concerns
As I mentioned earlier, we acknowledge your concerns and we look forward to our continued partnership with OSPI to address these issues.
We will meet weekly with our on-site compliance officer and host monthly meetings with our third-party contractor, OSPI program review staff and identified staff from the Puget Sound ESD. In addition, we will host quarterly reviews for both OSPI and the U.S. Department of Education to review our progress on the RCCAP.
I am confident that we will meet the performance indicators set forth by OSPI and that the restriction indicated in your letter of $3 million will be released as we demonstrate adequate progress
Moving forward
We are completing the bidding process to hire our third-party consultant, and we look forward to their support and recommendations.
At your earliest convenience, we look forward to pulling together all parties to determine next steps and continued partnership on behalf of our students.
Sincerely,

Dr. Larry Nyland
Interim Superintendent
Seattle Public Schools
 

Monday, October 13, 2014

87 days out from the TIERS group meeting, 255 days to meet FAPE compliance.

It's now been 87 days since the July 22nd TIERS group's "Forgive and forget" meeting, so what's improved?

It's hard to gauge how well the district is doing on the revised C-CAP, because the district doesn't openly communicate its progress to families. To me SPS sees families as secondary in the process.

So, let look at some outside indicators.

In 2013 SPS had a total of 5 citizen complaints filed with OSPI  for IDEA related violations.
As of October 2014 SPS has a total of 13 citizen complaints filed against them for IDEA related violations.

In 2013 SPS had a total of 7 due process hearings filed for IDEA related issues.
As of October 2014 SPS has 18 due process hearings filed for IDEA related issues.


As of October 2014 SPS has a total of 5 US department of education civil rights violations investigations pending against them.

It appears based on the above numbers that things are possibly worst, but in no meaningful measurable way have improved.  I cant imagine SPS has a chance with only 259 days left.

Thursday, October 9, 2014

Dyslexic Henry Winkler comes to Seattle to promote his books.

Winkler is co-author of a series of popular children's books featuring a boy named Hank Zipzer: the World's Greatest Underachiever.
Standing with students, Winkler said, "I cannot believe that my name is on a book."
Fifth grader, Iris Dimpsey is a fan of Winkler's books. She said, "Well, the books are really cool because they are about dyslexic kids and I'm dyslexic."
And so are other students at Hamlin Robinson. It's the only school in the Puget Sound area designed for children with dyslexia, a condition that makes learning words difficult.

Read it carefully according to KING5 and me Hamlin Robinson is the ONLY school in the Puget Sound area designed for children with dyslexia! There are at least 2,000 students in SPS diagnosed with dyslexia and another 2-3 thousand undiagnosed. SPS does not serve dyslexic students SPS makes dyslexic students suffer through ineffective curriculum and teaching methods.

Maybe Mr. Winkler should pay a visit to SPS and ask why SPS doesn't use Hamlin Robinson's methods for teaching students with dyslexia.   


Wednesday, October 1, 2014

So who is Seneca Family of Agencies and what are they going to give SPED for $421,000?

SPS administration is asking the Seattle School Board at its Wednesday meeting to approve a contract for about $421,000 with a California-based consultant, Seneca Family of Agencies. This group is to replace the TIERS group after officials found issues and possible contract tampering by SPS administrators. More on that soon.

I guess it's time to start digging into Seneca Family of Agencies.

Here's something:

Public School Partnership Programs

Seneca partners with school districts and charter schools, most often located in urban areas to provide these culturally rich and diverse communities access to educational services that accelerate academic progress and develop the skills needed to successfully transition back into a public school setting. Seneca also partners with local school districts to provide Outpatient Services in the form of therapeutic classrooms and mental health services on public school campuses. Each student’s unique needs and goals are addressed through a personalized treatment plan that includes individual, group, and family therapy, supported by intensive case management and crisis intervention services. Program services are designed and tailored to enable each student to make the most of his/her education.

Wait until they get a load of SPS SPED OMG, I predict they will use up the $421,000 and run for the hills. 

Tuesday, September 30, 2014

OSPI withholds $3,000,000 of IDEA part B funding

Strong words from OSPI and withholding of $3,000,000.00 should get someones attention at SPS, maybe the school board should step in and make sure people are doing their jobs.




