Analyses

How many students one special education group may have

The state sets it: 8 to one certified special educator in a substantially separate setting, 12 with an aide. Here is the rule, and here is what it cannot tell you about Lunenburg.

lunenburgbudgetproject.org — written by the Lunenburg Budget Project, an independent tool for residents. Not affiliated with the Town of Lunenburg, the School Committee or the school district. The data this page is computed from: /data/sped-regulation.json

8 to 1

students to one certified special educator, substantially separate (603 CMR 28.06(6)(d))

12 to 1

with a certified special educator and an aide — same clause

16 to 1

the highest the rule ever goes, and only where the group is outside general education 60% of the schedule or less

What this report counts

This is not a general class-size rule. 603 CMR 28.06(6) opens by naming what it governs: eligible students aged five and older receiving special education services outside the general education environment. A general education classroom is not a group it speaks to. And it binds an instructional GROUP, while everything DESE publishes about Lunenburg counts children. Nothing joins the two, which is why this page stops where it does — and nothing on it is a compliance finding about anybody.

If you read nothing else

018students

A substantially separate group may not exceed 8 students to one certified special educator

With an aide it is 12. The aide is what raises the ceiling; the teacher count never changes.

603 CMR 28.06(6)(d), quoted in full below: a setting "serving solely students with disabilities for more than 60% of the students’ school schedule" shall have "instructional groupings that do not exceed eight students to one certified special educator or 12 students to a certified special educator and an aide". These are the numbers residents argue about, and until this regulation was added to the archive nothing in this town’s published record set them out.

What it rests on 603 CMR 28.06(6)(d), read out of DESE’s own published text of the regulation on every build.

What it does not show Anything about Lunenburg. This is the ceiling on a GROUP, and nothing on this page says how many groups this town runs or how large they are.

Nothing published lets anybody compute how many staff this rule requires in Lunenburg

41 children could be four groups or seven, needing very different staffing. Both are lawful.

The regulation binds instructional groups. Lunenburg publishes a count of children by placement label and no count of groups, no size for any group, and no assignment of children to them. Three further things in the regulation would defeat a ratio even with that list: the sizes are MAXIMUMS and districts are "expected to exercise judgment in determining appropriate group size and supports for smaller instructional groups serving students with complex special needs"; grouping must be "compatible with the methods and goals stated in each student’s Individualized Education Program", which can require one-to-one support no class size predicts; and a group already at maximum may take two more students mid-year by decision of the Administrator of Special Education. This page therefore states the rule and stops, and the limit is a registered row in money-gaps.csv rather than a sentence only this page carries.

What it rests on 603 CMR 28.06(6)(b), (c) and (e); and the absence of any published list of Lunenburg’s special education instructional groups.

What it does not show That Lunenburg is over-staffed or under-staffed. Nothing on this page supports either reading, and it is not an audit.

038group-size tiers

Every tier the rule sets names one educator — at every age, in every setting

Across all 8 tiers only the aides change. A bigger group never buys a second educator.

8 tiers, in two age bands: 28.06(6)(c) and (d) for students aged five and older, 28.06(7)(e) and (f) for children three and four years of age. In every one of them the adult in charge is singular. What changes between 8 and 12, and between 12 and 16, is an aide. The build refuses to publish this table if a single row ever names a second educator, because the shape is the finding.

What it rests on 603 CMR 28.06(6)(c) and (d) and 28.06(7)(e) and (f), parsed tier by tier out of the sentences that state them.

What it does not show That the two bands name the same qualification. 28.06(6) says "certified special educator" and 28.06(7) says "teacher", and nothing here establishes those are the same thing — the table prints each clause’s own word. Nor what an aide is: the regulation never defines it, while DESE’s staffing files and the district’s budget lines say "paraprofessional".

0420students

The more separate the setting, the lower the ceiling — in both age bands

School age falls 16 to 12. Preschool falls 20 to 9 — same direction, bigger drop.

This is the opposite of what most people assume, and it holds at every age the regulation covers. 28.06(6)(c) governs groups outside general education 60% of the schedule or less and runs to "16 students if the certified special educator is assisted by two aides"; 28.06(6)(d), above that threshold, names two tiers and stops at 12. The phrase "two aides" occurs exactly once in the whole of 603 CMR 28.00, which this build asserts on every run. The preschool clauses run the same way and further: an integrated class may reach 20 under 28.06(7)(e), a substantially separate one is limited to 9 under 28.06(7)(f). The build refuses to publish if either band stops falling, or if preschool stops falling further than school age.

What it rests on All four class-size clauses, parsed; and a count of the phrase "two aides" across the full regulation.

