•    The 'learning disability' profile has introduced statistical requirements which involve a systematic bias against young children or students whose assessed intellectual ability, although average, is at the lower end of that range. Meanwhile, students who are at the upper end of the spectrum of intellectual ability are also apt to be excluded from intensive funding. Even if a gifted/learning disabled student is working well below his or her potential, is experiencing related difficulties, and is able to meet the statistical requirements for funding as set down by the Ministry (a score on a test of academic achievement must be two standard deviations below the assessed intellectual potential), no application need be made if he /she is, in some ways, coping with the curriculum expectations for his or her appropriate age/grade placement.

•    If a child does meet the statistical requirements for an ISA learning disability application but is not experiencing the "related" difficulties (usually social/emotional or involving attentional issues) which are outlined in connection with the profile, the Board need not apply for intensive funding.
The current profiles involve requirements which exist apart from the issue of academic need and which often deny intensive funding for students who, although they may lack the most basic academic skills, are coping in other ways. Ironically, there are learning disabled students who have been approved for the Ministry of Education's residential programs such as Trillium, who do not meet the criteria for ISA funding.

•    The intellectual disability profile has statistical requirements which exclude students, regardless of whether the student can cope with daily functioning or not. Only those at the first percentile intellectually and adaptively are to be submitted. Youngsters with severe needs whose levels of intellectual functioning approximate the second percentile, are excluded. If a student does meet the statistical criteria for submission, he/she will often fail to meet the "related difficulties" components of the profile.

•    The names and diagnostic classifications of children cited by Boards of Education for the purpose of ISA funding, continue to be supplied to the Ministry. A "coded" system of identification would be more appropriate and would help to satisfy issues related to confidentiality.

•    The considerable demands involved in discharging regular duties have left some schools feeling that they are unable to afford the man-hours required to scrutinize each potential application and provide the minute attention to detail that is required. Schools and School Boards which are already stretched to their limits, can least afford to spend the time and yet, often have the most at stake.

•    Professional staff who face lengthy backlogs for their services are being co-opted from their usual duties to participate in a process which, according to the funding model, is essential to the survival of special programs. While profession staff are involved in this process, they are not readily available to address daily situations faced by high need students.

•    Special class teachers who are often oversubscribed because of a school's attempts to provide services to children who await formal assessment or who "fall through the cracks" (the requirements for children typically regarded as "slow learners" have been tightening), are required to do paperwork beyond the formidable paperwork requirements already in place for every "exceptional" child under their tutelage.

•    Before a Board can submit a claim for a child who demonstrates a serious need, it must first demonstrate that the child has already been receiving that level of support. Very specific requirements apply and very specific details must be documented. For example, if an application is to be submitted for an ISA level 2 grant, detailed proof must be provided that "specialized support personnel provide frequent support during the school day to address the identified needs".

•    If the child has been receiving support through another agency or through private arrangement, that fact cannot be used to justify the application. Although applications can be submitted on behalf of students who, it can be argued, have not already been receiving the needed level of support because of the Board's inability to fund the necessary resources, those applications are to be dealt with separately and to be treated as exceptions to the rule. The current shortage of qualified Special Education teachers makes this requirement difficult to fulfill.

•    Time allowances have, in many cases, been unrealistic and inflexible. School Boards have often been allowed insufficient time to develop the resources (i.e. computer programs) needed to facilitate the ISA process and ease the pressure on teachers to meet stringent requirements related to the development of Individual Educational Plans. ISA profiles were made available to school boards in August - too late to respond within required timelines without significant disruptions.