Equitable Access Framework Explained

In response to an apparent need, I offer this explanation of the Equitable Access Framework.

It begins with the differences among schools, services, programs, and curricular foci. The distinctions are based on the definitions provided in the Superintendent’s Procedure 2200SP. This document should have ended the confusion about what is a school, a service, a program, or a curricular focus. Unfortunately it did not - mostly because few people took the time to read and understand the procedure. That includes the people who purportedly wrote it. Some of the confusion lies in the legacy names for things or our habitual way of speaking about them. Some of the confusion lies in the historical trespasses on authority. Some of the confusion is rooted in the large amount of overlap.

Schools are registered with the OSPI as schools. They are reported to the OSPI and appear on the OSPI web site as schools in this district. This objectively discernable criterion leaves little room for confusion about whether a school is a school or not. APP at Lincoln and K-5 STEM at Boren, for example, are schools, not programs. Interagency and Middle College are each one school though they both have multiple locations. The Cascade Parent Partner Program is a school, as is the Skills Center, despite the absence of “school” in their name.

Services are mandated by law to address the special academic needs of specific students. There are only three types of services: Special Education, Highly Capable, and ELL. Nearly all schools provide one or more of these services, though most of them do not have a specific program as a delivery model for the service. The majority of students receiving special education services, for example, receive them in a general education classroom. When the program is a delivery model for the service, such as APP for highly capable services or B.O.C. for ELL services, people become confused about the difference between the program and the service provided.

The distinguishing features of a program from the procedure are that the student must opt-in to the program or qualify for it and the student must enter the program through the student assignment process. There are two different kinds of programs. There are programs which are delivery models for services. These include APP, bilingual orientation centers, medically fragile programs, and other special education programs. There is only one program that falls outside that category: Spectrum. Spectrum is the only program that is not a delivery model for a service. It is, however, a program because it requires qualification and opt-in and it is accessed through the student assignment process. Though people sometimes speak of "the general education program" at a school, that is a misnomer. General education is not a program; students do not qualify for it or opt-in.

The superintendent’s procedure states “While schools offer a variety of approaches to instruction, using a particular teaching strategy does not create a program under this policy.” A distinctive approach to instruction constitutes a curricular focus instead. A curricular focus is an instructional approach offered at the local school level and not directly accessed through the district student assignment process. Option schools provide the clearest examples of curricular foci. Other examples include language immersion, International Education, STEM, Montessori, and Advanced Learning Opportunities. These are all instructional strategies like the distinctive qualities of option schools. Other curricular foci include International Baccalaureate and CTE courses, which are classes at a school which are accessed after enrollment.

There is definitely room for confusion between a program and a curricular focus when it comes to Montessori and language immersion at attendance area schools. They look like curricular foci because they are a teaching strategy, but they also look like programs because they require opt-in and they are accessed through the student assignment process. The superintendent has provided the needed additional clarity for language immersion by specifically listing it as an example of a curricular focus in the procedure. Montessori is analogous to language immersion.

These distinctions between school, service, program, and curricular focus may seem esoteric and trivial, but it is very important to know and be able to distinguish among these entities because each is under different authority. The Board has sole authority to create or close a school. The superintendent, under policy F21.00, has the sole authority to create, relocate, expand, contract, or close programs. The superintendent also has the sole authority to determine where services will be offered. School leadership teams have the sole authority to determine a school’s curricular focus, if any. It would be improper for the Board to dictate the site of a program or service, for the superintendent to dictate the creation or change of a curricular focus, or for school leadership teams to decide to create or close programs or services on their own.

Even after this explanation some areas of confusion may remain.

Is APP a program or a service? APP is a program which acts as the delivery model for highly capable services. APP is a program because it meets the definition of a program. Students must qualify for it, they must opt-in, and they enter it through the student assignment process. It is not synonymous with highly capable services because the District can and does provides highly capable services through other models as well. There are students receiving highly capable services in Spectrum programs, ALOs, and general education classes. In addition, there are twice exceptional students who are receiving special education services within an Accelerated Progress Program.