What it does not show Why. The regulation gives no reason for the pattern and this page offers none — any explanation would be a hypothesis about drafting decisions nobody here witnessed. Nor are the two bands strictly comparable: 28.06(6) caps an instructional GROUP and 28.06(7) caps a CLASS, and the preschool clauses count children with and without disabilities together.

050limits on adults in the room

The rule sets the MINIMUM staffing for a group size. IEPs add on top of it

12 children with one educator and 3 aides is lawful. So is 12 with one aide.

This is the most misread thing about the class-size rule, and it runs in both directions. Take the room people actually ask about: 12 children, one certified special educator, and 3 aides of whom 2 are assigned to individual children by their IEPs. The rule asks two questions — are there 12 students or fewer, and is there a certified special educator with an aide — and both are answered, so the room complies and has more staff than the rule requires. Every tier caps CHILDREN given a staffing configuration; not one of them limits adults. A room may also hold a speech therapist and a behaviour specialist and the class-size rule speaks to neither. So a room at the legal minimum and a room staffed three times over look identical from outside, which is why "we have a lot of paras" and "our groups are within the rule" can both be true and neither explains the other. And the regulation carries 0 limits on adults anywhere: this build searches its full text for 8 phrasings of individual support — "one-to-one", "1:1", "individual aide" among them — on every run, and publishes the count beside the result.

What it rests on Every class-size clause, read for what it counts; a worked room checked back against the tier it satisfies on every build; and a search of the full text of 603 CMR 28.00 for eight phrasings of individual support, published beside the result.

What it does not show The corner of it. Where a group of 12 has exactly ONE aide and that aide is assigned to a single child, nothing says whether they also satisfy the tier: the regulation says "assisted by one aide" and defines neither the aide nor their duties. Assuming they do understates the staffing a group needs; assuming they do not overstates it. The document does not say, and this page does not choose. Registered as a gap.

0741children

DESE reports 41 of Lunenburg’s 258 students with disabilities as substantially separate

That is the group 28.06(6)(d) covers. It is children, not groups, so it sets no staffing number.

In FY2026, 41 of 258 — 15.9%. Two things about that count before anybody divides it by eight. It is a count of CHILDREN and the rule binds GROUPS. And DESE’s Placement breakdown is in-district only: its four printed categories account for 242 of the 258, with 16 children in none of them: the breakdown is in-district only, and element DOE034 allows 8 placements where this prints four.

What it rests on DESE’s special education program characteristics file, Placement rows for Lunenburg, most recent year published.

What it does not show How those children are grouped, which is the only thing that would connect them to the rule. Nothing published says it.

Those are the answers this report could reach from the documents behind it. If the one you came for is not among them, ask us — no name or email needed.

What the rule permits, group by group

Every tier the regulation sets, at every age it covers, in one table. Read the two staff columns before the student column: the educator is one, in every single row — school age and preschool alike. What buys a larger group is an aide.

all 8 tiers — 603 CMR 28.06(6)(c) and (d) and 28.06(7)(e) and (f), parsed from the sentences that state them

the setting	when	students, at most	the staff that permits it	educators	aides	where it says so
School ageaged five and older · the clause says “certified special educator”
Outside general education 60% or less of the schedule	—	8	1 certified special educator and no aide	1	0	603 CMR 28.06(6)(c)
	—	12	1 certified special educator and 1 aide	1	1	603 CMR 28.06(6)(c)
	—	16	1 certified special educator and 2 aides	1	2	603 CMR 28.06(6)(c)
Substantially separate — more than 60% of the schedule	—	8	1 certified special educator and no aide	1	0	603 CMR 28.06(6)(d)
	—	12	1 certified special educator and 1 aide	1	1	603 CMR 28.06(6)(d)
Young childrenthree and four years of age · the clause says “teacher”
Integrated with children who do not have disabilities	up to five of the class have disabilities	20	1 teacher and 1 aide	1	1	603 CMR 28.06(7)(e)
	six or seven of the class have disabilities	15	1 teacher and 1 aide	1	1	603 CMR 28.06(7)(e)
Substantially separate — serving primarily or solely children with disabilities	more than 50% of the class have disabilities	9	1 teacher and 1 aide	1	1	603 CMR 28.06(7)(f)

the one educator each clause namesaide

And the ceiling falls as the setting gets more separate, in both bands. A school-age group outside general education 60% of the schedule or less reaches 16 students with 2 aides; a substantially separate one — more than 60% — stops at 12. Preschool runs the same way and further: 20 integrated, 9 substantially separate. Same direction, a bigger drop.

