What do the TISA rules mean for students with disabilities?

The Tennessee Department of Education has released a DRAFT of the rules for how TISA will be put into practice. The public can comment on the draft rules until August 2, 2022. This is your chance to help shape education funding!

The proposed TISA rules have three main areas of interest for students with disabilities and their families:

1. Weights for students with disabilities: TISA directs the Department of Education to define 10 categories of students with disabilities who have IEPs. Each category is given a different funding weight. The new rules call these categories “Unique Learning Needs,” or ULNs.
Why this is important: The Department of Education draft rules define these categories by how many hours a student with an IEP gets direct and indirect services per week. For example: the proposed rules define ULN 6 as a student who receives special education services for 9-14 hours per week. This would mean that student generates a weight of 75%, or an additional $5,145, for a total of $12,005 for the year. A possible concern is that schools could place students in more restrictive settings in order to get higher funding weights.
Other ideas:
Silver option: Use a review process to protect students from being placed in more restrictive environments in order to get higher weights.
The committee could look at trends in districts to make sure there aren’t sudden or unexplained changes in student special education settings.
The committee could also do random IEP audits to make sure that IEPs are best meeting student needs.
Advantages:
Students have some protections in place to make sure they can learn in the least restrictive environment. 
This method of assigning weights is simpler than other options. 
Gold option: Define weights based on the services laid out in an IEP.
Florida uses a “Matrix of Service” that organizes types of special education services into levels. 
IEP teams fill out the matrix based on services that are found in a student’s IEP.
This generates a weight based on intensity of the services that a student needs to succeed. 
Advantages: 
This model better targets funds to provide services for each student’s needs. 
Schools are more accountable to deliver the services that are in each IEP. 
There is less motive to “over-place” (put students in more restrictive settings) to generate higher weights.
Other concerns: Students with 504 plans are not weighted for any extra funding under the proposed rules. 

2. Outcomes Funding: The draft rules say that schools can get extra funding if high school seniors with disabilities achieve 3 of these 4 things:
Graduating with a general education diploma
Achieving certain scores on the standardized alternate assessment 
Spending more than 80% of the school day in the general education setting
Achieving certain post-secondary outcomes, like going to an inclusive college program or getting and keeping a job. For example: if a high school senior with an IEP gets a general education diploma, spent more than 80% of the day in general education classrooms, and is headed to Next Steps at Vanderbilt, they would generate more funding for their school
Why this is important: outcomes funding helps schools improve specific parts of their education program. Including an outcomes bonus for students with disabilities creates extra incentive to improve special education programs.  
A possible concern: the four chosen outcomes are difficult to achieve together in order to earn the funding – for example: a student who is on track to receive a general education diploma is not likely to be taking the standardized alternate assessment. 
A possible concern: the federal government suggests that only 1% of students take the alternate assessment. This limits the number of students who would be able to earn outcomes funding. 
Other ideas:
Silver: change the outcomes to include alternate academic diplomas and occupational diplomas 
This gives more students the opportunity to earn this outcomes funding
Gold: include an outcome incentive for younger special education students
Currently, only high school seniors have the chance to earn an outcomes bonus. This is not the same for students who are not in special education


Your perspective matters! 
The TN Department of Education wants to hear from the disability community about the new funding formula. Your perspective can help steer the rules that will decide how public schools are funded for many years to come. Email your feedback to Tisa.Rules@tn.gov by August 2, 2022. 

Still have questions? We’re here to help! Contact any of our organizations, The Arc Tennessee, Tennessee Council on Developmental Disabilities, Tennessee Disability Coalition.