By Carlos Avalos

A former teacher is alleging that the Etiwanda School District’s administration in recent years compromised its educational mission in favor of maximizing funding it receives from the state, destroying the district’s once cutting-edge preschool program in the process, and is now disadvantaging the district’s youngest and most vulnerable students.
Antoinette Jensen taught for seven years in the Creating Learning Opportunities Utilizing Diverse Strategies (CLOUDS ) program within the Etiwanda School District. Initially, she taught as a permitted early child education preschool teacher at Grapeland Elementary, then at Golden Elementary for the 2022-2023 school year, followed by a position at Terra Vista Elementary for the 2023-2024 school year.
The district’s administrators spent more than a decade of building the CLOUDS program into what many considered to be a model program for integrating preschool students into a learning environment and bringing them up to speed with regard to basic academic skills so they take full advantage of the educational opportunities awaiting them in first grade, second grade and beyond, thoroughly familiarizing with how the State of California funds its public school system. Having learned how to tap into that generosity to be able to run legitimate programs aimed at targeting students of varying socioeconomic means and across the entire cognitive spectrum, those running the district eventually fell to manipulating the funding protocols to prioritize not furthering the education of the students the district was entrusted with but to bring substantial amounts of money into the district by enrolling more and more students into programs for which the state would provide augmentation funding whether or not the amalgam of students placed into those classes resulted in a beneficial learning environment or not, Jensen alleges.
In the case of the district’s CLOUDS program, according to Jensen, the teachers found themselves being overburdened with students across too wide of an age spectrum being intermixed in the classes, resulting in their focus and span of control being tested beyond the breaking point. This, Jensen says, resulted in the once successful educational atmosphere within the classes being ruined and student academic achievement plummeting.
As a consequence, according to Jensen, the Etiwanda School District disserves the special education students in its preschool program, exploits their special-needs status, and even tolerates the abuse of special education students in its pre-kindergarten programs.
CLOUDS is a preschool program originally designed to allow special education preschool students 3-4 years of age to attend classes alongside general education preschool students of the same age range. Each preschool class in the CLOUDS program is supervised by two professionals: a certificated early childhood special education teacher and a permitted early childhood education preschool teacher. Initially, CLOUDS program students attended either morning or afternoon sessions, but not both.
Over time, the district’s CLOUDS program, which began with a single class in 2005, enlarged as the number of school sites offering CLOUDS classes gradually increased. By 2021, according to the district’s spokesman, David Oates, the district had 10 preschool cluster sites, three at Falcon Ridge, three at Grapeland, and four at East Heritage. In 2022, the district increased the number of preschool classes to 13. Also in 2022, the district made what Jensen said was a significant change to the CLOUDS program when it welcomed transitional kindergarten (TK) students – students who are too old to be admitted to preschool but too young to be admitted to kindergarten.
Proponents of the expansion claimed that their aim was to enrich the preschool learning environment. Jensen, however, maintains the expansion predictably had the opposite effect in the classroom and that the district’s real motive in expanding the program was simply to draw more funding from various local and state resources.
According to Jensen, through its expansion of the CLOUDS program, the district sought to enroll transitional kindergarten students who are classified as “unduplicated.” An unduplicated student is one who is either an English learner, a foster child, or eligible for free or reduced-price meals. For each such student enrolled, the district receives supplemental and concentration grants through the Local Control Funding Formula, known within educational circles by its acronym, LCFF.
There were two reasons Jensen raised concerns about what occurred in the Etiwanda School District.
As originally conceived, the CLOUDS program classes brought together young students within the limited three to four year age range, ones of differing socioeconomic backgrounds to be sure, but whose experiential and developmental bases were similar enough to allow their attention to be captured and essentially maintained by the classroom’s certificated early childhood special education teacher and a permitted early childhood education preschool teacher. Jensen further noted that neither held the required credentials to legally teach transitional kindergarten, which would later raise both instructional and compliance concerns.
Jensen’s most immediate observation was that by opening the age range to include transitional kindergarten, the district created a legally noncompliant situation. The CLOUDS program already served students with differing cognitive levels through inclusion, with general education students acting as peer models. The cognitive differentiation was not an issue, she said. The problem, according to Jensen, was that transitional kindergarten students were placed in a preschool classroom without a transitional kindergarten curriculum, and her permit does not authorize her to teach transitional kindergarten. As a result, the students were not instructed at their legal grade level, in violation of credentialing requirements, she said.
