Evaluation of the Elementary & Secondary Education Program

Project Title: Evaluation of the Elementary and Secondary Education Program

2. Action Plan Matrix

The High-Cost Special Education Program

ISC provides funds through the High-Cost Special Education Program for students assessed with moderate to profound learning disabilities. The program funding is student specific and based on individual student requirements. It is used for direct service support in the form of personnel, adaptive materials and resource services. The objective is to improve the educational achievement levels of First Nation students on reserve by providing for access to special education programs and services that are culturally sensitive and meet the provincial standards in the locality of the First Nation. The desired outcomes are that an increased number of High-Cost Special Education students have acquired a high school diploma or a certificate of completion^{Footnote 8}, and that these students are provided with support services as identified through their Individual Education Plans.

Direct services include program activities such as classroom student intervention and counselling, focused directly on meeting student needs, and these direct services need to account for a minimum of 75 percent of allocated funds. Indirect services refer to an array of supportive programs and activities focused on enhancing special education programming at schools, such as providing information services and professional development opportunities, and need to account for a maximum of 25 percent of allocated funds. The eligible expenditures, including eligible costs for adaptive technology are detailed in the National Guidelines^{Footnote 9} for First Nations seeking support for high-cost special education services.

New Paths for Education

New Paths for Education was a proposal-based program that funded projects and activities designed to improve the quality of education in First Nation schools and to enhance the educational experiences of students, teachers, administrators, parents and communities. Its objectives were to strengthen First Nation education management and governance capacity; improve the effectiveness of classroom instruction through curriculum and language development, pedagogical improvements, and Information and Communications Technology; support parental and community engagement; and assist band-operated schools to recruit and retain qualified teachers and educators and provide them with professional development opportunities.

Eligible expenditures included learning materials, professional fees, salaries, transportation and administrative costs. As of 2019-20, this sub-program was discontinued.

First Nation Student Success Program

The First Nation Student Success Program supported activities that aimed to increase students' achievement levels in reading and writing (literacy), mathematics (numeracy) and encourage students to remain in school (student retention). The program specifically supported the development of school success plans, student learning assessments and performance measurement systems for schools to assess, report and take steps to accelerate progress made by students and schools. As of 2019-20, this sub-program has been discontinued.

Education Partnerships Program

The Education Partnerships Program is intended to promote collaboration between First Nations, provinces, ISC and other stakeholders. The partnership component supports the establishment and advancement of formal partnership arrangements that aim to develop practical working relationships between officials and educators in provincial systems and in regional First Nations organizations and schools. The structural readiness component supports activities that strengthen the organizational capacity of First Nation organizations to: deliver educational services to First Nation schools; cover start-up costs for First Nation school boards; develop agreements with provincial school boards to establish new approaches to tuition/service agreements or fully delegate the responsibility to administer on-reserve schools to a provincial school board.

This program is one component of education reform with the overall objective to advance First Nation student achievement in First Nation and provincial schools. It is expected to do this through support for partnership arrangements, where First Nation and provincial officials share expertise and services, and partners coordinate learning initiatives in support of First Nation students, which can also lead to informing ISC education policy evolution.

ISC provides funding for both the establishment and advancement of partnerships, as well as administration costs.

First Nation and Inuit Cultural Education Centres Program

The First Nation and Inuit Cultural Education Centres Program provides proposal-based funding to First Nation and Inuit Cultural Education Centres on reserves or within Inuit settlement regions to support the development and promotion of First Nations and Inuit cultural heritage. The objective is to support First Nation and Inuit communities in expressing, preserving, developing, revitalizing and promoting their culture, language and heritage, through the establishment and operation of First Nation and Inuit cultural education centres. It also ensures that culturally relevant programming and services are available to First Nation and Inuit students through cultural education centres. It will also contribute to an enhanced cultural environment and understanding within communities.

The desired outcomes are: revived traditional cultural skills among First Nation and Inuit people; developed contemporary cultural skills among First Nation and Inuit people; First Nation and Inuit peoples' knowledge and use of their traditional languages; and cross-cultural awareness in mainstream educational programs and institutions.

