As a special education provider, you know how important it is to properly code your staff to the correct Position Title Code (PTC). If you incorrectly code your staff on your CFR, it could have a significant impact on your school, as well as the industry in total. While SED utilizes your CFR to reconcile your rate, they also use it to determine industry standards, such as median salaries by position title code and appropriate staffing patterns within your organization. An incorrectly coded staff member could result in a non-direct care screen, an understated median salary, or SED developing false staffing patterns (when these are finally created for 4410 providers).
While coding staff can be somewhat of an art, there are a few position title codes that we believe should be explored more deeply, as they have a higher likelihood of misclassification; the Curriculum Coordinator (PTC 237), the IEP Coordinator (PTC 238), and the Supervising Teacher (PTC 215 or 518). Appendix R of the CFR claiming manual defines these PTC as follows:
A certified administrator or certified Special Education teacher with five years teaching experience who is knowledgeable about the New York State Learning Standards and responsible for ensuring that the program’s curriculum is developed and aligned to such Standards. Monitors implementation of the curriculum, oversees curriculum training, and any curriculum adaptations. A curriculum coordinator is considered a direct position, because the focus of the curriculum coordinator is child or classroom focused. It is not their role to assess or supervise the teachers, or to sign off on teacher performance reviews, their role is to assist in curriculum development and implementation on a class by class basis to ensure the educational needs of each child are met.
A certified or licensed individual in one of the job titles below who is responsible for ensuring that IEP recommendations are implemented and that each service provider responsible for implementation of a student’s IEP is aware of his or her IEP responsibilities, including specific accommodations, program modifications, supports and/or services for the student, prior to implementation of such program. Serves as a liaison to the school district Committee on Special Education. Job Titles: Certified Special Education Teacher, School or Licensed Psychologist, Social Worker (Licensed or Master’s Level), or Certified Administrator. Similar to the Curriculum Coordinator, the IEP Coordinator must be a licensed individual and should be student centric, not teacher focused. An IEP Coordinator is responsible for ensuring that each student’s IEP mandates are met, which includes attending CPSE/CSE meetings.
Supervising Teacher (less than 50% classroom teacher – Code 518)
Provides for direct supervision of teachers. Certified administrator or supervisor of special education programs if serving more than 50 percent of his or her assignment in such capacity. Pursuant to Part 80 of the Regulations of the Commissioner of Education, a school administrator and supervisor serving greater than 25% (10 periods/week) of his or her assignment in any administrative or supervisory position must have valid administrative certification. For SEIT programs, all the time a teacher spends directly supervising SEIT teachers must be reported using this code. Certification requirements detailed above apply. As outlined, a supervising teacher’s responsibility is to oversee your program’s teachers. This includes in class observations, assessing teacher performance, signing off on evaluations and time records, etc. In reviewing your organizational chart, your teachers should report to your supervising teachers.
Supervising Teacher (more than 50% classroom teacher – Code 215)
Provides for direct supervision of teachers. Certified Special Education teacher serving as a teacher 50 percent or more of his or her assignment in such capacity. Pursuant to Part 80 of the Regulations of the Commissioner of Education, a school administrator and supervisor serving greater than 25% (10 periods/week) of his or her assignment in any administrative or supervisory position must have valid administrative certification. If supervising more than 50 percent of assignment, see Code 518. For SEIT programs, the time a teacher spends performing the duties of a SEIT teacher must be reported using code 218 and the time a teacher spends directly supervising SEIT teachers must be reported using code 518. This is a supervising teacher that spends more than 50% of their time in a classroom teaching, and less than 50% in a supervisory capacity. As outlined in the claiming manual, if a supervising teacher spends in excess of 25% of their time in a supervisory capacity, they must have a valid administrative certification.
In many programs, staff are responsible for wearing many hats. While the above titles may seem clear, things can get muddied because it is often difficult where one responsibility starts and another ends. The Reimbursable Cost Manual (RCM) does not allow staff to be split between direct and non-direct title codes, which further compounds the issue. The claiming manual does not allow for a supervisor to be charged to a 215 code, if more than 50% of their time is spent as a curriculum or IEP coordinator, it clearly limits direct services to a teacher position.
You should take the time to clearly document the job responsibilities of these staff, determine who they report to and who reports to them, do they perform staff reviews, do they do any teaching, etc. For many programs, this is not an easy assessment, but it is necessary in order to ensure you properly reflect your staff on your CFR.