Is Spectrum a program or a service? Spectrum is a program. It meets the definition of a program because students must qualify, opt-in, and access it through student assignment. While there are highly capable students in Spectrum receiving highly capable services within that delivery model, most Spectrum students do not qualify for highly capable services as Seattle Public Schools has set the criteria. Also, Spectrum isn't an instructional strategy or teaching approach; it is, among other things, teaching to a different set of Standards.

Is ALO a program or a curricular focus? ALO is not a program because students don’t need to qualify for it and it isn’t accessed through the student assignment process. Also, schools have always been allowed to start or stop an ALO at their own discretion. Or at least that's the story that the District has consistently told.

Are Option Schools programs? No. Option schools are schools. Each option school has a distinctive curricular focus or instructional strategy, but, as the procedure states, “using a particular teaching strategy does not create a program under this policy.” Although students must opt-in to option schools and they access them through the student assignment process, they do that to gain access to the school, not to enter the specific instructional strategy used at the school, so the strategy is not a program. ORCA K-8 is a school with an arts-based curriculum. The school is not a program and the arts focus is not a program. All of the option schools are in control of their constantly evolving instructional program. The district does not dictate the instructional strategy to option schools. When the District creates new option schools they can and should support the teams planning the schools but should not dictate the school’s curricular focus.

Is language immersion a program or a curricular focus? Language immersion is a curricular focus. Just in case there was any doubt, the procedure specifically cites language immersion as an example of a curricular focus. That's because language immersion is an instructional strategy. This means that school leadership teams, not the superintendent or the Board, should decide which schools, if any, offer language immersion.

Are language immersion and International Education synonymous? No, they are not. There are a number of students at International Education schools, like Denny, Hamilton, and Chief Sealth, who are active participants in the schools’ International Education focus but receive all of their instruction in English.

What about CTE? CTE has also been specifically cited as a curricular focus in the procedure. Students do not enter CTE classes through the student assignment process. So it is up to schools to determine what CTE they will offer. Same goes for International Baccalaureate.

What about STEM or Montessori? STEM and Montessori is an instructional strategies and therefore not programs. They are each a curricular focus. This means that any school that wishes to become a STEM school or offer Montessori is free to do so on their own authority and that the superintendent cannot direct a school to either start or end either of these types of classes.

What is the impact of the different areas of authority? Once this policy and procedure are understood, they will clarify areas of authority for the Board, the superintendent, and school leadership teams. The Board will no longer determine the location of programs or curricular foci as they did recently with the Growth Boundary vote when the Board took back the authority to determine the site for middle school APP. The superintendent will regain that authority as well as the authority to dictate the size and composition of Spectrum programs. School leadership teams will no longer be allowed to exercise the authority over Spectrum programs which they have usurped, but they will be free to decide whether to offer ALOs for themselves. In addition, any school that chooses to do so may adopt a curricular focus or instructional strategy including choices like STEM, International Education, ALO, arts-based curricula, or blended learning.

How can we assure equitable access with so much under local control? The District promises only equitable access to programs and services, not equitable access to curricular foci. Stop. Read that sentence again. Programs, like APP, Spectrum, ELL, and special education programs, will be equitably accessible. Same for highly capable, special education, and ELL services. By restricting the promise to programs and services and by narrowly defining them, the District has drastically pared down its commitment to equity. The District is not promising equitable access to Montessori, STEM, language immersion or a certain type of option school instruction. There has never been equitable access to TOPS, ORCA, Montessori, or language immersion and the district does not promise it now. Nevertheless, district leadership can and will encourage and support schools to provide popular instructional offerings in areas where they are not currently accessible. The District does commit to offering equitable access to option schools, but not the style of instruction offered in them.

