Adi Talwar

Ayana Reefe, the Head Start Director and Early Learn Coordinator at Grand St. Settlement, said the IEP process could be frustrating for parents. 'It's already difficult for them; it's a sensitive topic, for them to even understand their child has a disability.'

Young students and committed teachers fill the classrooms and hallways of the Grand Street Settlement‘s preschool, located on the bottom floor of a building in NYCHA’s Baruch Houses complex on the Lower East Side. Schools like this are critical to Mayor Bill de Blasio’s endeavor to expand pre-K access to all New York City children. However, the staff at Grand St. has noticed a rise in a particular part of the pre-K student population.

“One thing for sure,” Gracianna Rosias, the organization’s disabilities coordinator, says, “is that we do have more families this year who are in temporary housing.”

As a part of the city’s universal pre-K push, the Department of Education mandates that all children four years old by the end of a calendar year are eligible for enrollment (Mayor de Blasio also announced a push to expand the mandate to the city’s three-year olds last April), and the DOE has also promised available pre-K seats for children living in homeless shelters, even if parents do not apply.

This push for universal pre-K seemed to benefit housed and homeless children alike. According to the Institute for Children, Poverty and Homelessness, pre-K enrollment among all students jumped by 25 percent between the 2011-12 school year and SY 2015-16. The jump in homeless pre-K student enrollment was even more pronounced, at 49 percent.

However, the number of homeless students in the city’s Preschool Special Education program dropped by 33 percent in that same time period, according to a February 2017 ICPH report, even as overall enrollment in preschool special education jumped by 13 percent. The disquieting trend illustrates the challenges the city faces as early childhood education enrollment continues to rise.

According to the ICPH analysis of SY 2015-16 data, only 35 of the more than 6,550 homeless students enrolled in pre-K were in special education – a share that falls well short of citywide averages. The 35 students classified as homeless are 0.11 percent of the 31,262 preschool students enrolled in special education.

In the 2016-17 school year, between 31 and 35 homeless preschool students in New York City were receiving special education services, from 17 in the Bronx to none in Staten Island, according to data from NYS Student Information Repository System (SIRS). The data was released by NYS-TEACHS, a project from Advocates for Children, an organization supporting NYC children and groups susceptible to discriminatory policies and actions.

“As the city increases Pre-K and 3-K, the question of why these special education numbers are so low needs to be part of the conversation,” Anna Shaw-Amoah, a policy analyst for ICPH, says.

Process creates hurdles for homeless families

At an October 11, 2017 City Council Education Committee oversight hearing on the DOE’s approach to homeless students, then-Committee Chair Daniel Dromm expressed surprise about the precipitously low rate of homeless preschool special ed students when questioning Advocates for Children Policy Director Randi Levine.

“I think that also the way to help children with special education needs, thinking particularly with speech needs, is that you address them as early on as possible so that you can correct them,” he said. “And if that’s not being done, or if that’s not being caught at Pre-K level, we’re losing a lot of time with these students, and I think by the second grade or third grade we may have already lost them in that sense, and we’ll still provide services, but it’s much more difficult, I think, to do it.”

Levine testified there were likely more homeless pre-K kids in special ed than just the 35 children identified in city data—and that the low number was partly due to the DOE misunderstanding the housing status of certain students. But in an interview with City Limits, she said that homeless students could inadvertently lose out on special education services when families confront a complex evaluation process for assessing the need for special ed coupled with the instability inherent to life in the shelter system.

“It’s easy for children to slip through the cracks and not get timely evaluation,” she says, citing the time-consuming process of getting an Individualized Education Program, or IEP, the legal document that stipulates the services a school must provide for a child in special education. “For preschool students in general, we do see backlogs and delays at the stage of evaluation and at the stage of IEP development. There are particular challenges for certain populations,” including homeless families.

What makes the pre-K special education numbers for homeless students suspect is that, generally, students living in shelters require special- education services at a higher rate than other students, according to a 2016 report on student homeless from the Independent Budget Office.