ISC directly funds First Nation and Inuit cultural education centres and the Inuit Tapiriit Kanatami. ISC also funds the First Nations Confederacy of Cultural Education Centres, which manages and administers funds for a majority of First Nation Cultural Education Centres. Eligible expenditures include salaries, materials, service fees, facility rental, administration and travel.

2.1 A Snapshot of First Nation Student Outcomes

According to the 2016 Canadian Census, the proportion of adults without a high school diploma or other post-secondary or trades certificate on reserve was 62 percent, compared to about 34 percent of the Indigenous population off reserve, and 18 percent for the rest of the Canadian population. The stated outcome of the Elementary and Secondary education sub-program is that students will progress in their elementary and secondary education, assessed by the percentage of tested students on reserve who meet or exceed a standard assessment for literacy and numeracy in the province of reference. In general, however, results show low levels of literacy (Figure 1) with modest but notable differences between male and female learners (with female learners generally performing better), and significant regional variability from approximately 48 percent in British Columbia to 26 percent in Manitoba. Similar figures are observed with numeracy.^{Footnote 10}

Such data before or after this period are not yet available to measure change over time using these indicators. And importantly, there is considerable variation between the 2015-16 and 2016-17 numbers with some anomalies, suggesting reliability issues in terms of what students are being captured in these figures. These data have been collected only since 2015 and do not differentiate between students attending school on or off reserve, nor do they differentiate between grade levels or ages.

Text alternative for Figure 1: 2016-17 Literacy Rates by Region (excluding Saskatchewan) and by Gender

Figure 1 is a bar chart comparing the 2016-17 literacy rates by region (excluding Saskatchewan) and by gender of indigenous learners. For the Atlantic region literacy rates are 63% for female learners and 55% for male learners. In British Columbia the literacy rates are 49% for female learners and 49% for male learners. In Ontario the literacy rates are 44% for female learners and 42% for male learners. In Quebec the literacy rates are 42% for female learners and 38% for male learners. In Alberta the literacy rates are 33% for female learners and 25% for male learners. In Manitoba the literacy rates are 31% for female learners and 20% for male learners. Data on Saskatchewan was not collected for this metric.

The department does, however, systematically track information on progression, exits and graduation. Of all the students eligible to graduate in any given year, Nominal Roll data show that success, as measured by advancement to the next grade, or graduation, fell slightly from 46 percent to 43 percent from 2010-11 to 2015-16. While ISC reports graduation rates as the proportion of students in their final year of studies who graduate, this does not account for the students that did not make it to their final year. Student outcomes are better articulated by cohort analysis^{Footnote 12} that captures progression and results over a period of time.

A cohort analysis of all students in the Nominal Roll registered in grade 9^{Footnote 13} in 2010 reveals low proportions of students graduating by the end of 2014-15 (within 5 years of entering grade 9), from about 15 percent in Manitoba to about 44 percent in British Columbia (Figure 2), and about 28 percent overall. Generally, there is a significant gender gap, with women typically graduating at a rate of about 10 percent higher than men, except in Alberta where the gap is smaller, and in Ontario where the gap is wider. Notably, these estimates could be inflated somewhat for any students who were marked as having completed studies in 2012-13 or 2013-14 due to coding issues, which were resolved as of 2014-15.

Importantly, however, the proportion graduating by 2015 was markedly higher for First Nation students attending school off reserve, with significant gaps between on- and off-reserve students observed in British Columbia, Alberta, Quebec, and especially in Ontario (see Figure 3).

As mentioned above, the frequencies of repeating grades and dropping out begin to spike in Grade 9 and 10, suggesting that this is a critical point for many students in terms of progression. There is no gender difference in this regard.