High risk determination. The United States Department of Education’s General
Administration Regulations in 34CFR 80.12 provide as Follows:
(a)    A grantee or subgrantee may be considered “high risk” if an awarding agency
Determines that a grantee or subgrantee:
(1)    Has a history of unsatisfactory performance, or
(2)    Is not financially stable, or
(3)    Has a management system which does not meet the management standards set
        Forth in this part, or
(4)    Has not conformed to terms and conditions of previous awards. Or
(5)    Is otherwise not responsible; and if the awarding agency determines that an
Award will be made, special conditions and/or restrictions shall correspond to the
high risk condition and shall be included in the award.
(b)   Special conditions or restrictions mat include:
(1)    Payment on a reimbursement basis;
(2)    Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given funding period.
(3)    Requiring additional, more detailed financial reports;
(4)    Additional project monitoring ;
(5)    Requiring the grantee or subgrantee to obtain technical or management
Assistance; or

(6)    Establishing additional prior approvals.
For the reasons described above, OSPI has concluded that SPS is a high risk grantee. In light of its Level 4 determination, its subsequent failure to demonstrate compliance with the  requirements of IDEA Part B as a result of the 2013-2014 implementation of the C-CAP by June 30, 2014, and its failure to have both the required third-party consultant and a non-interim director  of special education services in place to implement the revised C-CAP, SPS has shown that it has a history of unsatisfactory performance with respect to the delivery of special education services under IDEA. Moreover, the District’s non-compliance described in the Level 4 determination, and its failure to implement the initial C-CAP in a timely manner, verify that SPS has not conformed to the terms and conditions of previous Part B awards and the required actions associated with the awards. Finally, SPS’s June 17th, 2014 internal audit shows that the District’s management system does not meet the standards required under the Department of Education’s General Administrative Regulations, 34 CFR Part 80.  


Full letter below



SUPERINTENDENT OF PUBLIC INSTRUCTION


Randy I. Dorn       Old Capitol Building ·PO BOX 47200 ·Olympia, WA 98504-7200 ·http://www.k12.wa.us



September 18, 2014



Dr. Larry Nyland Interim Superintendent Seattle Public Schools
P.O. Box 34165, MS 32-150
Seattle, WA 98124-1165 Dear Dr. Nyland:
The purpose of this letter is to (1) declare the Seattle Public Schools (SPS) as a high risk grantee consistent with 34 CFR § 80.12, and (2) provide notice that the Office of Superintendent of Public Instruction (OSPI) will withhold a portion of the federal funding available under Part B, Sections 611 and 619 of the Individuals with Disabilities Education Act (IDEA) to SPS for the 2014-15 school year. These actions are being taken because SPS has a history of unsatisfactory performance with respect to the delivery of special education services under the IDEA, has not conformed to the terms and conditions of previous awards and required actions associated with such awards, has a management system which does not meet the management standards set forth in the United States Department of Education' s General Administrative Regulations, and  received a needs substantial intervention (Level 4) determination for the 2012-13 school year.

I.       BACKGROUND


a.  Data collection and monitoring.  OSPI's special education program review team annually monitors selected school districts' implementation of Part B of the IDEA pursuant  to WAC 392- l72A-07010.  Ifthe program review team identifies specific instances where a district has not complied with the requirements of IDEA Part B, OSPI will notify the district of the identified non-compliance  to be corrected within one year of notification  of the specific non-compliance. The district then must initiate a process of corrections, including, if necessary,  systemic corrections, to ensure that the non-compliance is corrected as soon as possible, but no longer than one year from the notification  of non-compliance.  WAC 392-l 72A-07010(3), 34 CFR § 300.600(e).   Following that, if the district does not timely address the identified non-compliance with corrective actions, OSPI is required to institute procedures to ensure compliance.  WAC 392-172A-07.010(4).

Under separate rules, WAC 392-172A-07012 and 34 CFR § 300.600(a), OSPI annually reviews the data it obtains from districts through required data collection and monitoring (and other information) and, based on that information, issues a determination regarding each school district's overall compliance with the requirements of Part B of the IDEA.  A "Level I" determination means that OSPI has determined a district meets the requirements of Part B. In




contrast, a "Level 4" determination means the district needs substantial intervention in implementing the requirements of IDEA. A district's determination level triggers certain ob]jgations. Among others, if OSPI determines that a district needs substantial intervention (Level 4), OSPI "will withhold, in whole or in part, any further payments to the district under Part B." WAC 392-l 72A-07012(4). See 34 CFR §§ 300.600(a)(3), .604(c).

