Ontario cannot show that its special education system works for the children inside it.

The Education Act requires each board to provide a parent guide following an IPRC referral. The Auditor ran the three boards’ guides through readability tools and found them written at reading levels ranging from Grade 12 — graduate studies at TCDSB, Post-secondary year 1 — graduate studies at PDSB, and Grade 11 — post-secondary year 2 at UCDSB. Only PDSB published its guide in multiple languages.

Teachers themselves told the Auditor that “the IEP consultation process is filled with jargon. Navigating the special education system is challenging, even for those of us with specialized knowledge of how it works.”

The Learning Disabilities Association of Ontario noted that families from lower socio-economic backgrounds are especially impacted when communication is inconsistent, overly technical or not culturally responsive, leading to disengagement and mistrust. The Ontario Human Rights Commission has flagged this same concern since 2018.

The Ministry does not provide guidance on when assessments are required, what documentation supports an identification, or how to comprehensively define exceptionalities. It permits each board to develop its own.

To identify a developmental disability, PDSB requires a cognitive score below the <0.1st percentile; TCDSB sets the threshold at the <1st percentile. The same child could be identified at one board and not the other.

The Ministry’s own categories of exceptionality do not reflect contemporary diagnoses. FASD, ADHD, brain injury, depression and bipolar disorder are not explicitly listed in any category, forcing IPRCs to map novel diagnoses into pre-1980s categories. Autism is classified as a communicational exceptionality even though many autistic students may better align with behavioural or developmental.

And the audit found 65% of placement decisions had no written rationale. Where one existed, 59% only named the diagnosis. 88% of placement changes had no documented explanation. Two-thirds of decisions, in writing or out: undocumented.

At the audit date, 34% of students at TCDSB and PDSB who needed an assessment had been waiting more than a year — 499 students at TCDSB and 248 at PDSB. The Auditor flagged this same problem in 2017. Nothing changed.

Each specialist runs their own waitlist for an assigned cluster of schools, with no consolidation across the board. At TCDSB, one specialist had 64 outstanding speech-language assessments; another had two. None of the three boards prioritizes assessments based on a complete consolidated waitlist.

The equity issue: a private psychological assessment in Ontario costs $2,500–$4,500, and over $5,000 when autism and ADHD screening are added. Boards review private assessments quickly — there are no waitlists for review. So children whose families can pay receive placements and supports sooner than children whose families cannot.

The Ministry disagreed with the audit’s recommendation to track these waitlists centrally. The Auditor’s reply: the recommendation in no way suggests withholding supports without diagnosis. It is a tracking and equity recommendation.

At every board, at least 90% of annual learning goals lacked measurable criteria. Modified expectations lacked measurable criteria at least 94% of the time. Alternative expectations lacked measurable criteria 50% to 86% of the time.

Accommodations, teaching strategies, and assessment methods were generic across the entire sample. “Frequent check-ins,” “proximity to instructors,” “extra time for processing,” “modelling,” “prompting,” “observations,” “anecdotal notes” — repeated. The student-specific part of the “individual” education plan was missing.

Parent participation is a legal requirement. The audit found no evidence of parent consultation in 38% of TCDSB files, 67% of PDSB files, and 95% of UCDSB files. Where consultation was noted, documentation did not show meaningful engagement.

The Ministry set 14 IEP standards in 2017 and promised annual reviews of selected boards to assess compliance. At the time of the audit, it had not conducted a single one.

Educational Assistants — the staff doing day-to-day behaviour, personal care, and IEP implementation work — were absent at higher rates than any other educator group. EAs were absent on an average of 18% of school days across the three boards combined. The fill rate compounded the problem.

According to a 2024 survey by the Ontario School Board Council of Unions, 95.8% of EAs and child and youth workers experienced violent or disruptive incidents — 54.8% daily.

And the staffing was inequitable to begin with. At TCDSB, ratios ranged from 8–76 students per teacher. At PDSB, 13–70. At UCDSB, 10–78. PDSB schools were understaffed by a net of 51 EAs against PDSB’s own documented allocation methodology — the shortfall came from budget caps, not from a re-think of need.

The Ontario College of Teachers does not include specific certification requirements for special education. The Ministry does not set minimum training requirements. Province-wide, between 2019 and 2024, approximately half of all certified teachers held Special Education Part 1, about 20% held Part 2, and about 15% held the Specialist qualification.

For EAs, the Ministry sets no entry or training requirements. There is no provincial certification, licensing body, or mandatory qualification standard. Required behaviour de-escalation training varies: PDSB requires it for all EAs, UCDSB only for those supporting students with safety plans, and TCDSB encourages but does not require it.

59% of regular-classroom and special-education teachers reported receiving no or minimal training on key topics: identifying needs, developing IEPs, assessment, behaviour management, autism, and learning disabilities. Over 70% said additional training would help.

Under the Education Act, a principal can refuse a student entry if their presence would be detrimental to the well-being of others. The Ministry calls these exclusions a last resort. When they happen, schools must document the reason, notify parents, and create a return-to-school plan.

Between 2020/21 and 2023/24, an average of 239 students receiving special education services were reported excluded each year — just 0.07%. 23 school boards (32%) reported no exclusions of students with special education needs in any of those four years.

The Auditor’s teacher survey told a different story. 39% of teachers said they had observed or been involved in informal, undocumented exclusions in 2024/25. Of those, 33% said it happened more than five times.

And students with special education needs were over-represented in formal suspensions: 16% of total enrolment, 43% of suspensions — and 48% were suspended more than once over five years (vs 21% of other students).

Total special education spending across Ontario’s school boards rose by 21% from 2019/20 to 2023/24, outpacing the 17% Ministry funding increase and 15% inflation over the same period.

In 2023/24, 46 of Ontario’s 72 boards collectively spent $397.9 million (14%) more than they were funded for special education. Boards are allowed to carry forward unspent funds — but underspending must still be eventually directed to special education.

The Ministry promised in its own policy guide to review board special education plans for compliance. Of the 49 boards that submitted 2023/24 checklists, 69% reported they had amended their plans — mostly without specifying what. The Auditor found no evidence the Ministry identified or reviewed those changes.

“School boards have allocated funding to special education programs from other budgets because they have identified this as necessary to try to meet the needs of this vulnerable population. This can negatively affect other education programs and services.” — Audit, p. 57