Outside general education 60% or less of the schedule
(c) Instructional grouping size requirements are maximum sizes and school districts are expected to exercise judgment in determining appropriate group size and supports for smaller instructional groups serving students with complex special needs. When eligible students are assigned to instructional groupings outside of the general education classroom for 60% or less of the students' school schedule, group size shall not exceed eight students with a certified special educator,12 students if the certified special educator is assisted by one aide, and 16 students if the certified special educator is assisted by two aides.
603 CMR 28.06(6)(c)

Substantially separate — more than 60% of the schedule
(d) Eligible students served in settings that are substantially separate, serving solely students with disabilities for more than 60% of the students' school schedule, shall have instructional groupings that do not exceed eight students to one certified special educator or 12 students to a certified special educator and an aide.
603 CMR 28.06(6)(d)

Young children — an inclusionary setting
(e) Type of Setting - Inclusionary. Inclusionary programs for young children shall be located in a setting that includes children with and without disabilities and shall meet the following standards: Services in such programs may be provided in the home, the public school, Head Start, or a licensed childcare setting. For public school programs that integrate children with and without disabilities, the class size shall not exceed 20 with one teacher and one aide and no more than five students with disabilities. If the number of students with disabilities is six or seven then the class size may not exceed 15 students with one teacher and one aide.
603 CMR 28.06(7)(e)

Young children — a substantially separate setting
(f) Type of Setting - Substantially Separate. Substantially separate programs for young children shall be those programs for three and four year olds that are located in a public school classroom or facility that serves primarily or solely children with disabilities. Substantially separate programs shall adhere to the following standards: Substantially separate programs shall be programs in which more than 50% of the children have disabilities. Substantially separate programs operated by public schools shall limit class sizes to nine students with one teacher and one aide.
603 CMR 28.06(7)(f)

What this does not show

That the two bands are strictly comparable. 28.06(6) caps an instructional group and 28.06(7) caps a class; the preschool clauses count children with and without disabilities together, and they say teacher where the school-age clauses say certified special educator. Nothing here establishes those are the same qualification, which is why the table prints each clause’s own word on its band rather than one word over all of them.

What this does not show

A cap on students with disabilities in the substantially separate preschool row. 603 CMR 28.06(7)(f) runs the other way: it defines such a programme as one in which more than 50% of the children have disabilities, and caps the class rather than that share. Writing a number in that column would be this page inverting a floor into a ceiling.

The same children, staffed two ways

The question that comes up every time: if there are 12 children in a room with one teacher and 3 paras, and each para is a one-to-one, how does that work out? It complies — and it has more staff than the rule requires. The rule sets the minimum for a group size. IEPs add on top of it.

the rule asks two questions: how many students, and is there an educator with an aide

8 children

1 educator and no aide

Complies, at the minimum the rule allows

One certified special educator and no aide. This is the largest group the rule permits without one.

603 CMR 28.06(6)(d)

12 children

1 educator and 1 aide

Complies, at the minimum the rule allows

The aide is what raises the ceiling from 8 to 12. Nothing more is required at this group size.

603 CMR 28.06(6)(d)

12 children

1 educator and 3 aides, 2 of them assigned to an individual child by an IEP

Complies, with more staff than the rule requires

The same group size, staffed three times over. The rule asks two questions — 12 students or fewer, and a certified special educator with an aide — and both are answered. The other 2 are there because IEPs require them, not because this rule does.

603 CMR 28.06(6)(d)

the one educator each clause namesaidean aide an IEP assigns to one child

A room at the legal minimum and a room staffed three times over look identical from outside. That is why a count of paraprofessionals cannot be turned into a statement about group sizes, and why group sizes cannot be turned into a staffing number — the same wall this page hits below, approached from the other side.

What this does not show

Any part of those rooms except the ones the regulation fixes. The student counts and the minimum staffing are read off the tiers above; the 2 extra aides in the third room are this page’s illustration, chosen to match the room people describe, and nothing here says how common such a room is in Lunenburg or anywhere else.

What this does not show

The corner of it. Where a group of 12 has exactly one aide and that aide is assigned to a single child, nothing states whether they also satisfy the tier. The regulation says “assisted by one aide” and defines neither the aide nor their duties — and it contains 0 rules about one-to-one support of any kind, searched on every build for 8 phrasings including “one-to-one”, “one to one”, “1:1”. Assuming such an aide counts understates the staffing a group needs; assuming they do not overstates it. Registered as a gap below.

What travels with those numbers

Finding 1

They are maximums, and smaller is expected

The same clause that sets the sizes says districts are “expected to exercise judgment in determining appropriate group size and supports for smaller instructional groups serving students with complex special needs”. A group at the maximum is the ceiling, not the standard.