Because determinations under WAC 392- l 72A-07012 are issued in November of an ongoing school year, OSPI expects that the district will come into compliance with IDEA Part B at the concJusion of the then-current IDEA Part B federal funding cycle.

b.   The C-CAP.  Following OSPI's on-slte monitoring of SPS in the 2011-12 and 2012-13 school years, OSPI identified several specific instances where the District was not complying with the requirements of IDEA Part B. OSPI concluded that the non-compliance was systemic in nature and, pursuant to WAC 392-172A-07010, ordered the District in spring of 2013 to develop and implement an approved comprehensive corrective action plan (C-CAP). In addition, OSPI required the District to contract with a nationally recognized third-party consultant to provide the technical assistance and resources necessary to implement the C-CAP activities identified by the District. As provided for under WAC 392-l 72A-07010(3), the District was required to demonstrate substantial compliance with IDEA Part B as a result of the implementation of the C­ CAP by June 30, 2014. The District did not challenge any of the conclusions or results of the program reviews in 2012 or 2013.

SPS did not retain the required third-party consultants until April of 2014,just two months before the C-CAP was to be fully implemented.   The District then requested that the initial C­
CAP be revised in July of 2014 in order to be successfully implemented.   Inan effort to accommodate the delayed start of the extensive C-CAP activities identified in 2013, provide SPS every opportunity to successfully utilize its consultants, and involve relevant stakeholders inthe process in a meaningful way, OSPI agreed to extend the implementation of the C-CAP until June 30, 2015.

Subsequent to this, OSPI was provided a copy of an internal audit report as an attachment to the third-party consultant's report issued on July 21, 2014.  The internal audit, dated June 17, 2014, identified several accounting, internal control, and source documentation concerns related to SPS's management  of special education funds. OSPI further learned from SPS district staff on August 7, 2014 that the third-party consultant contract awarding process utilized by the SPS may have been flawed, resulting in the placement of SPS's executive director of special education on administration leave pending an internal investigation, the appointment of an interim director of special education, the expiration of the previous consultants' contract, and a new solicitation for  a third-party consultant.                                                  ·    ·

c.  Level 4 determination.  On November 1, 2013, OSPI issued its Level 4 determination for SPS's 2012-13 school year. This, again, was an assessment of the District's overall compliance with IDEA Part B, using data and information provided by the District to OSPI. From this evidence, OSPI concluded that SPS had not corrected all identified issues of non-compliance




associated with the 2011-12 school year within one year of identification.  In a letter to Superintendent Jose Banda dated November  1, 2013, I indicated that, as a result of the Level 4 determination, "The district must demonstrate substantial compliance with the requirements of IDEA 2004 as a result of the 2013-14 implementation of the C-CAP by June 30, 2014.
Otherwise, any further payments of federal IDEA funding to the district will be jeopardized." The District never objected to or challenged this determination.

II.    HIGH RISK STATUS


a.      High risk determination. The United States Department of Education's General Administrative Regulations in 34 CPR § 80.12 provide as follows:

(a)  A grantee or subgrantee may be considered "high risk" if an awarding agency determines that a grantee or subgrantee:
(1)  Has a history of unsatisfactory performance, or
(2)   Is not financially stable, or
(3)  Has a management system which does not meet the management standards set forth in this part, or
(4)  Has not conformed to terms and conditions of previous awards, or
(5)   Is otherwise not responsible; and if the awarding agency determines that an award will be made, special conditions and/or restrictions shall correspond to the high risk condition and shall be included in the award.
(b)  Special conditions or restrictions may include:
(1)   Payment on a reimbursement basis;
(2)   Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given funding period;
(3)   Requiring additional, more detailed financial reports;
(4)   Additional project monitoring;
(5)   Requiring the grantee or subgrantee to obtain technical or management assistance; or
(6)   Establishing additional prior approvals.

For the reasons described above, OSPI has concluded that SPS is a high risk grantee. In light of its Level 4 determination, its subsequent failure to demonstrate compliance with the requirements of IDEA Part B as a result of the 2013-14 implementation of the C-CAP by June 30, 2014, and its failure to have both the required third-party consultant and a non-interim director of special education services in place to implement the revised C-CAP, SPS has shown that it has a history of unsatisfactory performance with respect to the delivery of special education services under the IDEA. Moreover, the District' s non-compliance described in the




Level 4 determination, and its failure to implement the initial C-CAP in a timely manner, verify that SPS has not conformed to the term$ and conditions of previous Part B awards and the required actions associated with the awards.  Finally, SPS's June 17, 2014 internal audit shows that the District's management system does not meet the management  standards required under the Department of Education' s General Administrative  Regulations, 34 CFR Part 80.

b.   Special conditions. The Department of Education General Administrative Regulations provide at 34 CFR § 80.12(c) that, if an awarding agency decides to impose conditions on a high risk grantee, the awarding official will notify the grantee or subgrantee as early as possible, in writing, of:

(1)   The nature of the special conditions/restrictions;
(2)   The reason(s) for imposing them;
(3)  The corrective actions which must be taken before they will be removed and the time allowed for completing the corrective actions and
(4)  The method of requesting reconsideration of the conditions/restrictions imposed.