The distinctions between schools, services, programs, and curricular foci have been unclear for a long time. As a result, the proper areas of authority have been repeatedly violated. The Board has improperly dictated sites for programs, the superintendent has mandated the creation of a curricular focus at a school, and school leadership teams have decided to shrink or eliminate programs. The revised Policy 2200, the superintendent’s procedure 2200SP, and the Equitable Access Framework represent efforts to restore order to the system and clarify the areas of authority. Bringing order to this system and setting the boundaries of authority will not be a comfortable transition for everyone. Some will sharply miss the authority they have previously (improperly) exercised. The previously unmanaged, unaccountable, and opaque system sorely needed this reform.


A school is an OSPI-registered school defined by state statutes.”

Adams, Aki Kurose, Alki, APP at Lincoln, Arbor Heights, B.F. Day, Bailey Gatzert, Ballard, Beacon Hill, Birth to 3 Contracts, Broadview-Thomson, Bryant, Cascade Parent Partnership Program, Catharine Blaine, Center School, Chief Sealth International, Cleveland - STEM, Concord International School, Daniel Bagley, Dearborn Park, Denny International, Dunlap, Eckstein, Education Service Centers, Emerson, Experimental Education Unit, Franklin, Frantz Coe, Garfield, Gatewood, Graham Hill, Green Lake, Greenwood, Hamilton International School, Hawthorne, Head Start, Highland Park, Hutch School, Ingraham, Interagency Programs, Interagency Detention School, Jane Addams K-8, Jane Addams Middle School, John Hay, John Muir, John Rogers, John Stanford, K-5 Stem at Boren, Kimball, Lafayette, Laurelhurst, Lawton, Leschi, Lowell, Loyal Heights, Madison, Madrona, Maple, Martin Luther King Jr., McClure, McDonald , McGilvra, Mercer, Middle College, Montlake, Nathan Hale, North Beach, Northgate, Nova, Olympic Hills, Olympic View, Orca, Pathfinder, Pinehurst K-8, Private School Services, Queen Anne, Rainier Beach, Rainier View, Residential Consortium, Roosevelt, Roxhill, Sacajawea, Salmon Bay, Sand Point, Sanislo, Schmitz Park, Seattle World School, Skills Center, South Lake, South Shore  PK-8, Stevens, Thornton Creek, Thurgood Marshall, TOPS K-8 , View Ridge, Viewlands, Washington, Wedgwood, West Seattle Elementary, West Seattle High School, West Woodland, Whitman, Whittier, Wing Luke


A service is a supplementary support to basic education that is required .by federal, state, or local law and/or regulations.
Required services are Special Education, English Language Learners, and highly capable students, as defined by the state.”

Special Education Services, Highly Capable Services, Bilingual Education Services


A program may offer educational opportunities that are not mandated by federal, state, or local law or regulations. While schools offer a variety of approaches to instruction, using a particular teaching strategy does not create a program under this policy. Students access programs through an established assignment process consistent with the student assignment plan. Students must opt-in and/or qualify for the program.”

Hard of Hearing program, medically fragile programs, bilingual orientation centers, ELL programs, Accelerated Progress Program, Spectrum, SM4 classrooms, and disability-specific special education programs.

Curricular Foci:

A curricular focus is a teaching or an instructional approach offered at the local school level and not directly accessed through the district student assignment process.”

STEM, International Education, language immersion, Montessori, Advanced Learning Opportunity, distinctive option school approaches and instructional strategies, ,  various CTE programs (Maritime Science and Engineering, Academy of Finance, Project Lead the Way), International Baccalaureate


Anonymous said…
Thank you Charlie!!!! That is very helpful and useful information.

Anonymous said…
You are wrong about what constitutes a special education program. You don't get to "opt in", you are given no choice. Courts have only recently affirmed a student's right to reject special education. In that case, if you don't want your kid's program, you have 1 choice, forgo special education completely. Some deal.

Also, disability specific qualifications are illegal. Not to say SPS doesn't do have them. They crop up from time to time. Autism, etc, were all supposed to go away because of their tenuous legal standing. Then, several new administrators rolled in to town and they never heard of needs based programing. Before you knew anything, those disability specific programs appeared again. To stay legal, a disability specific program must not be limited to any particular disability.. nor must people with a particular disability be assigned a program based on their disability.