Finding 2

An IEP can require smaller, or one-to-one, regardless

603 CMR 28.06(6)(b) requires the size and composition of a grouping to be compatible with the methods and goals in each student’s own plan. No class-size rule predicts a plan that calls for one-to-one support, and nothing in the tiers above overrides one.

Finding 3

A group at maximum may take 2 more, mid-year, by decision

603 CMR 28.06(6)(e), and it carries conditions: the additional students must have compatible instructional needs and then be able to receive services in their neighbourhood school; the Administrator of Special Education must notify the Department and the parents of every member of the group in writing, with reasons; the increase lasts only for the year it starts in; and the district must take all steps necessary to bring the group back within the sizes for later years.

Finding 4

No group may span more than 48 months of age

603 CMR 28.06(6)(f). This is a real constraint on reaching the sizes above: a district cannot combine children into one group of 12 simply because the total permits it. A wider range may be approved on written request to the Department.

The grouping must match the IEP
(b) The size and composition of instructional groupings for eligible students receiving services outside the general education classroom shall be compatible with the methods and goals stated in each student's Individualized Education Program IEP .
603 CMR 28.06(6)(b)

Two more students, mid-year, by decision
(e) After the school year has begun, if instructional groups have reached maximum size as delineated in 603 Code of Massachusetts Regulations CMR 28.06(6)(c) and (d), the Administrator of Special Education and the certified special educator(s) providing services in an instructional group may decide to increase the size of an instructional grouping by no more than two additional students if the additional students have compatible instructional needs and then can receive services in their neighborhood school. In such cases, the Administrator must provide written notification to the Department and the parents of all group members of the decision to increase the instructional group size and the reasons for such decision. Such increased instructional group sizes shall be in effect only for the year in which they are initiated. The district shall take all steps necessary to reduce the instructional groups to the sizes outlined in 603 Code of Massachusetts Regulations CMR 28.06(6)(c) and (d) for subsequent years.
603 CMR 28.06(6)(e)

The clauses above are quoted exactly as DESE publishes them, which is why some read “603 Code of Massachusetts Regulations CMR”. That expansion is in DESE’s own page, in a span its markup hides from sighted readers and reads aloud to screen readers. Tidying it here would be this site quoting its rendering of the regulation instead of the regulation.

What this does not show

What an aide is. The regulation uses the word and never defines it. 603 CMR 28.02(3) defines the certified special educator, in full, and there is no matching definition of the other. The word paraprofessional appears in 603 CMR 28.00 only in the staff-training clauses, one of which names “teachers, paraprofessionals, and teacher assistants” as three separate things. DESE’s staffing files and the district’s budget lines say paraprofessional. Those are the words two different documents use, and nothing here establishes that they name the same job.

What a certified special educator is
(3) Certified special educator shall mean a person with a teaching certificate or license in an area of special education or a related service provider with appropriate certification or license in his or her professional area. Licensure shall meet the requirements of the Massachusetts Regulations for Educator Licensure and Preparation Program Approval at 603 Code of Massachusetts Regulations CMR 7.00 and the requirements for renewal of license at 603 Code of Massachusetts Regulations CMR 44.00, as necessary. A certified or licensed special educator may provide, design, or supervise special education services.
603 CMR 28.02(3)

The one place paraprofessionals are named
The school district shall provide such staff training in methods of collaboration among teachers, paraprofessionals, and teacher assistants to accommodate diverse learning needs.
603 CMR 28.03(1)(a)

What the words mean — and which ones the rule never defines

A reader who has just been told that aide and paraprofessional are two documents’ words needs to know what either one means. 603 CMR 28.02 is the definitions section, and it defines 6 of the 14 terms this page leans on and none of the other 8. The absences are the more useful half.

Certified special educator

(3) Certified special educator shall mean a person with a teaching certificate or license in an area of special education or a related service provider with appropriate certification or license in his or her professional area. Licensure shall meet the requirements of the Massachusetts Regulations for Educator Licensure and Preparation Program Approval at 603 Code of Massachusetts Regulations CMR 7.00 and the requirements for renewal of license at 603 Code of Massachusetts Regulations CMR 44.00, as necessary. A certified or licensed special educator may provide, design, or supervise special education services.

603 CMR 28.02(3) · used 7 times in the regulation

Special education

(20) Special education shall mean specially designed instruction to meet the unique needs of the eligible student or related services necessary to access the general curriculum and shall include the programs and services set forth in state and federal special education law.