Text alternative for Figure 2: Graduation and Leaver Rates for Cohort Registered in Grade 9 in 2010

Figure 2 is a stacked bar chart examining the graduation and 'Leaver' rates for Indigenous student cohorts registered for Grade 9 in 2010, by province/region. The term 'Leaver' refers to a student not returning to school the following year who has not graduated and not changed schools. In British Columbia, the cohort that was registered for grade 9 in 2010, by 2015 44% had graduated and 7% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated. In the Atlantic Region, the cohort that was registered for grade 9 in 2010, by 2015 39% had graduated and 9% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated. In Alberta, the cohort that was registered for grade 9 in 2010, by 2015 (5 years from entering grade 9) 29% had graduated and 11% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated. In Quebec, the cohort that was registered for grade 9 in 2010, by 2015 25% had graduated and 8% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated. In Saskatchewan, the cohort that was registered for grade 9 in 2010, by 2015 24% had graduated and 17% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated. In Ontario, the cohort that was registered for grade 9 in 2010, by 2015 20% had graduated and 20% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated. In Manitoba, the cohort that was registered for grade 9 in 2010, by 2015 15% had graduated and 14% were still registered in 2015-2016 (5 years from entering grade 9) without having graduated.

Text alternative for Figure 3: Regional Graduation Rates by School Type for Cohort Registered in Grade 9 in 2010

Figure 3 is a bar chart that compares the regional graduation rates for indigenous students by school type for the cohort registered for grade 9 in 2010. In British Columbia the graduation rates for the cohort registered for grade 9 in 2010, was 30% for students attending on-reserve schools, and 52% for students attending off-reserve schools. In the Atlantic Region the graduation rates for the cohort registered for grade 9 in 2010, was 32% for students attending on-reserve schools, and 45% for students attending off-reserve schools. In Alberta the graduation rates for the cohort registered for grade 9 in 2010, was 20% for students attending on-reserve schools, and 44% for students attending off-reserve schools. In Ontario the graduation rates for the cohort registered for grade 9 in 2010, was 6% for students attending on-reserve schools, and 43% for students attending off-reserve schools. In Saskatchewan the graduation rates for the cohort registered for grade 9 in 2010, was 25% for students attending on-reserve schools, and 38% for students attending off-reserve schools. In Quebec the graduation rates for the cohort registered for grade 9 in 2010, was 13% for students attending on-reserve schools, and 32% for students attending off-reserve schools. In Manitoba the graduation rates for the cohort registered for grade 9 in 2010, was 14% for students attending on-reserve schools, and 25% for students attending off-reserve schools.

For grade progression, while First Nation students attending school on and off reserve seem to show similar trends in earlier years, this changes at grade 10, where First Nation students attending schools off reserve show a considerable drop in progressing to the next grade (either repeating a grade or dropping out), at about 68 percent, compared to 76 percent on reserve. A similar gap is seen in grade 11, with 76 percent of First Nation students attending school off reserve passing grade 11 compared to 86 percent on reserve (see Figure 4).

These results seem to suggest that while students attending school off reserve repeat grades at a higher frequency, they also graduate at a higher frequency. When examining student dropout data, trends mirror those of graduation rates, with First Nation students attending school on reserve dropping out at significantly higher rates than those attending off reserve (see Figure 5).

Text alternative for Figure 4: Grade Progression Rates between First Nation students attending school on versus off-reserve

Figure 4 compares the grade progression rates (advancing to the next grade) between first nations students attending school on-reserve and those attending school off-reserve. 93% of First Nations students attending school on-reserve progressed from grade 3, while for First Nations students attending school off-reserve it was 97%. 94% of First Nations students attending school on-reserve progressed from grade 4, while for First Nations students attending school off-reserve it was 97%. 95% of First Nations students attending school on-reserve progressed from grade 5, while for First Nations students attending school off-reserve it was 97%. 95% of First Nations students attending school on-reserve progressed from grade 6, while for First Nations students attending school off-reserve it was 98%. 95% of First Nations students attending school on-reserve progressed from grade 6, while for First Nations students attending school off-reserve it was 98%. 91% of First Nations students attending school on-reserve progressed from grade 7, while for First Nations students attending school off-reserve it was 95%. 91% of First Nations students attending school on-reserve progressed from grade 8, while for First Nations students attending school off-reserve it was 93%. 81% of First Nations students attending school on-reserve progressed from grade 9, while for First Nations students attending school off-reserve it was 79%. 76% of First Nations students attending school on-reserve progressed from grade 10, while for First Nations students attending school off-reserve it was 68%. 86% of First Nations students attending school on-reserve progressed from grade 11, while for First Nations students attending school off-reserve it was 76%.