Jensen also points out that the district justified the program expansion under the pretext of student enrichment, when in reality, she believes the true intent was to increase the district’s access to state funding. The district inappropriately exploited unduplicated students, in her view. The State of California, through its Local Control Funding Formula, provides funding to school districts for each unduplicated student enrolled in a district educational program. The Etiwanda School District has deliberately enrolled all of its unduplicated students in certain programs in order to obtain state funds designated for the support of unduplicated students, whether or not their attendance and participation in those classes is beneficial to them, Jensen said.
The Expanded Learning Opportunities Program (ELOP) is a state program that provides school districts with funds for after-school activities. The district placed transitional kindergarten students into preschool classrooms for the second half of the day after completing legal transitional kindergarten instruction. It then filed for state reimbursement through the Expanded Learning Opportunities Program, claiming the secondary placement qualified as an after-school program, according to Jensen. However, these students were placed in a lower-grade instructional setting during the school day, not in extended care outside of core hours. This stretches the definition of “after-school” and violates California Department of Education rules prohibiting funding during core instructional time, Jensen points out.
Medi-Cal offers school districts funding for services provided to students with qualifying special needs. Jensen alleges that the district has improperly claimed Medi-Cal reimbursement by combining unduplicated general education students in the CLOUDS program with special education students for billing purposes—treating them interchangeably to generate additional revenue, despite those general education students not qualifying under Medi-Cal eligibility criteria.
The disservice to these students is taking place as a consequence of creating an incompatible hybrid of preschool and traditional kindergarten, which has diminished the educational atmosphere of the scholastic setting, Jensen said.
According to Jensen, as a consequence of the district’s attempt to secure additional state funding, transitional kindergarten students in the CLOUDS program were, from 2022 to 2024, placed in preschool classrooms – a full grade below their legal placement – and taught by staff without the required credentials. Based on her classroom observations as an experienced educator, Jensen states that these students did not receive instruction aligned with their grade level. This conclusion, she noted, is supported by the district’s own achievement measurement tools used within the CLOUDS setting.
While Jensen initially supported the CLOUDS program and believed additional revenue was appropriate to support early childhood inclusion, she later discovered that general education students, who were included in classrooms to fulfill the “least restrictive environment” requirement for special education students, were charged tuition. Through investigation, she learned this practice was inconsistent with special education law, as peer model participation written into an Individualized education program should not carry a financial burden for families, and is a public obligation under federal and state education law.
Prior to 2022, the program was achieving more than a modicum of success in fulfilling its stated purpose, Jensen said. When the district expanded CLOUDS to include transitional kindergarten students – slightly older children who would have been too old under prior guidelines – Jensen began noticing problems. She maintains that this shift ultimately undercut the program’s original value and compromised its ability to serve students as it was originally intended.
While an age difference of one, five, ten, or even twenty years among adults may mean little in a professional workplace, Jensen pointed out that a gap of even six months to a year among preschool-aged children can represent a significant – and at times unbridgeable – difference in cognitive and functional levels within a classroom setting.
She objected to the expansion of the CLOUDS program, stating that when slightly older transitional kindergarten students were added, the program began to break down. As a result, the uniform classroom environment was lost. Transitional kindergarten students were taught below their legal grade level in a preschool setting, without an appropriate curriculum or challenge. This led to disengagement, with some students becoming bored due to the lack of stimulation. In turn, that boredom contributed to behavioral disruptions, as students acted out after losing the attention and focus of the teachers.
Exacerbating the situation, according to Jensen, was that in 2022 – when the CLOUDS program expanded to include older students – the number of classrooms also increased to 13. This rapid expansion led to shortages in supplies, including changing tables, and the hiring of new, inexperienced teachers who were rushed into classrooms without adequate training. Some of these teachers struggled to manage environments with multiple student subgroups competing for limited attention, resulting in misbehavior, escalating classroom disruptions, and an overall atmosphere of chaos. In at least some cases, including one in which Jensen was directly involved, this allegedly resulted in the abuse of students within the classroom setting, she said.
In essence, according to Jensen, the district’s expansion of the CLOUDS program diminished teachers’ ability to effectively instruct students and weakened the overall structure and quality of the classroom environment.