The reality is... the district has been saying for a long while: we don't have special education programs at all - they're all services. That is the actual language of IDEA - special education is a service not a place. I guess that's why they've taken to calling programs, "services". To comply with IDEA directly.

sped parent
Charlie Mas said…
Thank you, sped parent, for that information.

It does not surprise me in the least to learn that Seattle Public Schools is in violation of IDEA.

That said, there can be no question that the District forms programs to provide special education services to students grouped together by disability. We know, for an absolute fact, that there are deaf/hard of hearing "service models", medically fragile "service models" and transitional kindergarten "service models". They are listed in the District's matrix of linked schools for student services.

These "service models" are, unquestionably programs because students must qualify for them (they don't have to opt-in) and they are accessed through the student assignment process.

At middle and high school, students are also grouped into programs for service model 2, 3, and 4. These are also programs although they are not disability specific.
mirmac1 said…

sped parent knows her stuff. Our students do not "qualify", nor do they access their appropriate placement via the student assignment process. They are placed on the basis of their needs, as spelled out in their IEP.
Anonymous said…
Charlie, DH/H are anomalous "programs" within the special education world. This is because there are special laws specifically for hearing impaired students. Most notably, the guaranteed right for families to select the sign language they prefer to use. The district then must provide "service" in that selected language. The DH/H really isn't different than anything else though. The district should (and does) provide a service: an appropriate signing environment - and then make it available to anybody who needs it. In this case, the students who need it are hearing impaired - a diagnosis category. You could imagine - a child with a disability other than hearing impairment, living with hearing impaired parents. In that case, the student may well need DH/H services without being hearing impaired. In fact, the district has such children, and is a reality. The district also has students with multiple disabilities - and then it tries to shunt them off to the most restrictive thing, also illegal. The district can not create a barrier to programs, any programs, based on disability or even intelligence. That is prohibited by IDEA. The "qualification" for any program or service of another name the district has, is the need as determined by their IEP team which includes parents, nothing more. The team must conclude that a student would receive "some benefit" from a placement. That's it!

-sped parent
Anonymous said…
A few other misunderstandings. 1. As discussed, there is no "qualification" for a program or anything else, that students must demonstrate for placement, only benefit as determined by an IEP team which includes parents.
2. Enrollment handles special ed program placement. Wrong. It does not. The ever changing people working in the district's special ed central office, hand place all students in special ed "programs" (That is, those not handled by resource rooms.) Every year sped central staff does this hand placement. At every grade level. They like to say "enrollment handles" it. And yes families may have to submit paperwork to the "enrollment" office. The reality is that enrollment just sends it over to central office. In many/most cases, the sped central staff execute the activity as if it were the enrollment office, it simply can't be by the real enrollment because it must follow IEPs.

3. Difference between Program or Service... none really. IDEA requires SERVICE. So the district is changing the name. The real point behind SERVICE is the obligation that teachers teach what's on IEPs in the Least Restrictive Environmnet, no matter what "program" a student is in. That is, they must provide "service". A program - well, it doesn't carry that obligation. Which is why the district is trying to get rid of the word "program".

-sped parent
Lynn said…
APP actually is synonymous with highly capable services in this district. The annual Highly Capable Grant Application reports the number of students receiving highly capable services - the only students included who are not enrolled in APP are kindergarteners.
Charlie Mas said…
Lynn, I think you're going to see that reporting change to reflect students who are receiving highly capable services through delivery models other than APP.

I could be wrong, but we're seeing schools tht essentially make that promise right now.
Anonymous said…
DHH laws allow for selection of method of communication (ie sign language versus oral). It doesn't allow for parental selection of sign modality (ASL v SEE). Seattle won that case in federal court a few years ago.

carmaig said…
Great thread Charlie and replyers. So glad to have a better understanding of these distinctions
Charlie Mas said…
Regardless of the law (there's an expression we have to use a lot when we talk about SPS) the District creates Special Education programs. Whether the law precludes them from actually calling them "programs" or not, that's what they are.