Text alternative for Figure 5: Dropout Rates between First Nation students attending school on versus off-reserve

Figure 5 is a stacked bar graph which compares the drop-out rates of First Nations students by grade for those attending school on-reserve and those attending school off-reserve. For First Nations students in grade 3 the drop-out rate was 0.7% for those attending school on-reserve and 0.6% for those attending school off-reserve. For First Nations students in grade 4 the drop-out rate was 0.9% for those attending school on-reserve and 0.6% for those attending school off-reserve. For First Nations students in grade 5 the drop-out rate was 1% for those attending school on-reserve and 0.6% for those attending school off-reserve. For First Nations students in grade 6 the drop-out rate was 1% for those attending school on-reserve and 0.5% for those attending school off-reserve. For First Nations students in grade 7 the drop-out rate was 2% for those attending school on-reserve and 1% for those attending school off-reserve. For First Nations students in grade 8 the drop-out rate was 3% for those attending school on-reserve and 1% for those attending school off-reserve. For First Nations students in grade 9 the drop-out rate was 11% for those attending school on-reserve and 3% for those attending school off-reserve. For First Nations students in grade 10 the drop-out rate was 14% for those attending school on-reserve and 5% for those attending school off-reserve. For First Nations students in grade 11 the drop-out rate was 16% for those attending school on-reserve and 8% for those attending school off-reserve. For First Nations students in grade 12 the drop-out rate was 27% for those attending school on-reserve and 16% for those attending school off-reserve.

To understand these results in contexts beyond gender and region, a regression^{Footnote 15} analysis was undertaken to illustrate factors related to success. Beyond region, gender and school type, this also included measures from the 2011 census of the education level in the community (assessed by the proportion of adults with a high school education or higher); the economic strength of the community (assessed by the participation rate^{Footnote 16} and median household income); housing crowding^{Footnote 17}; and remoteness (using an index of remoteness developed by ISC that factors in several components of access to services and distance from services on a scale of 0 to 1, with greater numbers meaning greater remoteness) (see Table 1).

The analysis suggests that all of these factors are associated with education success as measured in this cohort analysis, but not universally, and there is significant regional variation (see Table 1). For students in Quebec attending school on reserve, for example, their success appears deeply related to the education level in the community, the economy, the extent of crowding in homes and community remoteness. For the students attending off reserve schools, these relationships are less pronounced, but crowding and remoteness have major impacts.

For students in Ontario attending school off reserve, their success is highly related to the education level in their community and remoteness. There are no determinants strongly related to success in Manitoba. The low success rates are consistent across all factors.

For students attending school off reserve in Saskatchewan, their success is highly related to all factors except remoteness. There seem to be no factors varying the success of students attending school on reserve.

All factors are related to the success of Alberta students attending schools on and off reserve, except for crowding. There are noted gender differences with men's success being far more related to the educational attainment of the community, and to remoteness, than women.

The success of British Columbia students attending school on reserve is far more related to these variables than for those going to school off reserve. There is a noted gender difference with remoteness being related to the success of women attending school on reserve more so than men.

The implications of these observations are no doubt deeply complex. Economic, social, historical and geographic issues likely affect different regions, communities and individuals differently. As outlined in the remainder of this report, this speaks to a need to reconsider how the issue of First Nation student success is approached systemically.