By enrolling CLOUDS students from 13 schools in both morning and afternoon sessions, the district positioned itself to receive additional funding through the Expanded Learning Opportunities Program. At the same time, it charged general education preschool families – those who are not low-income, not English learners or not foster households – to participate in the program. However, when general education students are included to fulfill the least restrictive environment requirement in an individualized educational program, families should not be charged under the Free Appropriate Public Education mandate. The district has also billed Medi-Cal for services provided to individualized educational program students in these classrooms. According to Jensen, the district is double-dipping –charging some families while collecting state and federal special education funds – undermining the program’s integrity and turning what should be an inclusive public service into a pay-to-participate model.
After raising concerns about the CLOUDS program – including whether the district was violating rules tied to Expanded Learning Opportunities Program and Local Control Funding Formula funds – Jensen said she faced retaliation and resistance from district leadership. She shared her concerns directly with administrators, offering frank assessments of the program’s shortcomings and recommending state oversight. According to Jensen, her feedback was met with hostility. She also expressed frustration that credentialed staff, who knew they were not authorized to teach transitional kindergarten in a preschool setting, remained silent. Jensen believes this silence stemmed from fear; staff recognized the violations but were unwilling to report them due to the district’s retaliatory environment. Ultimately, Jensen was constructively terminated due to retaliation.
The Etiwanda School District’s spokesman, David Oates told the Sentinel that Jensen’s suggestion that the 2022 expansion of the CLOUDS program to include in its classes transitional kindergarten students and move from a venue of 10 classrooms to 13 classrooms was driven by financial considerations and specifically to bring more money into the district were untrue.
“Ms. Jensen’s accounts are incorrect,” Oates said. “In fact, no funding for the program changed.”
Oates claimed the district “does not receive any concentration grant money.”
Oates insisted that the district’s 2022 expansion of CLOUDS classes did not overtax resources or represent an unmanageable, unacceptable, or counterproductive change to the program.“We had a net increase of three classes districtwide, because we already had 10 classes at our preschool cluster sites – three at Falcon Ridge, three at Grapeland, and four at East Heritage.”
The 2022 transformation of the CLOUDS program to include transitional kindergarten-aged students in the program did not have a deleterious impact on the educational atmosphere in the preschool classrooms as Jensen claimed, Oates said, and Jensen’s input at the time carried no weight. Her criticisms were based on opinion, he said, which did not qualify as sound educational policy or theory.
“Ms. Jensen’s opinion is not supported,” Oates said. “In fact, the district’s state performance plan indicator for preschool outcomes increased significantly during this timeframe, indicating that the impact on the educational atmosphere was overwhelmingly positive.”
Oates took issue with Jensen’s assertion that the district’s addition of transitional kindergarten students to CLOUDS classrooms – justified as enriching the learning environment – was a pretext to obscure its true motive of bringing in more state funds. He dismissed her claim that the district inappropriately exploited unduplicated students by enrolling many of them in CLOUDS classes merely to obtain the state funding provided for placing them in a district educational program.
“This fundamentally misunderstands education policy,” Oates said of Jensen’s accusations. “Early education has been a major initiative of federal, state, and local educational leaders. The Head Start Program, the Kindergarten Readiness Act of 2010, the California Department of Education’s Transitional Kindergarten Guide, and the Universal Transitional Kindergarten Expansion Program all stress the urgency of including these students at exactly the ages we have implemented. Special education laws also stress the importance of inclusive programming.”
Oates continued, “Pre-kindergarten and transitional kindergarten admissions are not, as Ms. Jensen suggests, a fundraiser. It is the essence of the urgent drive to set students up for success by their early integration into the classroom learning environment. We ensured all students who qualified under the unduplicated students program received the services and care for which they are entitled.”
Oates explained that “the purpose of transitional kindergarten students participating in the CLOUDS Preschool class was to provide them with additional support in foundational preschool skills. The enrollment process clearly outlined this, detailing the following: ‘Preschool focuses on foundational preschool skills. Children will work on pre-academic skills such as colors, shapes, letters, and numbers, and social-emotional skills in an inclusive environment using developmentally appropriate activities that guide students to be actively involved in exploration, discovery, and play.’”
There was a degree of inexactitude, or perhaps a semantic dispute without practical distinction, in the district’s response to Jensen’s charge that it inappropriately—and possibly illegally—expanded admission criteria into the state’s Expanded Learning Opportunities Program (ELOP) and enrolled students in dual placements that, by some interpretations, are mutually exclusive. Preschools operate in separate morning and afternoon sessions. Jensen stated that transitional kindergarten students attended their legal class and were then placed in preschool classrooms for the second half of the day – creating what she called a “backwards instructional model” inconsistent with grade-level standards.
