Vermont special-education leaders urge district-led, voluntary CSAs with guardrails to protect inclusion

House Education heard detailed testimony on Feb. 18 from two Vermont special-education leaders advocating for Cooperative Service Agencies (CSAs) that are voluntary, district-governed and designed to protect inclusion while expanding access to services.

Chris Benway, president of the Vermont Council of Special Education Administrators and director of special services for his district, said CSAs can address staffing shortages and improve services for students with low-incidence disabilities, but must operate with local control and clear guardrails. “CSIS cannot serve as the l as the decision makers for eligibility, placement, or IEP determinations,” Benway said, stressing that federal and state law leave those legal responsibilities with Local Education Agencies.

The witnesses argued that CSAs should be flexible and responsive to regional needs — for example, contracting for occupational or physical therapy, or board-certified behavior analysts where they are scarce — rather than offering a uniform menu of services statewide. Benway said success should be measured by stronger inclusion and improved services within local schools, not by creating separate placements.

Erin McGuire, director of equity and inclusion and co-director of student support services and instruction for the Essex Westford School District and past president of VCSEA, emphasized that building CSAs will take time and money. “We can't sort of quickly save money with them; there would need to be an investment upfront,” McGuire said, urging lawmakers to plan for staffing, hiring practices, policies and governance structures that could take a full year to set up.

McGuire and Benway both warned that while improving local availability of services is a goal, increased access can also increase identified need and short-term costs because students who previously lacked access may now receive recommended services. McGuire urged the legislature to consider a maintenance-of-effort (MOE) bill to ensure that whatever funding recommendations the Agency of Education makes do not interrupt LEA funding levels.

Committee members raised whether CSAs might unintentionally increase segregation by creating regional therapeutic programs that draw students out of their home schools. Witnesses responded that placement decisions are made by individual IEP teams under federal law, and that data on separate placements is an aggregate of individual team decisions. McGuire cited an Agency of Education report (section 29 of Act 73, as discussed in testimony) showing Vermont’s comparative placement patterns and said any policy design should avoid reversing the state’s inclusion gains: “We cannot increase segregation. We cannot go back on the inclusion work that Vermont has done.”

On governance, McGuire recommended a district-centered board made up of participating districts rather than a state-run model so that regional differences — travel time, office locations, rural vs. population-dense needs — can be accounted for in hiring, office placement and service design. Both witnesses suggested CSAs should be explicitly purchaser/provider arrangements: LEAs would buy services from CSAs, which should preserve LEA authority and staff structures.

Representatives asked about human-resources logistics and collective bargaining; witnesses said CSAs must preserve teacher retirement and benefits and cautioned that creating separate employer structures could complicate hiring. They described one staffing model in which districts pool fractional needs (for example, 10 hours, 5 hours and 20 hours) into full-time positions that are easier to recruit for than multiple 0.4 FTE roles.

The committee received no motions or votes on CSAs in this session. Witnesses recommended further hearings, presentations from existing regional CSAs for practical lessons, and legislative attention to funding guardrails, governance structures and the interaction with Act 73/173 implementation and special-education funding weights.

The committee thanked the witnesses and paused to reconvene for its next agenda item.