Table 1: Factors Associated with Student Success

2.2 Review of ISC's Education Funding Approach

First Nation student success entails a sense of pride and identity, which Canada's historical colonial legacy has eroded for many Indigenous peoples and their children through intergenerational trauma. Every Indigenous partner interviewed in this evaluation indicated that the legacy of residential schools, the Sixties Scoop and related colonial policies continue to influence attitudes towards the education system at large amongst First Nation community members. The program design and funding structure of ISC programs during the period of this review did not address the breadth of need both directly and indirectly related to a strong education system. This necessitates a significant reconsideration of how ISC can better support First Nations to address education barriers and gaps.

An appropriate support system should assume that generally, First Nation children come from a place of collective and often individual trauma, and that many need strengthened supports well beyond classroom and curriculum – to parental engagement, cultural connection and extensive social community development and services.

While the raw dollar per capita funding for First Nations education on reserve is high relative to provincial ministries, it does not account for the legislative, economic and historical context of First Nation realities, where costs would vastly exceed those off reserve if a model of sufficiency funding (funding based on cost as opposed to indexation) applied.

During the period covered in this review, funding took the form of a mix of proposal-based project funding and annual block funding normally distributed in 4 or 5 year agreements. The general premise is that funding First Nations this way will enable First Nation schools to offer a learning environment that is comparable to that off reserve. Critically, however, this goal presumes that a comparable learning environment is adequate and appropriate for First Nation students, and uniformly so across all First Nations. First Nation and government interviewees participating in this evaluation agreed that ISC program support should have a goal of appropriateness and sufficiency, not comparability.

For First Nation students attending school off reserve, provincial schools are reimbursed a tuition amount at the rate of the provincial nominal roll for that school. This creates an inequity – whereas provincial schoolboards negotiate the tuition amount with First Nations who administer provincial tuition (or with ISC where the First Nations does not administer the tuition), during the period covered in this evaluation, ISC alone determined the amount for a student attending school on reserve, not the First Nation. In other words, First Nations had far less control and autonomy than provincial school boards, but were expected to offer comparable programs and facilitate comparable results.

Ultimately, both total and per-capita funding have increased (see Figure 6). While the number of students on the nominal roll was stable^{Footnote 20} (approximately 105,000) between 2010-11 and 2015-16, both total and per-capita expenditures have increased by 15 percent in that time, from $1.27 billion to $1.46 billion per year, or from approximately $12,000 per student to $14,000 per student. Improvements in student success have not occurred over this time frame. While the Nominal Roll data are not (as of the completion of this report) usable past 2015-16, it is important to note that funding increased in 2017-18 to approximately $1.83 billion, which is approximately the planned spending going forward to 2020.

Text alternative for Figure 6: Total and Per Capita expenditures have increased 15 percent while the total number of students has remained stable between 2010-11 and 2015-16, and graduation rates have not improved

Figure 6 is a series of four graphs which examines the program from 2010-2011 to 2015-2016 in terms of program spending, the number of total students on the nominal roll, the amount spent per student, and the proportion of Final Year students graduating.

The first chard examines the total program spending in billions from 2010-2011 to 2015-2016. In the 2010-2011 program spending was $1.27 billion. In 2011-2012 program spending was $1.34 billion. In 2012-2013 was $1.4 billion. In 2013-2014 program spending was $1.43 billion. In 2014-2015 program spending was $1.45 billion. In 2015-2016 program spending was $1.45 billion.

The second chart examines the total number of students on the nominal roll from 2010-2011 to 2015-2016. In 2010-2011 the total number of students in the nominal roll was 105,139. In 2011-2012 the total number of students in the nominal roll was 104,577. In 2012-2013 the total number of students in the nominal roll was 103,395. In 2013-2014 the total number of students in the nominal roll was 104,397. In 2014-2015 the total number of students in the nominal roll was 105,889. In 2015-2016 the total number of students in the nominal roll was 104,758.

The third chart examines the annual program spending per student for the period of 2010-2011 to 2015-2016. In 2010-2011 the program spent $12,079 per student. In 2011-2012 the program spent $12,813 per student. In 2012-2013 the program spent $13,540 per student. In 2013-2014 the program spent $13,697 per student. In 2014-2015 the program spent $13,693 per student. In 2015-2016 the program spent $13,936 per student.

