August 31st, 2021
Proposed State Rule on Paraeducators
The USBE staff is proposing yet another rule, this time related to paraeducators, that we believe is harmful to schools and school districts. This doesn’t relate specifically to special education but is a general rule limiting how schools can use paraeducators. We vigorously oppose this rule on several grounds.
1. IMPROPER STATE OVER-REACH: We believe the state office of education should cease trying to micromanage schools in Utah. Districts and Charter Schools are responsible for educating the children in their communities, and there are many accountability elements built into the system that ensure that schools are compliant with the laws. Rules that are written to further manage the schools should ONLY be written as a response to a law that requires the rule, or as a response to some pressing need or urgent and broad-scale problem seen in the schools. Passing rules that don’t fulfill those purposes is an example of regulatory overreach and abuse. If the USBE staff cannot point to a compelling reason to write new rules, they should not be supported in doing so. We hope that the state board of education (USBE) can send a strong message to their staff that extraneous rules written with the only purpose to micromanage schools are not acceptable in Utah. They can do this by opposing this rule.
2. NEED FOR PARAEDUCATORS IN UTAH SCHOOLS: Utah has some really tough challenges to deal with in education. Utah has been the lowest funded state in the nation for many years, and as the state with the highest ratio of children to adults (taxpayers), many Utah schools suffer from large classes, and teachers carry the burden of that. Our Utah teachers are amazing and do SO MUCH with so many challenges. At APA, one of the best things about our schools is that we decided early on that every elementary classroom would have a full-time paraeducator to assist the teacher. This takes our effective class size (student per adults) to half of what it is in many Utah elementary classrooms (15:1 as opposed to 30-35:1). Our teachers LOVE the model and our students thrive with so many caring adults to help meet their needs. These paraeducators are highly qualified and expertly trained to teach small reading and math groups using scripted programs, as well as help in the homeroom, which is a huge blessing to our students who benefit from being taught at their precise instructional level. Our model is innovative, effective, and powerful, resulting in maximum academic achievement for students. We have been successful in attracting very smart, capable people to be paraeducators at our schools. Utah has a great natural resource in our parents and other community members - many who have degrees in other fields but are excited to come and assist our teachers at the schools for very modest pay. Because we created the position to be a full-time job with benefits (most districts limit the paraeducator position to part-time), we are able to attract great people who sometimes stay with us for many years.
This particular rule focuses on the use of paraeducators in schools. The rule seeks to eliminate APA’s use of paraeducators in the ways we use them. When asked by a parent why she was pushing this rule forward, Leah Voorhies (Assoc. Supt.) replied that “Part of the impetus for the Rule update was an audit that demonstrated that paraprofessionals were providing services and support to students with disabilities without the required training and supervision of a licensed educator.”
Here she is referring to the audit of APA’s special education program where the auditors wrongly claimed that our paraeducators were not trained or supervised properly. This is abjectly false. We believe it is very likely that our paraeducators undergo more training than any paraeducators in any school or district and we would challenge the USBE to show us evidence otherwise. We provided the auditors with documented evidence of our paraeducators’ training, including 1:1 coaching forms for employees - 16 individual training sessions for one employee, 12 sessions for another employee - which the state threw out saying the training was “insufficient” with no other explanation. To be candid, on the day the auditors dismissed all our evidence, I knew for certain that APA was the victim of a state regulatory agency with an agenda. We will fight hard to continue to be able to provide the award-winning education we have provided for 18 years. We will always fight to “do what’s best for kids”.
In conclusion (and thank you for reading this far for those who have stuck with this!) we believe this rule’s goal is to eradicate APA’s small group learning in elementary school. Although we are weary of the attacks, frankly, I am not entirely disappointed this rule has been brought forward because it reveals the persistent, abusive attacks on APA in a whole new, very public way.
Additionally, I was very excited to see today that a group of parents (not an APA group) who are very concerned about this rule have published a petition asking our state leaders to vote against it at their meeting on Thursday.
Here is a link to the petition: https://www.change.org/p/
And here is the link to the rule if you would like to read it:
https://www.schools.utah.gov/
Thank you for the privilege of serving your family. We deeply appreciate your support.
Carolyn Sharette
Executive Director