When the District says that the services required by your child's IEP cannot be provided at your attendance area school, but that they are provided at Lowell, along with similar services for all of the other students in need of that type of service in the Washington and McClure service areas, that's a program. They can choose not to call it a program if that would make it illegal, but it's a program. That's exactly what a program is.

Changing the name of a thing doesn't change the thing.

This is a well-used trick by SPS. The Board wrote a policy to govern advisory committees, so the district stopped having advisory committees and started having task forces instead. Task forces are no different from advisory committees, but since they are not called advisory committees, they operate outside the rules of the policy.
Anonymous said…
There is a positive idea in the designating some things as "services". That is, you must provide the "services" a kid needs, as detailed on his/her IEP, regardless of whatever "program" the district has decided to put in place or not put in place. When staff are assigned to "programs" they often get the erroneous notion that they are exempt from providing certain services. Often, they think they don't have to provide "least restrictive environment" because they're a program. Or they think they don't have to provide academics at a needed level. Students are still entitled to have their needs met, in the least restrictive environment, with maximum access to non disabled peers. (Maximum access, not "as convenient for staff"). We families tend to like programs because there is staffing associated with programs. With services - well, we don't see people responsible for them. They are promises without teeth. That staffing, and those ratio's - are what people want to see. Services are what get delivered.

-sped parent
Charlie Mas said…
There we go. Programs are delivery models for services. They aren't the only delivery models for those services, but that's what they are about. As long as people remember that the purpose of the program is to deliver the service, then the program won't be seen as the goal or the solution in itself.
Anonymous said…
Thanks again Charlie for the post. This all has been driving me crazy especially when in a discussion about Advanced Learning.

In that same vein, can we PLEASE stop conflating APP and AHG identified kids? The Accelerated Progress Program is not the same thing as where AHG kids are served.

The Accelerate Progress Program (APP) is the program into which Academically Highly gifted (AHG) kids are guaranteed a spot. They can OPT OUT of APP by attending their neighborhood school or spectrum (which I keep hearing doesn't actually provide enough seats for all who qualify and is very different in each school, but that is another issue....)

APP is currently a SELFCONTAINED classroom delivery model where kids are grouped by grade AND are AHG identified.

However, next year there will be an "option APP" site in West Seattle that WILL NOT BE SELFCONTAINED classrooms. According to Ms. Heath, there will only be about 60 AHG kids that will possibly attend Fairmont park, so that means that there will not be enough kids for each grade.

AHG kids in this school WILL NOT be in self-contained classrooms.
Therefore, in my mind, Fairmont park will not be an APP site.

Yes, it's possible that AHG kids can be served by a "blended" model and a "walk to" model, but that simply isn't APP. APP is SELF CONTAINED classrooms.

Should Fairmont Park offer some sort of delivery model that AHG kids will opt into? Why not? But it isn't APP, and continuing to call it APP is problematic.

Why does this matter? Because this is the first step to all APP kids getting placed back into "blended classrooms" and provided "differentiation through walk to" services.

Some AHG kids are served through Spectrum or ALO’s, which is great. However, if the district starts calling "blended classrooms" and "walk to" APP, then it is a very short distance for APP at Lincoln and APP at TM to become the same.

It all sounds so nice to have an “APP” site in West Seattle, but that is not what is happening. It isn't APP if it's blended classrooms and "walk to".

dw said…

Thank you for picking up on this. I've been preaching about this exact problem for months now, ever since the Fairmont Park "program" was announced. Please continue to call attention to this issue, because it's going to take more than just a couple of us complaining to even get a serious response, let alone action.

Unfortunately, the road ahead looks challenging, because I believe the district (or at least the couple people in charge of these decisions) truly do want to dissolve APP into blended and differentiation service models. In essence, they want to destroy APP, though they will never admit it.

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