The fourth and final graph tracks the proportion of final year students who graduated in a trend line starting in 2010-2011 and ending in 2015-2016. In 2010-2011 the proportion of final year students graduating was 41% and trends down slightly to 37% by 2015-2016.

This evaluation finds a need to restructure program funding access and support, in addition to the annual increasing funding reference levels stemming from Budget 2016. A significant proportion of the costs of operating a functional and appropriate education system on reserve is for wrap-around services, such as psycho-educational and extra-curricular supports; infrastructure, which is handled separately from education funding within ISC; salaries for support staff; and transportation. Whereas off reserve, funds for these expenses come from comprehensive funding from school boards with revenues from provincial ministries and municipalities, this contrasts sharply to funding on reserve, where it is a combination of proposal and block funding mostly from ISC, which is largely referenced by historical indices as opposed to being cost-determined.

With limited to no revenue base, many First Nations mostly need to rely on ISC funding for education and wrap-around services. ISC's current approach to funding does not adequately reflect the fact that operating an education system on reserve costs more, not only for direct costs of education provision such as teacher salaries and transportation, but all wrap around services, which in a municipality would be covered under multiple budget areas. Despite increased funding, some education staff on reserve interviewed said they must spend time seeking outside funding for wrap-around services, which generally are more readily available off-reserve.

Many First Nation-operated schools (with few exceptions) are unable to provide competitive compensation for teachers and teaching assistants, and normally are limited in their ability to employ teachers beyond one-year contracts. Often, when First Nation schools are able to provide salary parity, they are able to do so only if they have significant revenue streams. Site visit participants interviewed for this evaluation stated that the disparity between wages, predictability and job security on reserve versus those in provincial schools was a driving factor behind a lack of teacher retention.

A lack of teacher retention creates several issues for First Nation schools, including increasing the school's administrative workload by creating a need to constantly recruit and hire new teachers, which was identified as a challenging, time-consuming process, and especially challenging for remote and isolated communities and those with limited administrative capacities. The lack of retention also inhibits the school from having a faculty with strong relationships with students, parents and the community at large – something that was identified as crucial to student and community wellbeing.

The approach to funding during the evaluation period did not take into account the unique circumstances (both historical and current) that affect students accessing education. Despite the fact that funding per capita is high relative to provincial ministries, the missing aspect of this funding is the necessary wrap-around services unique to each community.

"There are students that eat at our lunch program on Friday that won't be given anther meal
until they come back to our breakfast program on Monday morning."
 – First Nation school administrator

Student transportation was cited as problematic, where many interviewees indicated that communities with poor road infrastructure face significant challenges, as travelling down poorly maintained roads accelerates the deterioration of buses, and they lack the funding for adequate repairs. Often it is very difficult to procure funds for student transportation and communities have indicated it can take far too long to receive these essential funds. One community visited had pursued funding for a washer and dryer for the school to wash and dry students' clothes after they walked kilometers through mud to attend classes, due to poor road conditions and insufficient transportation, but funding for such items does not exist due to the rigidity of funding models.

School infrastructure continues to be a struggle for many communities. There is a long waitlist of communities for new schools, and many do not know how long they will wait for their proposal to be considered. If a project is approved, it becomes another long process for education and band administrators to handle. Additionally, school infrastructure is handled via a separate program and funding allocation from ISC, further complicating a First Nation's ability to procure funds, and by requiring First Nations to adhere to what is considered 'allowable' expenses, rather than allowing First Nations to establish their priorities based on their unique circumstances.

2.3 Early Childhood Learning

The separation of Early Childhood Learning from the rest of the education system runs contrary to the notion of lifelong learning. Lifelong learning, as articulated by many First Nation communities, is an ongoing process beginning with early childhood education and continuing beyond post-secondary education.^{Footnote 21} The separation also increases the administrative burden faced by First Nation education administrators, who already fill multiple roles.