603 CMR 28.02(20) · used 208 times in the regulation

Eligible student

(9) Eligible student shall mean a person aged three through 21 who has not attained a high school diploma or its equivalent, who has been determined by a Team to have a disability(ies), and as a consequence is unable to progress effectively in the general education program without specially designed instruction or is unable to access the general curriculum without a related service. An eligible student shall have the right to receive special education and any related services that are necessary for the student to benefit from special education or that are necessary for the student to access the general curriculum. In determining eligibility, the school district must thoroughly evaluate and provide a narrative description of the student's educational and developmental potential.

603 CMR 28.02(9) · used 63 times in the regulation

Least restrictive environment

(12) Least restrictive environment ( LRE ) shall mean the educational placement that assures that, to the maximum extent appropriate, students with disabilities, including students in public or private institutions or other care facilities, are educated with students who are not disabled, and that special classes, separate schooling, or other removal of students with disabilities from the general education environment occurs only when the nature or severity of the student's disability is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily.

603 CMR 28.02(12) · used 8 times in the regulation

In-district program

(10) In-district program shall mean a special education program operated in a public school building or other facility that provides educational services to students of comparable age, with and without disabilities.

603 CMR 28.02(10) · used 10 times in the regulation

Out-of-district program

(14) Out-of-district program shall mean a special education program located in a building or facility outside of the general education environment that provides educational services primarily to students with disabilities and shall include all programs approved under 603 Code of Massachusetts Regulations CMR 28.09. Such program may be operated by a private organization or individual, a public school district, or a collaborative.

603 CMR 28.02(14) · used 6 times in the regulation

Used, and never defined

Each of these appears in the regulation — several of them inside the tiers above — and 28.02 gives none of them a meaning. The count is how many times the word appears, singular or plural. What each one must therefore mean is not stated here and is not guessed at.

aideused 7 times, defined nowhere

the word that decides whether a group of eight may hold twelve, and the regulation defines neither the person nor their duties. It names no other document for the meaning either.

paraprofessionalused 2 times, defined nowhere

every occurrence is in the staff-training clauses of 603 CMR 28.03(1)(a), one of which names “teachers, paraprofessionals, and teacher assistants” as three separate things. The regulation never says what one is, or what one may do.

teacherused 15 times, defined nowhere

the only licensure requirement anywhere in the regulation is 603 CMR 28.09(7)(b), and it governs APPROVED SPECIAL EDUCATION SCHOOLS rather than a district classroom. Nothing here states what a teacher in 28.06(7) must hold.

teacher assistantused 1 time, defined nowhere

instructional groupingused 9 times, defined nowhere

substantially separateused 7 times, defined nowhere

class sizeused 4 times, defined nowhere

one-to-onedoes not appear in the regulation at all

searched for in 8 phrasings across the full text. The regulation contains no rule about individual support at all.

What a certified special educator is
(3) Certified special educator shall mean a person with a teaching certificate or license in an area of special education or a related service provider with appropriate certification or license in his or her professional area. Licensure shall meet the requirements of the Massachusetts Regulations for Educator Licensure and Preparation Program Approval at 603 Code of Massachusetts Regulations CMR 7.00 and the requirements for renewal of license at 603 Code of Massachusetts Regulations CMR 44.00, as necessary. A certified or licensed special educator may provide, design, or supervise special education services.
603 CMR 28.02(3)

The one place paraprofessionals are named
The school district shall provide such staff training in methods of collaboration among teachers, paraprofessionals, and teacher assistants to accommodate diverse learning needs.
603 CMR 28.03(1)(a)

What this does not show

What an undefined word means anyway. A count of how often the regulation uses aide is a fact; what an aide must be qualified to do is not established by it, and nothing in this archive settles it. Whether the aide the tiers name is the paraprofessional the town budgets is a registered gap, below — and its direction matters: reading them as the same job understates what a group needs, reading them as different overstates it.

And a school the district places a child into

A programme approved by the Department under 603 CMR 28.09 does not get its own sizes: 603 CMR 28.06(6)(g) holds it to the substantially separate tiers, and 603 CMR 28.09(7)(e) says the same thing from the approval side, adding that the Department may impose tighter limits where the population requires more specialised services.

Approved programs take the substantially separate sizes
(g) Instructional group sizes in all programs approved under 603 Code of Massachusetts Regulations CMR 28.09 shall be limited to those outlined in 603 Code of Massachusetts Regulations CMR 28.06(6)(d), and no such instructional groups shall have an age range greater than 48 months.
603 CMR 28.06(6)(g)

Approved schools are held to the same sizes
Instructional groupings and student/teacher ratios shall not exceed the class size standards set forth at 603 Code of Massachusetts Regulations CMR 28.06(6) and (7). The Department may impose additional limits, if, in the opinion of the Department, the population requires more specialized services.
603 CMR 28.09(7)(e)

What Lunenburg publishes beside it

Everything above is the state’s rule and applies to every district. This section is the town’s own published counts, and the heading is here so that the line between the two is visible rather than inferred.