Under Education Code § 46120(b)(1)(A), Expanded Learning Opportunities Program minutes must occur before or after school and do not count toward daily instructional minutes.
Jensen’s charge against the district on that issue “is incorrect,” Oates said. “Students only attended one CLOUDS session, either morning or afternoon. These students attended their half-day transitional kindergarten class during the remaining portion of the school day. The Etiwanda School District assigns students to either the morning or afternoon, not both. Even if they were to attend both sessions, the district doesn’t get reimbursed any additional money for it.”
According to Oates, Jensen is misinterpreting the California Educational Code by implying or stating that the district is stretching the definition of an after-school program or obtaining Expanded Learning Opportunities Program reimbursement to which it is not entitled by having students who are attending both transitional kindergarten and CLOUDS sessions.
“We disagree,” Oates said. He referenced a California Department of Education posting with regard to universal prekindergarten which stated, “California launched UPK [universal prekindergarten] in the 2021–22 state budget by putting into action recommendations laid out in the California Master Plan for Early Learning and Care through a dramatic expansion of TK [transitional kindergarten] with universal access to transitional kindergarten for all four-year-old children by the 2025–26 school year and expanded access to the California State Preschool Program for income-eligible three-year-old children and children with disabilities. While universal prekindergarten relies heavily on universal transitional kindergarten and [the] California State Preschool Program, it also includes other early learning programs serving three-and four-year-old children, including the federal Head Start Program, subsidized programs that operate a preschool learning experience and are operated by community-based organizations (including family child care), and private preschool programs.”
“Families with four-year-old children can choose which pre-K program to enroll them in, but transitional kindergarten is the only option that will be universally available and free of cost for all four-year-old children, as part of California’s public education system. Part of universal prekindergarten is also the Expanded Learning Opportunities Program, which includes before-school, after-school, summer, or intersession learning programs that develop the academic, social, emotional, and physical needs of students, and provides access to a full day of programming that meets the needs of California’s working families.”
Further, according to the California Department of Education posting, “California launched universal prekindergarten in the 2021–22 state budget by putting into action recommendations laid out in the California Master Plan for Early Learning and Care through a dramatic expansion of transitional kindergarten with universal access to transitional kindergarten for all four-year-old children by the 2025–26 school year and expanded access to the California State Preschool Program for income-eligible three-year-old children and children with disabilities. While universal prekindergarten relies heavily on universal transitional kindergarten (UTK) and CSPP [the California State Preschool Program], it also includes other early learning programs serving three- and four-year-old children, including the federal Head Start Program, subsidized programs that operate a preschool learning experience and are operated by community-based organizations including family child care, and private preschool programs. Families with four-year-old children can choose which pre-k program to enroll them in, but transitional kindergarten is the only option that will be universally available, and free of cost, for all four-year-old children as part of California’s public education system.”
Oates’ citation of the California Department of Education posting clashed with the Etiwanda School District’s 2023-24 Local Control and Accountability Plan (LCAP) Annual Update, which states on page 117 that the district does not operate a California State Preschool Program (CSPP) or receive CSPP funding.
Oates said the Etiwanda School District is ahead of the curve among school districts statewide in seeking to get both preschoolers, transitional kindergarten-aged and kindergarten-aged children, into a welcoming learning environment.
“In California, kindergarten is currently optional, not mandatory, for children,” Oates said. “The state mandates school enrollment at age six, typically for first grade. That said, AB 2226 was recently passed by the California Assembly to make kindergarten mandatory, starting with the 2026-27 school year. This bill would require children to complete one year of kindergarten before entering first grade in a public school.”
Oates responded to Jensen’s charge that the district is engaged in what is tantamount to Medi-Cal fraud, addressing Jensen’s accusation that the district was tapping into money intended to redress medical issues and using bureaucratic sleight-of-hand by lumping unduplicated students in the CLOUDS program with special education students. This mixing of prekindergarten students with special education students interchangeably crossed the line from creative billing practices to an outright criminal abuse of the federal government’s generosity to the state, she said.
“The Etiwanda School District only bills Medi-Cal for students who receive its billable services, whose parents have given us written permission to do so,” said Oates.
