1 Early Intervention Monitoring Wyoming DDD April 2008 Training

2 Background

3 Why revise the GSS? To ensure implementation of IDEA To identify and correct noncompliance in a timely manner To facilitate program improvement To improve results and functional outcomes for children and families

4 Key Principles 1.Limited indicators; consistently used and closely aligned with results for children/families 2.Data used throughout the year to identify emerging issues; preventative TA 3.Data system responds to most indicators; other data sources as needed

5 Key Principles 4.Annual off-site analysis for all programs 5.Monitoring data used for APR 6.Onsite conducted with programs in greatest need 7.Quarterly activities ensure timely, accurate data

6 Stakeholder Process Initial stakeholder meeting – April 2007 Local perspectives Review and feedback on materials Pilot monitoring process

7 Components of GSS

8 1.State Performance Plan/Annual Performance Report (SPP/APR) 2.Indicators for Monitoring Regional Programs 3.Wyoming Part C Rules 4.Wyoming Part C Policies and Procedures

9 Components of GSS 5.Interagency Agreements 6.Contracts with Regional Programs 7.Complaints/Dispute Resolution System 8.Off-site and onsite monitoring activities

10 Components of GSS 9.Training and TA System 10.Corrective Action Plans 11.Incentives and Sanctions

11 Indicator Measurement Tool

12 Indicator Measurement Table Indicators for Monitoring Regional Programs 1-10 come from SPP/APR requirements come from stakeholder group discussion of priority indicators for WY DDD

13 Indicator Measurement Table Timely Services Natural Environments Child Outcomes Family Outcomes 0-1 Child ID 0-3 Child ID 45 day timeline Transition Timely correction of noncompliance Timely submission of Data

14 Indicator Measurement Table - Indicators Quality Evaluation/ Assessment Procedure Safeguards IFSP Service Provision Timely IFSP Meetings Quality IFSPs Developmental Status on IFSPs Clinical Opinion Qualified Personnel

15 Indicator Measurement Table – Data Sources 618 Data Data System Reports Annual Self Assessment CAP Tracking Log COSF data Previous Monitoring Reports Data and Reports Submission Tracking Log Personnel Report Family Survey Data

16 Indicator Measurement Table - Format Indicators Data Sources Measurement Target

17 Indicator Measurement Table – Use of Data To report on the SPP/APR To identify low performance and noncompliance To trigger the development of CAPs To make status determinations To select programs for onsite visits

18 Data System

19 Data Procedures Programs establish data procedures, e.g. –data entry person and responsibilities –data accuracy/reliability process –process to respond to Request for Data Clarification –process for using data reports to identify issues, determine training/TA needs, track

20 Data Entry Data entry expectations –Child-specific IFSP data by the 10 th of each month –COSF data 30 days following completion of COSF form

21 Data Verification Data verification –Check data for completeness and accuracy –Correct data as necessary –Make records available during onsite visits –Submit copies of IFSPs, COSFs

22 Report Generation Quarterly to review data entry for accuracy and reliability Quarterly to identify potential issues that may require training and/or TA Ongoing for tracking progress in improving performance and noncompliance

23 Annual Self Assessment

24 Annual Self Assessment –Timely services (#1) –Transition steps and conference (#8a, #8c) –Evaluation/ assessment in all areas (#11b) –Procedural safeguards (#12a, #12b) –Services provided by qualified personnel (#13a, #13b) –Measurable, functional IFSP (#15a-d) –Clinical Opinion (#17) Data for some, not all, indicators:

25 Annual Self Assessment State disseminates in May each year and provides training and TA Regional programs review 10% or 10 records (whichever is more) identified by state Programs submit to state by June 30 th

26 Quarterly Self Assessment Quarterly record reviews using self- assessment items Random selection of child records provided by the state (10% or 10 records) Submitted to the state and used to identify emerging issues for training and TA

27 Off-site and Onsite Monitoring Activities

28 Off-site Monitoring To monitor all programs annually To identify emerging issues and plan TA To verify data To track progress

29 Annual Desk Audit Conducted in July and August each year Allows monitoring of all regions annually without going onsite State issues a ‘Report Card’ to each region re: their performance on the indicators; requires confirmation of data

30 Annual Desk Audit Data system reports 618 data Annual Self Assessment data Family survey data COSF data Complaints and dispute data Previous monitoring reports Previous CAPs Personnel Report CAP Tracking Log Data and Report Submission Log

31 Annual Desk Audit The state uses the data to: –Identify noncompliance (and possible CAPs) –Make status determinations –Select sites for onsite monitoring –Notify programs of findings and decisions –Respond to the SPP/APR due in February

32 Identification of Noncompliance and Low Performance Noncompliance –Compliance Indicators –100% target –‘finding’ requires CAP –Correction of noncompliance within 1 year –Tracking correction and reporting in SPP/APR

33 Identification of Noncompliance and Low Performance Noncompliance –Individual child instances are not a ‘finding’ and do not require CAP. However, the program is still required to correct these instances and report the correction.