DESE’s placement breakdown for Lunenburg, FY2026

placement DESE reports	children	share of all students with disabilities
Full Inclusion	183	70.9%
Substantially Separate	41	15.9%
Partial Inclusion	16	6.2%
Separate School in District	2	0.8%
In none of the four printed categories	16	6.2%
Total students with disabilities	258	100.0%

Do DESE’s labels mean what the regulation means?

On the axis, yes, and this is the only reason the two halves of this page can be set beside each other at all. DESE counts placements on element DOE034 of its student information return, and the handbook defines each value as a percentage of time outside the general education classroom — the same quantity 603 CMR 28.06(6)(d) keys on.

element DOE034, as DESE’s SIMS data handbook defines it

code	the label DESE prints	what the handbook says it means
10	Full Inclusion	special education services outside the general education classroom less than 21% of the time
20	Partial Inclusion	special education services outside the general education classroom 21% to 60% of the time
40	Substantially Separate Classroom	special education services outside the general education classroom more than 60% of the time

So “Substantially Separate Classroom” and 603 CMR 28.06(6)(d) both turn on the same 60% threshold. That is where the correspondence ends.

What this does not show

That the two count the same population, or the same kind of thing. The regulation governs eligible students aged five and older and puts three- and four-year-olds under a separate clause; DOE034 covers ages 6 to 21 and a different element covers ages 3 to 5. Those splits are not the same line. And DESE labels a child while the regulation binds a group — the difference this whole page turns on.

What this does not show

That the four printed categories divide the town’s 258 students between them. They account for 242, leaving 16 in none of them. The breakdown is in-district only: DOE034 allows 8 placements and the published file prints four of them. Adding the four and treating the total as their sum is the mistake the row above exists to prevent.

every placement DOE034 allows

code	what the handbook calls it	named identically in the published breakdown
10	Full Inclusion — special education services outside the general education classroom less than 21% of the time	yes
20	Partial Inclusion — special education services outside the general education classroom 21% to 60% of the time	yes
40	Substantially Separate Classroom — special education services outside the general education classroom more than 60% of the time	yes
41	Public Separate Day School	—
50	Private Separate Day School	—
60	Residential School	—
70	Homebound/Hospital	—
90	Public Residential Institutional Facilities (0370XXXX schools)	—

What this does not show

Which code each of the other printed categories is. The published breakdown labels one row “Separate School in District” and the handbook has no value of that name; matching it to a code would be this page inferring a correspondence neither document states. The three marked above are marked because the two documents use the same words, and no further mapping is attempted.

Why no staffing number follows from any of this

This is the question everybody arrives with, and the honest answer is that the published record cannot carry it. The rule binds groups. Lunenburg publishes children. 41 children could be four groups or seven — needing very different staffing — and both are lawful.

Registered gap · people

How many paraprofessionals Lunenburg needs, against how many it employs

603 CMR 28.06(6)(d) is now in this archive, and it sets the class-size rule everybody argues around: a substantially separate group may not exceed eight students to one certified special educator, or twelve to a special educator AND AN AIDE. So a paraprofessional is partly what PERMITS a larger group rather than being a ratio in itself — which means paraprofessional counts track PROGRAM STRUCTURE and not student headcount, and would explain the thing /school-staffing measures and cannot account for: paras rising while enrolment fell. WHAT STILL CANNOT BE COMPUTED: the regulation binds INSTRUCTIONAL GROUPS and nothing published says how many groups Lunenburg runs, how large each is, or how its 41 substantially separate students are divided among them. 41 students could be four groups or seven, needing very different staffing, and both are lawful. THREE THINGS THAT WOULD DEFEAT ANY RATIO ANYWAY, all in the regulation itself: the sizes are MAXIMUMS and districts are expected to go smaller for complex needs (28.06(6)(c)); grouping must match each student’s own IEP, which can require one-to-one support no class-size rule predicts (b); and a group at maximum may take two further students mid-year by decision of the Administrator of Special Education (e). IT IS NOT: evidence that staffing is too high or too low. Nothing here supports either. — closes: the district’s own list of special education instructional groups by school and setting, with the students and staff assigned to each — compiled for DESE’s program approval under 603 CMR 28.09 and not published.