Homeless students in New York City (and throughout the country) are protected by the McKinney-Vento Homeless Assistance Act, which was passed in 1987 and reauthorized in 2015. It mandates that all educational benefits, including public preschool, are to be provided for homeless children. Part of the challenge in offering special ed for pre-K homeless students is because it can be difficult to determine the need for such services in the first place. Students are protected by the Individuals with Disabilities Education Act, which requires schools to provide a “free and appropriate public education” to any child with disabilities. U.S. Department of Education data available from 2014-15 indicated that 13 percent of all public school students were receiving some sort of special-education services.

Pre-K special-education services in New York are coordinated by one of 10 Committees on Preschool Special Education (CPSE), covering different locations throughout the five boroughs, and the services are defined in a student’s IEP.

To discern if services are needed (and if so, what kind) parents must send a “referral” to the CPSE requesting that they begin an IEP evaluation process. In response, the CPSE sends this parent a packet including a list of approved preschool special education evaluation agencies in NYC. The parent chooses an evaluation agency to test whether the student will benefit from services, and the CPSE must hold a meeting within 60 calendar days of the family’s first meeting with the evaluation agency. If the assembled group determines the student will benefit from an IEP, they will draft a plan detailing the students’ abilities and needs, long and short-term measurable goals, and a description of how parents will be notified of their child’s progress.

The process can stymie families in the most stable of situations, and many problems inherent to IEP acquisition can affect housed and homeless families alike. For example, the process can be delayed because of a shortage of bilingual translators. And the DOE’s preschool IEP process is especially challenging because it is spurred by the parents.

“There isn’t adequate support for families, particularly for families who lose their houses and have multiple demands, whereas when a child is in school, the school is responsible for the evaluation process,” Levine says. ‘There still may be challenges, but it is on the school, as opposed to when they’re in a preschool, where it’s parent-driven.”

Throughout the school system, homeless students suffer from late IEP evaluations; 54 percent of homeless students with IEPs received them after kindergarten in the 2015-16 school year, compared to 43 percent of housed students. A late IEP can also hinder educators’ efforts to address developmental delays in a child when it would be most impactful.

The screening process is not the only challenge. Schools often struggle with funding students’ IEPs in their entirety (many argue that the federal government underfunds the cost of properly realizing IDEA). A City Council report on K-12 service funding found that 73 percent of students fully received mandated services in SY 2017-18, with 23 percent partially receiving services and 4 percent not receiving any (though these numbers showed a marked improvement from the previous year, according to the report).

Funding problems aside, special education seems to offer clear benefits to homeless students with developmental delays. According to the ICPH, homeless students who received IEPs earlier were more likely to be successful in school. Those homeless students who did not have IEPs by the end of Kindergarten were twice as likely to be held back as homeless students who received IEPs by that time, and only 9 percentof those students scored proficient on 3rd-grade assessments, in comparison to 17 percent of homeless students who attained IEPs earlier, according to ICPH 2016 data. Students who received IEPs earlier also had lower suspension rates.

City efforts show promise, but work remains

Grand St. Settlement’s early childhood center at 294 Delancey serves 74 pre-K students from throughout the area, and includes a classroom specifically for three-year olds and an “integrated classroom,” enabling students receiving special ed services to learn in the same space as their general education peers.

Ayana Reefe, the center’s Head Start director, said the school runs its own internal screening of students within 45 days of enrollment to see if they might benefit from special ed services. If so, the school will do all it can to help parents craft DOE referrals, and try to assist them in choosing an evaluation agency; the whole endeavor can take up to six months. However, they are serving as support in a process that is designed to be instigated by preschool parents, who must take a more active role in advocating for special education evaluation and services than if their child was in a K-12 setting.

“We go to the meeting with each parent explaining what to expect. If at the meeting they are uncomfortable, they know their due process rights,” she says.

Adi Talwar

The difficult process of determining whether a preschool student could benefit from special education services is all the more challenging for families in temporary housing, according to Gracianna Rosias, a disabilities coordinator at Grand St. Settlement's Child and Family Center. Families face a dizzying and detailed journey and must be their own advocates, she said.

Grand St. touts high rates for getting homeless students early IEPs, if needed; of eight pre-K students with families in temporary housing at the Delancey St. location, three have IEPs (of the seven other homeless families at the organization’s other Manhattan locations, one family had been referred to the DOE, one was in process, and one student had an IEP).

Staff said the most common cause for student turnover was that homeless families had to move to a shelter elsewhere in the city. And that can wreak havoc on an IEP process.