Initially, Oates offered a relatively terse response to Jensen’s contention that the district is doing a disservice to its preschool students by having created, with the addition of transitional kindergarten students to the CLOUDS classes, an incompatible hybrid of preschool and traditional kindergarten that has diminished the educational atmosphere and scholastic setting.
“The Etiwanda School District hired three new teachers for three new classrooms, with some of the new teachers bringing experience from other local school districts,” Oates said. “As with any teacher new to the district, those teachers were provided with training and teacher induction support from the district’s professional development department.”
The district endeavored to preserve a teachable environment in the CLOUDS classrooms, Oates said, stating, “behavioral expectations were provided.
Any student who was unable to meet those expectations was dismissed from the program. In doing so, we created a positive, inclusive, and effective learning environment.”
He continued, “Ms. Jensen’s opinion is flatly wrong, is contradicted by test scores, and fundamentally misunderstands federal, state, and local educational policies,” Oates said. “These initiatives have improved the learning environment and are improving our children’s opportunities to be college and career ready. The data clearly supports that these strategies are working.”
The Sentinel thereafter pressed Oates regarding the core of Jensen’s position that the expansion of the CLOUDS program had a negative impact on classrooms by mixing special education preschool students aged 3–4, general education preschool students aged 3–4, and students at or near transitional kindergarten age. The Sentinel emphasized that Jensen’s concern was not with inclusion or student diversity but with the legal fact that, under California law, neither an early childhood special education credential nor an early childhood general education permit authorizes instruction in transitional kindergarten, which was verified by the California Commission on Teacher Credentialing.
The Sentinel asked Oates whether the district’s real motive in expanding the program was to draw in more revenue rather than to advance student learning.
Jensen, the Sentinel pointed out, raised concerns that the district’s decision to place transitional kindergarten students, who are older than and developmentally advanced over the three-year-old and four-year-old students typically served by CLOUDS, into preschool classrooms created instructional chaos. The Sentinel emphasized that it was Jensen’s sincerely held belief that this change created a hodgepodge of cognitively and developmentally diverse students that proved simply too challenging for the CLOUDS instructors to handle. The Sentinel inquired as to whether the district disagreed with Jensen’s contention that the significant maturity gap between preschoolers and transitional kindergarten students made it difficult to deliver developmentally appropriate education in the CLOUDS classroom setting. According to Jensen, this wasn’t just a logistical failure, but a legal one: transitional kindergarten is not part of preschool, and teachers without a multiple subject credential or transitional kindergarten authorization are not legally cleared to instruct transitional kindergarten students, according to the California Commission on Teacher Credentialing. The Sentinel asked for refutation of Jensen’s assertion that in undertaking this expansion, that district officials were more focused on bringing money into the district than in the scholastic advancement of the students in the CLOUDS program.
Documentation showed, the Sentinel told Oates, that Jensen objected to the expansion of the CLOUDS program in 2022, her contention being that when slightly older kindergarten students were added to the CLOUDS environment, things went awry. The Sentinel noted that as a consequence of what Jensen felt was a principled pursuit of insistence on standards she believed to be appropriate, she was ignominiously relieved of her teaching position.
Oates responded.
“Ms. Jensen may believe that requiring teachers to integrate children with learning disabilities into the classroom is challenging for the teachers,” Oates said. “However, the reality is that many children have learning disabilities, and our first priority should be the child, not the adult, who prefers a classroom where all children, including those with learning disabilities, can fully participate.” Until the 1970s, children with learning disabilities had few, if any, rights to equal access to education, and even then, they were often placed in separate classrooms. Since the 1980s, the law mandates that children with learning disabilities are to be educated in integrated classrooms in the least restrictive environment. Isolating them for the convenience of adults who would rather not teach children with special needs is clearly against the law, our policy, and our mission to empower every child. Ms. Jensen’s criticism fundamentally misunderstands the law and the policies that support it.
Oates continued, “Similarly, Ms. Jensen may believe that requiring teachers to instruct 4-year-olds is challenging, but the education policies of the United States, California, and this district acknowledge that it is even more difficult for a child to wait until they are 6 or even 5. Children benefit from a head start in education.”