One row in what we cannot answer, quoted here rather than restated — so the page and the registry cannot drift apart.

Writing this page found 3 more, and both are now rows in the same registry rather than sentences only this page carries:

Whether an “aide” in the class-size regulation is a paraprofessional the town budgets603 CMR 28.06(6) sets every group size in terms of a certified special educator AND AN AIDE — a group of eight becomes lawful at twelve because an aide is present. 28.02(3) defines the certified special educator in full and the regulation defines no counterpart for the aide anywhere; the word “paraprofessional” appears in the whole of 603 CMR 28.00 only in the staff-training clauses of 28.03(1)(a), one of which names “teachers, paraprofessionals, and teacher assistants” as three separate things. DESE’s staffing return and every Lunenburg budget line say paraprofessional. So the term that DECIDES whether a group of twelve is lawful cannot be matched to any post the town funds, and a count of paraprofessionals is not a count of aides in the regulation’s sense. This sits directly under the gap about how many paraprofessionals the town needs: even with the group list, the units would not match. — closes: DESE’s guidance on what qualifies a person as an aide for 603 CMR 28.06(6), or the district’s own job descriptions mapped to that clause.
Where 16 of Lunenburg’s students with disabilities are placed, in FY2026DESE’s placement breakdown prints four categories — Full Inclusion, Partial Inclusion, Substantially Separate and Separate School in District — and in FY2026 they sum to 242 of the 258 the same file prints as the total. Element DOE034 has nine acceptable values and this breakdown is in-district only, so the other 16 children are in categories the file does not print, and nothing published says which. That bounds every reading of the placement mix: the four printed rows are not a partition, and adding them and treating the result as the whole is the same error as summing a column that was never the total’s parts. — closes: DESE’s full DOE034 distribution for Lunenburg, or the district’s 1 October SIMS placement submission.
Whether an aide assigned to one child also counts as the aide that raises a group from eight students to twelve603 CMR 28.06(6)(c) and (d) raise the maximum group size from eight students to twelve when the certified special educator is "assisted by one aide". The regulation never defines the aide, never states their duties, and — searched on every build for eight phrasings — contains NO rule about one-to-one support of any kind. So where a child’s IEP assigns an aide to that child, nothing published says whether that person also satisfies the tier. THE DIRECTION OF THE ERROR IS THE POINT: assuming they do understates the staffing a group needs, and assuming they do not overstates it, so neither assumption is safe and this project makes neither. It is the same wall as the paraprofessional gap, hit from the other side — the rule counts students and the staffing record counts posts, and nothing converts one into the other. — closes: DESE’s program approval materials under 603 CMR 28.09, which describe how each approved group is staffed; or the district’s own group descriptions naming which adults are counted against which tier.

What this does not show

Anything about whether Lunenburg is over-staffed or under-staffed. Nothing on this page supports either reading, and this is not an audit. The job here is to give the argument residents are already having a copy of the rule it is about.

What the town said about this

Lunenburg does not argue in the regulation’s words. The town says class size and paras; it does not say “substantially separate” or “603 CMR” — not one of those appears in a single searchable meeting document. That is a fact about vocabulary and not about attention: 21 documents discuss class size and 38 discuss paraprofessionals.

documents mention “class size”

documents mention “paraprofessional”

documents mention “caseload”

documents mention “substantially separate”

documents mention “603 CMR”

Searched 8,899 of the 12,015 meeting documents this archive holds (74%), covering 2009-01-05 to 2026-11-17. The other 3,116 carry no text a search can match — 3,096 of them are image scans awaiting OCR. An empty result above is a statement about what can be read, never about what was said.

“noting that kindergarten classrooms were operating with 25 students and no aides”

Finance Committee · minutes · 2026-01-12 · our copy · the town’s

The nearest thing in the whole meeting archive to a Lunenburg group size said out loud beside a staff count. It is a KINDERGARTEN class — a general education classroom — and 28.06(6) governs special education instructional groupings, so this is not a figure the rule applies to. It is here because it is the shape of the argument residents are having.

“Julianna Hanscom states there is no formula. The school is aware of what students are in programs who will then go into a program next year. There hasn’t been a large or small caseload, and the inclusion of teachers is between 15 to 20 students”

Finance Committee · minutes · 2024-03-14 · our copy · the town’s

The Director of Special Education, asked how the budget decides staffing, answering that there is no formula. That is consistent with a regulation that sets MAXIMUMS and requires judgement below them — and it is a statement about how the district budgets, not a measurement of any group.