“Shelter families tend to move, and turnover is a lot,” Reefe says. “They might come into your program in September, but due to the fact that the process is lengthy, they can start doing the paperwork then find out a couple of weeks later that they have to move.”

Rosias agrees: “For families who have children in temporary housing, we do remind them that if at any time there is a change, to let us know so we can address them to the appropriate district.”

Though schools, DOE staffers and others often try to assist families, without a stable address communication can be difficult to maintain. Reefe expressed frustration that DOE packets for referrals intended for families are often lost in the mail or sent to a PO Box of the shelter where a family was last purported to reside, and often do not make it into the families’ hands. Joanna Huang, a disabilities and mental-health coordinator, said they try to keep in touch with families who move to a new shelter in order to ensure the process continues unabated.

Levine suggested that the DOE offer families an additional mailing address, such as the preschool in which the student is enrolled, as a more stable option. The Department of Homeless Services has information on where families are situated, and the DOE’s Students in Temporary Housing office can access this data.

“The DOE needs to establish protocols for determining whether preschool-aged children referred for special-education evaluations are living in shelters,” she said. “For example, as one recommendation, when an evaluation for a preschool-aged child is not moving forward and the CPSE staff cannot reach the parent, the CPSE staff should contact the DOE’s Students in Temporary Housing office to determine if the child lives in a shelter and, if so, determine the best way to reach the family.”

A new PATH needed?

The damaged lines of communication with these families risk being further frayed during the initial steps through which families enter the shelter system.

Families attempting to apply for temporary housing do so at the Prevention Assistance and Temporary Housing (PATH) intake center, located a few blocks west of the Grand Concourse on 151st Street in the Bronx. The facility is open 24 hours a day for families needing immediate assistance, and all family members must attend an initial screening. According to the DHS, PATH accepted intakes from 18,000 “unique households” in FY 2016.

At the facility, families meet with a Human Resources Administration caseworker to see if there are any other options for housing besides a shelter, according to DHS information on PATH. Families are temporarily placed in a shelter as DHS determines their eligibility, a process which should not take longer than 10 days. (Some critics, including Councilman Stephen Levin in the October Education Committee hearing, said there were instances where the process could take from 30 to 40 days, though DHS Administrator Joslyn Carter assured Levin these cases were “outliers”.) The DHS did not respond to several requests for comment for this story.

Levine, who testified on behalf of Advocates for Children at the October hearing, said the DOE’s efforts to improve homeless pre-K student enrollment were laudable, citing interagency task forces assembled to increase cooperation among the DOE, DHS and Administration for Children’s Services. However, she said it was difficult for families in shelters to complete an IEP process if they might move one or several times among areas before they are settled. For that reason, some advocates want more detailed resources and information at the PATH center.

“We think that it’s important to have staff at PATH and at the shelters who understand preschool special education, who are able to screen students, and who are are able to talk to parents about when they are in the pre-K special education process, and help them address any barriers to getting those services,” she said.

ICPH policy analyst Anna Shaw-Amoah expressed hope that the DOE’s support for K-12 homeless special education students will filter down to younger students, as well.

“These are families and parents overloaded with challenges and needs, especially at the point of entering a homeless shelter,” she says. “I think what has been successful in the past is putting services where families are, and not requiring additional ‘come to this office’ or ‘come to this location.'”

The DOE operates an office at PATH Monday through Friday from 8 a.m. to 8 p.m., offering educational materials and information about transportation options and additional material for families to consider. DOE Deputy Chancellor of Operations Elisabeth Rose questioned whether PATH was the appropriate place to offer detailed information about students’ education options.

“For families that are losing their homes or entering the shelter system, the intake process of PATH can be a completely overwhelming and stressful process for adults and children. We do not believe that PATH is the ideal location for parents to absorb critical information about their child’s educational future,” she said at the October hearing. “At all shelters families have assigned case workers who are able to address educational needs of their children in a more comfortable setting.”

The Students in Temporary Housing unit, which is part of the DOE’s Office of Safety and Youth Development, employs 10 “content experts” throughout the city that work with schools in each borough, who oversee 117 “family assistants,” which are the primary point of contact for children and families within shelters throughout the city. Schools should follow-up with parents in temporary housing on the status of an IEP evaluation, according to the DOE’s Special Education Standard Operating Procedures Manual.