Indigenous partners who were interviewed indicated that there is a strong will amongst educators to get children into classroom-like environments at an earlier age in order to better familiarize them with the classroom, to offer opportunities to be close in proximity to their siblings and to allow for stronger education programs for early learners. The separation of early childhood education from elementary/secondary education results in early childhood education programs being housed in separate facilities than the school, if the programs are available at all.

It was commonly noted in interviews conducted as part of site visits that First Nation children entering Kindergarten do so at a considerable disadvantage when there is no formalised early childhood education system on reserve. There was variability between communities on the extent to which they felt funding for Aboriginal Head Start was sufficient, and a tendency to deprioritise early childhood education in general where the basic elementary education system was struggling to meet basic needs.

It was noted by key-informant interviewees, and is echoed in the last evaluation of Elementary/Secondary Education completed in 2012-13, that the Government of Canada's fragmentation of early childhood education policy is acting to the detriment of communities' ability to adequately support these systems, and ultimately to the detriment of learner success.  

A substantial body of international research, including the findings of a number of well-cited longitudinal studies, suggests that appropriate participation in high-quality early childhood education programs leads to short- and longer-term improvements in educational achievement, particularly for disadvantaged children. Additionally, positive outcomes (albeit more nuanced and mixed) can also be expected on child health, wellbeing and parenting skills. Early childhood education has also been shown to contribute to increased income over the short (for parents) and longer term (for children), as well as a reduced use and reliance on public services (e.g., social services, welfare, justice-related, among others). Further, research sponsored by the World Bank, which has taken a lead role in Early Childhood Care and Development, states that 'Policymakers must identify the educational investments that yield the highest public returns. Here, the literature is clear — Dollars invested in Early Childhood Care and Development yield extraordinary public returns.'^{Footnote 22}

First Nation education policy in general needs to look at issues holistically and recognise that an ambitious policy framework, which aims to tackle early learning gaps and needs, is needed. Including early childhood education into ambitious and integrated education policy would not only better empower First Nations to support their young children's education in a way that is culturally relevant, but would also allow for the early assessment of any learning issues or special needs. Early intervention in these matters will substantially increase the likelihood of longer-term success and wellbeing.

2.4 Regional Agreements

Regional agreements can be a powerful self-determination tool, allowing communities to work together to create better outcomes for the future. Over the time period covered by this evaluation, ISC had two regional agreements in the area of education: British Columbia had the British Columbia Tripartite Education Agreement, which has one of the highest regional graduation rates amongst Indigenous students (although notably this has al ways been the case and predates the agreement); and Manitoba had the Manitoba First Nations School system, which includes 11 Manitoba First Nations and is a First Nations-designed and led school system. While some regional agreements have shown promising outcomes, these agreements are not a blanket solution to the problems identified in this evaluation. The context of each regional agreement is different, and involves communities with unique histories and cultures. The manner in which these agreements are negotiated can influence how communities feel about them once they are in place.

One community participating in this evaluation that was a member of a regional agreement stated that they were never involved in any negotiations of their formal agreement with the third party and the Government of Canada, and they had never seen a copy of their agreement. The agreement also resulted in the community losing crucial funding for wrap-around services, as they lost the ability to run deficits where needed to keep programs running.

Decision-making on the allocation of limited funds will be difficult in any context, and First Nation schools have expressed frustration with their Band councils, education governing bodies and provincial ministries, in addition to ISC. Very often the concerns expressed are similar – decisions made that educators find detrimental to the wellbeing of students (reductions in teaching assistants, various transportation costs not approved, the elimination of positions due to lack of financial resources, etc.). It is therefore important that devolution of control, including through regional or other types of education agreements, not be considered a solution in and of itself. Rather, devolution and the agreements that support First Nations control of First Nations education offer one key approach to strengthening self-determination, but challenges may persist nonetheless. Extensive cooperation, investments, and capacity development must be integral parts of new approaches to First Nation education funding.