“seven of her IEP students with significant pull-out service needs were being seen by a paraprofessional rather than a certified special education teacher”

Finance Committee · minutes · 2026-01-27 · our copy · the town’s

A Turkey Hill special education teacher, in public comment. The regulation draws exactly this line — 28.02(3) defines the certified special educator and never defines the aide — which is why the distinction matters. THIS IS NOT EVIDENCE OF A BREACH, and the same clause is why: it says a certified special educator may "provide, design, or supervise" special education services, so a service delivered by somebody the educator supervises is contemplated by the regulation. What is established is that a teacher said this at a public meeting. What is not is how many students, which posts, or what supervision was in place; no FTE by assignment is published.

“they are the backbone of special education and without them the department cannot run”

School Committee · minutes · 2024-01-24 · our copy · the town’s

A parent, in the public comment on the FY25 budget, on the proposed paraprofessional cuts. It establishes that residents argue about paraprofessional numbers. It establishes nothing about instructional groups, which is what the regulation on this page binds.

What this does not show

That any of those quotes can be read against the tiers above. Not one of them names an instructional group, a setting, or a percentage of a school schedule — and the kindergarten figure is a general education classroom, which 603 CMR 28.06(6) does not govern at all. They are here because they are the argument this page is trying to give better inputs to.

What this does not show

That the pull-out account above describes a breach of anything. 603 CMR 28.02(3), printed earlier on this page, says a certified special educator may provide, design or supervise special education services — so a service delivered by somebody the educator supervises is contemplated by the regulation rather than excluded by it. What is established is that a teacher said this at a public meeting. Nothing published says how many students district-wide, which posts, or what supervision was in place, and this page makes no finding about any of it.

The documents

603cmr28-special-education-regulations.html

Massachusetts Department of Elementary and Secondary Education, 603 CMR 28.00

The regulation itself, as DESE publishes it in one page. Every clause quoted on this page is read out of the extracted text on every build and every figure in the table is parsed from the sentence that states it, so a change at DESE stops this build rather than being republished under the old citation.

table (quoted, not loaded) · 875 KB

sha256 33943cfe2e3068d2…

our copy · the publisher’s

sims-datahandbook-current.docx

Massachusetts Department of Elementary and Secondary Education

The Student Information Management System data handbook, which defines element DOE034 — the placement label DESE counts on — as a percentage of time outside the general education classroom. This is what makes the counts and the regulation comparable at all.

table (quoted, not loaded) · 204 KB

sha256 c73f309549e13b0c…

our copy · the publisher’s

dese-sped-program-characteristics.xlsx

Massachusetts Department of Elementary and Secondary Education

Special education program characteristics, the source of the placement counts. Its Placement breakdown is in-district only and its four printed categories do not sum to the total it prints beside them — measured on every build rather than assumed.

table dese_sped_program · 5.4 MB

sha256 417435bddfcac3eb…

our copy · the publisher’s

What this report cannot answer

How many special education instructional groups Lunenburg runs, how large each is, or which children are in which. That list is what the regulation actually binds, and no published document contains it — so no staffing number follows from anything on this page.
That an "aide" in the regulation is a "paraprofessional" in DESE’s staffing files or in the district’s budget. 603 CMR 28.02(3) defines a certified special educator and defines no counterpart; the word paraprofessional appears in the regulation only in the staff-training clauses, one of which names teachers, paraprofessionals and teacher assistants as three separate things.
Whether any Lunenburg group is at, under or over any of these maximums. Nothing in this archive reports a group size, and nothing on this page is a compliance finding.
How DESE’s placement label was assigned to any individual child. It is reported by the district at a census date on element DOE034, and the percentage-of-time judgement behind each one is not published.
What any of it costs. A placement label is not a dollar and a group size is not a budget line — the money is a different report, at a different grain.

What would close these

The district’s own list of special education instructional groups by school and setting, with the students and the staff assigned to each — the list compiled for DESE’s program approval under 603 CMR 28.09 and not published anywhere. Every limit on this page is also a row in what we cannot answer, which is the single registry the records request reads from.

The other reports

Every other report

The One Big Report →Special education — four reports →What other districts spend, for each pupil →What the state requires us to spend — and where that puts us →Chapter 70 — the formula, and why it pays the floor →How Chapter 70 actually works, in eight steps →School staffing — did it go up, and over which years →What courses actually ran, subject by subject →The cut register — what was announced, and what shows →What stopped being funded →When a grant ends — who picks up the bill →Who leaves Lunenburg schools, and where they go →Monty Tech — the assessment, and what sets it →If students leave — what school choice would cost →What a family actually pays →What sports cost, and who pays →Health insurance — the cost outside the school budget →Budgets against what was later reported →

Every analysis this project has written, in one index, is at reports.