“If the student had been referred for a special education evaluation but the parent did not sign consent for the evaluation or services, the school should continue to seek consent if the case remains open,” the manual reads. “If the school has any difficulty connecting with a parent, the school should contact the STH Content Expert.”

However, the manual applies only to school-aged students, according to Levine, and the language about students in shelters was a recent addition. She could not recall any written DOE policies or procedures specifically concerning the preschool special ed process for homeless students. Additionally, the number of temporary housing sites, ranging from hotels to conventional shelters, far outnumber the DOE’s 117 family assistants.

“Furthermore…Family Assistants do not have the type of qualifications and training needed to provide the education advocacy that is often needed to overcome barriers,” she says. “That’s why we are recommending that the DOE begin placing social workers at shelters to assist with education rather than increase the number of Family Assistants.”

Preschools face hesitation from some parents

Sitting in her office at the Grand St. Settlement, Reefe said that the lengthy IEP process frustrates and discourages parents.

“It’s already difficult for them; it’s a sensitive topic, for them to even understand their child has a disability,” she says. “(Our staff) get the ball rolling, they do a great job getting these parents to say ‘yes,’ and then it takes six or seven months to get the process going. The parents say ‘you told me all this and there’s no services.'”

The DOE and other advocates hope that the number of homeless preschool students receiving special-education services will rise to match citywide averages as more students are exposed to Head Start programs and early childhood teachers.

Betty Baez Melo, a project director for the Early Childhood Education Project at Advocates for Children, said integrating preschool-aged homeless students into early childhood education, even if special ed services weren’t necessarily available, was a good first step, and the biggest vulnerability remained with children in the shelter system who did not attend preschool at all. According to the ICPH, of the 20,000 homeless three-and-four year olds in New York, more than 4,000 students who could benefit from special ed services were not being reached.

“If we’re talking about access to early childhood education, we want to make sure the most vulnerable children have access to it,” she says. “The students with disabilities and students in temporary housing are the ones who would benefit the most from it.”

However, she also acknowledged that attaining special education services may not be at the forefront of parents’ minds when their housing situation is so unstable.

“It’s a lot to take on; you’re interacting with a family when they’re vulnerable,” Melo says. “Staff must ask “‘Would you be interested in pursuing this as an interest?’ when it’s not their main concern.'”

The staff at Grand St. Settlement touted their collaborations with nearby shelters. Reefe said the partnerships help them bridge gaps with parents, many of whom were worried about disclosing information to new agencies for reasons ranging from documentation status to the anxiety inherent with navigating a family through New York’s shelter system.

“Establishing these relationships is one of the biggest things we can do, because once we explain to case workers what we do, they start calling us to tell us we have a parent who has a concern,” she says. “They’ve got to trust you.”

In a statement sent to City Limits shortly after this story was published, the Department of Homeless Services press secretary Isaac McGinn wrote: “DHS and DOE remain focused on addressing the unique needs of students in temporary housing, which is why we’ve worked together to expand dedicated staffing and programming, established a real-time data feed between the agencies to most effectively provide support to families on the verge of and experiencing homelessness, and released a plan earlier this year that puts people—and students—first by offering those families the opportunity to remain close to their communities and schools, as they get back on their feet. The central goal of the Mayor’s Turning the Tide plan is keeping families and children closer to support networks and schools. While we implement that plan and phaseout the use of all commercial hotel locations, we are working closely with DOE to preserve as much educational stability as possible for our families as they get back on their feet.”

Later on Wednesday, DOE press secretary Toya Holness wrote to City Limits: “We are committed to identifying and meeting the individual needs of all pre-K students with disabilities. Over the past year, we have expanded our support for families in temporary housing with children who may have special education needs — including training shelter staff on special education procedures, making guidance materials available to families at shelters, and using data from DHS to help us maintain contact with families throughout the special education process — to ensure that services are provided without delay.”

Adi Talwar

As the Family Services and Disabilities Junior Coordinator, Joanna Huang and the staff of Grand St. Settlement work with families to help determine if the preschool students under their care could benefit from special education services. The process of attaining an IEP is parent-driven for preschool-aged children; parents must begin the process by submitting their own referral to the DOE.