The following oversight mechanisms, designed to assist the District in achieving substantial compliance with Part B of the IDEA and the revised C-CAP by June 30, 2015, are conditions to OSPI's award of the 2014-15 Part B grant:

•    Between October 2014 and May 2015, SPS will host weekly meetings with an on-site compliance officer designated by OSPI. These meetings wiJl be for the purpose of monitoring the District' s implementation of the revised C-CAP and to provide technical and management assistance.
•    Between October 2014 and May 2015, SPS will host monthly meetings with the District­ selected third-party contractor, OSPI program review staff, and identified staff from the Puget Sound Educational Service District (PSESD).  These meetings will be for the purpose of monitoring the District' s implementation  of the revised C-CAP and to provide technical and management assistance.
•    SPS will submit to on-site quarterly reviews requested by OSPI for staff from the U.S. Department of Education.

These conditions must be met before the special conditions will be removed.

c.  Reconsideration  of conditions.   Ifyou would  like OSPI to reconsider these special conditions to the District's 2014-15 Part B award, please send a letter to my attention by United States mail postmarked no later than thirty days after receiving this letter.  The letter should state with particularity any law or facts the District believes OSPI has overlooked in imposing the conditions.




Ill.WITHHOLDING OF PART B FUNDS


a.  Withholding of funds.  Because SPS received a Level 4 determination for the 2012-13 school year, OSPI is required under WAC 392-l72A-07012(4) to withhold payments to the District under IDEA Part B in whole or in part. Accordingly, OSPI will withhold an amount of the 2014-15 IDEA Part B grant to SPS equal to $3,000,000. This amount includes (1)
$1,659,759, the amount of IDEA funding SPS has reserved to implement to the revised C-CAP in the District' s most recent application for IDEA Part B funding in the iGrants form package 267, and (2) an ·additional $1,340,241, which is an amount intended to encourage SPS to meet the foregoing special conditions without creating substantial disruption to the provision of FAPE in the District.

Upon receipt of evidence of acceptable performance within the 2014-15 grant period, OSPI may incrementally restore a portion of the withheld amount of $3,000,000 during the 2014-15 school year.  Acceptable performance will be measured by adequate progress toward the specific activities and timelines associated with the revised C-CAP.  OSPI, PSESD, and the United States Department of Education will verify whether progress  is adequate.

b.   Opportunity for hearing regarding withholding. Under WAC 392-172-06065(2), the District has an opportunity for a hearing before a designee of the Superintendent of Public Instruction regarding OSPI's decision to partially withhold Part B funds. SPS must request the hearing no later than thirty days after receiving this notice of OSPI's action. Within thirty days following its receipt of a request, OSPI will hold a hearing to review whether OSPI's determination to withhold a portion of SPS's Part B funding is in error. At the hearing, the District will have the opportunity to provide the Superintendent's designee with documentary evidence SPS believes demonstrates that OSPI erred in reaching its determination that Part B funding should be withheld. The designee will consider any new evidence the District provides and respond in writing to the District within thirty days by affirming OSPI's initial determination, rescinding the determination, or issuing a revised determination. Ifthe District rem.ains unsatisfied with OSPI's determination, it will have the right to file an appeal of the determination with the Office of Administrative Hearings within thirty days ofreceiving OSPI's final determination .

Thank you very much for your efforts to improve special education services in Seattle Public Schools. I am hopeful that the actions being taken in this letter will enable the district to re­ establish itself as a lighthouse district in special education in Washington.

Sincerely,



,
Assistant Superintendent
Special Education




cc:        Gil Mendoza, Ed.D., Deputy Superintendent, K-12 Education, OSPI
Dr. Kelly Goodsell, Executive Director, Learning, Teaching & Family Support, Puget Sound Educational Service District  121                                                   ·
Mr. Michael K. Yudin, Acting Assistant Secretary for Special Education and Rehabilitative Services, United States Department of Education
Mr. Phillip A. Maestri, Director, Risk Management Services, Office of the Deputy Secretary, United States Department of Education
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