“Ms. Jensen’s criticism seems to stem from the belief that integrating students with learning disabilities and 4-year-old children is unique to Etiwanda,” Oates continued. “These practices are not exclusive to our district. Integrating children with disabilities is a legal requirement. While educating 4-year-olds is not mandated by law, it is strongly encouraged. When a parent enrolls a 4-year-old child who has a disability, the district is legally prohibited from denying access to 4-year-olds with disabilities. Furthermore, it is against the law to segregate all 4-year-old students with learning disabilities into a separate classroom, even if an adult prefers not to educate them.”
“She argues that four-year-olds with learning disabilities should not be integrated into the classroom. We fundamentally disagree. Four-year-olds with disabilities deserve to be in the classroom and benefit from the opportunities that early access to education provides.”
Oates was misstating her position entirely, Jensen said. She had no objection whatsoever to the inclusion of 3-year-olds and 4-year-olds in the CLOUDS classroom settings, she said. It was the inclusion of older transitional kindergarten students – ones nearly old enough to be in Kindergarten – into the CLOUDS classrooms that was detracting from the education of those special needs students, she said.”
Jensen said the district’s notion of placing transitional kindergarten students “backwards” into preschool classrooms for so-called enrichment, despite receiving no state funding for doing so, is not just misguided, but “laughable.” “You don’t make a child repeat a grade for enrichment,” she said. “There’s no funding justification, no legal basis, and no credentialed authority to support it.” She further stated that both she and her co-teacher, a credentialed early childhood special education teacher, were assigned to teach transitional kindergarten students without holding the multiple subject credentials required by the California Commission on Teacher Credentialing. “Does Mr. Oates’ opinion supersede the Department of Credentialing?” she asked. “Because the law says we weren’t authorized to teach transitional kindergarten—yet we were forced to.”
Jensen disputed Oates’ claim that the district “does not receive any concentration grant money.”
“If there was no financial incentive, why were transitional kindergarten students, already counted for attendance in their transitional kindergarten classrooms, placed backwards into preschool, taught below grade level by staff not credentialed to teach transitional kindergarten in violation of state credentialing laws?” she asked.
“Let’s stop dancing around it,” Jensen said. “From 2022 to 2024, the Etiwanda School District placed transitional kindergarten students into preschool classrooms during the school day, misclassified them as preschoolers, collected enrichment funding, and called it legal. That’s false. This wasn’t ‘interpretation’ or ‘innovation.’ It was a direct violation of California education law.”
“Here are the facts: Fact one, preschool programs cannot generate transitional kindergarten funding,” she said. She referenced a direct statement from the California Department of Education’s fiscal briefing, which says, “Preschool programs are not eligible to generate funding for transitional kindergarten programs. transitional kindergarten funding is based on average daily attendance.”
Jensen intoned, “Yet the district placed transitional kindergarten students into CLOUDS preschool classrooms and still claimed transitional kindergarten attendance, but required separate attendance sheets outside of the school’s official reporting system.”
She went on. “Fact two: Expanded Learning Program funding cannot be used during the school day.” She cited the California Education Code § 46120(b)(1), which states, “Expanded Learning Program funding shall be expended… before or after school, not during the school day.” Despite that restriction, she said, “Yet the district openly stated in its own program overview that transitional kindergarten students were placed into preschool classrooms during the school day under a so-called ‘mixed delivery enrichment model’ — effectively placing them in a lower grade for backwards instruction.”
She next quoted Nicholas Newman, of the Commission on Teacher Credentialing, in citing “Fact three: Transitional kindergarten must be taught by a fully credentialed teacher.” She offered Newman’s quote, which reads, “Transitional Kindergarten is not considered a preschool program and any teacher in a transitional Kindergarten teaching position must have a full teaching credential.”
Jensen said, “All CLOUDS classrooms were staffed with permit-only early childhood educators, and early childhood special education teachers, not the multi-subject credentialed teachers the law requires. The CLOUDS program wasn’t expanded due to educational necessity—it was expanded too quickly and illegally to house transitional kindergarten students. It happened so fast that there were no changing tables and special education students had to stand for diaper changes. There was no transitional kindergarten curriculum, no credentialed transitional kindergarten teachers – just exhausted early childhood educators juggling three age groups in a special education inclusion class: preschool special ed, preschool general ed, and transitional kindergarten—violating Americans with Disabilities Act rights and credentialing law. Based on California Education Code § 48000 and the Commission on Teacher Credentialing, transitional kindergarten must be taught by a teacher with a multiple subject credential. The CLOUDS program used early childhood special ed teachers and early childhood education permit holders—none credentialed for transitional kindergarten under state law.”