With limited or no additional funds for any given First Nation at the outset of many of these agreements, First Nation education administrators interviewed indicated that the added autonomy was to the organisation conducting negotiations on behalf of First Nations, and not always or necessarily to the First Nation. In many cases, significant funding decisions were made that were not supported by the band, and that did not adhere to their priorities, so in effect they were signing agreements for decisions to be made by another administrative body that, while Indigenous, was not felt by many interviewees to represent their communities. It was felt by several of the interviewees that agreements often increase competition between First Nations, where larger ones tend to achieve a better situation than smaller ones. Where the benefits to agreements are referenced, they mostly include some third-level services that decrease some of the administrative burden on the band.

In general, there was far more enthusiasm for regional agreements and aggregates among ISC regional staff than among First Nations. Government staff consistently stated that the agreements provide more flexibility, predictability and ultimately improved third-level services, and better enabled communities to place more emphasis on language and culture. There is limited evidence that this has occurred to date, and there was skepticism among First Nation administrators (outside of British Columbia) that were interviewed in this evaluation. It is too early to be able to measure such outcomes, as agreements (other than British Columbia's, which is long-standing) are still in their infancy, and there are very few agreements against which to measure progress.

Importantly, to both advance the self-determination of Indigenous peoples through education agreements, and simultaneously strengthen the stability of education administrations on reserve, it is essential to ensure that no school or community will benefit less from an education agreement than from their previous funding arrangements. It is also important to ensure communities that are part of an agreement are aware of the level of autonomy they will have in an agreement, and are given adequate time and opportunity to consider these implications, be a meaningful player in negotiations and make informed choices. Finally, First Nation administrators who were interviewed expressed concern about having to go through designated organisations to be heard in engagements. If they feel their interests are not adequately represented by these organisations, they face significant difficulty having their points heard if those interests are not shared by the designated organisation.

2.5 High-Cost Special Education

The demand for High-Cost Special Education services for First Nations is high, and on-reserve schools have many students with conditions requiring accommodation. All interviewees stated that high-cost special education was a major cost driver for their schools, and that, in general, the availability of services for these students is greater in the provincial school system. There are needs that students have that communities struggle to meet due to a lack of funding, infrastructure and isolation, and some have gone so far as to find other sources from private donors.

The program's distinction of a moderate to profound learning disability for eligibility for High-Cost Special Education funding was identified as problematic. Many students lack a diagnosis for a moderate to profound learning disability, but still require high-cost academic or behavioral supports that are similar to some of the services needed for those diagnosed with 'profound' disabilities. There is difficulty finding adequate funding for these supports, which has negative implications for both the students with needs and those in their classrooms.

Specifically, interviewees indicated that, in general, children on reserve have moderate access to basic medical services, basic counselling, some mentoring and cultural services, psycho-educational testing, basic occupational therapy and general in-class support. In contrast, off reserve they have access to these services, and they have far more access to pediatricians, medical specialists, trauma-informed counselling, autism services, strategies for students with severe behavioural issues and hubs of children's services. The consequences of this are that parents are often not connected and engaged with early intervention strategies until after kindergarten, and are significantly behind in terms of early diagnosis, assessment and treatment.

The most commonly cited issue with High-Cost Special Education was the fact that it is largely proposal-based, which is administratively burdensome, putting school administrators in the position of seeking approval for funding and providing evidence as to how much is needed every year – a scenario that is far less likely off reserve, with a more reliable budgetary base for special education writ large. Additionally, core funding for the level of service needed by qualified personnel to work with students with special needs is extremely limited.

Beginning in July 2016, the Government of Canada began flowing money through a fund of $382.5 million from Jordan's Principle. The purpose was to provide immediate support for children in need of a wide range of services related to health, education and social needs. The intent going forward is to build better structures and funding models to better ensure First Nation children have access to the products, services and supports they need, when they need them.

The extent to which this funding has provided, or can be reasonably expected to continue to provide, improvements in this regard has yet to be fully understood. However, given the integral role of special education in the education system, and its associated costs, a clear and comprehensive strategy would help to ensure that special education is fully integrated in a school's operations and equitable to what a student would have off reserve.