34 Identification of Noncompliance and Low Performance Low performance –Performance Indicators –Target set by stakeholders –Substantially less than the state target requires a CAP

35 Status Determinations Data analysis from Desk Audit Four Status Determination Categories: –Meets Requirements –Needs Assistance –Needs Intervention –Needs Substantial Intervention

36 Onsite Selection 3 regional programs per year –2 based on greatest need –1 randomly selected All regions receive an onsite within a 5 year period

37 Notification Letter State notifies region in writing re: –Noncompliance –Need for CAP –Status determination category –Onsite selection

38 Ongoing, Preventative Activities Quarterly record reviews Quarterly conference calls and/or meetings to discuss data Specific TA, as needed, statewide or region-specific

39 Other Off-site Activities Reviewing and approving CAPs Tracking progress and correcting noncompliance Providing TA and training Releasing programs from noncompliance Providing rewards and sanctions

40 Onsite Monitoring Programs in greatest need To determine the underlying reasons that contribute to noncompliance and/or low performance

41 Onsite Visit Preparation Initial Conference Call Selection of Onsite Review Team Onsite Review Team Orientation/Training Data Analysis Selection of Root Cause Analysis Tools Onsite Visit Planning Calls Onsite Review Team Assignments

42 Conducting Onsite Visits Entrance Meeting Data Collection Data Verification Analyses of Data Collected Onsite Reporting Results Planning targeted TA Issuing a Findings Report

43 Pilot Onsite Visits Regions share experiences with onsite monitoring process –General comments about how it went –Advice to other regions

44 Monitoring Team Invite input regarding the Monitoring Team –Who is the team? –How can individuals become part of the team? –What is the selection process? Application process? –What is the training process?

45 End of Day 1

46 Developing Corrective Action Plans

47 Development of CAPs Findings of noncompliance and low performance require the development of a CAP  Remember: Noncompliance must be corrected within 1 year of identification (in writing)

48 Steps related to CAPs: Desk Audit Review findings of noncompliance, areas of low performance and evidence of change expectations provided by the state Convene a team of knowledgeable staff/ providers to conduct root cause analysis Identify improvement activities

49 CAP Root Cause Areas Corrective Action StrategiesResponsibleTimeline Policy & Procedures Funds T & TA Supervision Personnel Practices

50 Steps related to CAPs Request TA, as needed, related to root cause analysis, meaningful strategies, etc. Submit CAP within 30 days of written identification Modify CAP, if necessary, to meet state approval Receive targeted TA

51 Steps related to CAPs Collect and submit CAP data according to timelines Review progress data and modify CAP, if necessary Use TA, as needed, to implement CAP Review written notification of release from CAP

52 Developing a good CAP Scenario Activity

53 CAP Checklist Designed for reviewing CAP to assure plan can serve its intended purpose of guiding needed systems change and fostering continuous improvement

54 Tracking Progress CAP Tracking Log One year deadline for timely correction State may impose changes to CAP State may impose targeted TA State will release from CAP when corrected

55 Training and Technical Assistance

56 Training and TA Review quarterly data reports with state to identify training and TA needs Attend/access statewide training and TA Request and access regional training and TA

57 Incentives and Sanctions Incentives, e.g. public recognition Enforcement actions, e.g. –Directing use of funds to correct noncompliance –Imposing special conditions on the contract –Denying or recouping payment for services for which noncompliance is documented –Terminating or not renewing the contract

58 Disputes and Complaints Regional programs try to resolve complaints or disputes informally Now required to track informal complaints/disputes Informal Complaint Tracking Log is submitted to the state annually with contract Tracking informal complaints will help with program improvement

59 Meeting Federal Requirements

60 Federal Requirements OSEP requirements for monitoring APR indicators and WY priority indicators Reporting to the public

61 Status Determinations 1.Meets Requirements 2.Needs Assistance 3.Needs Intervention 4.Needs Substantial Intervention

62 Meets Requirements Demonstrates substantial compliance (95%) on all compliance indicators (Indicators 1, 7 and 8) All indicators, including performance indicators, have valid and reliable data (actual target data, baseline data, etc.) Timely correction of noncompliance identified through monitoring or other means (Indicator 9)

63 Needs Assistance Not demonstrating substantial compliance (95%) on one or more of compliance indicators (Indicators 1, 7, and 8) One or more indicators, including performance indicators, do not have valid and reliable data (actual target data, baseline data, etc.) Not demonstrating timely correction of noncompliance (Indicator 9)

64 Needs Assistance 2 consecutive years in needs assistance –Advise of available sources of technical assistance –Direct use of funds –Identify as a high-risk grantee and impose special conditions on the contract.

65 Needs Intervention Not demonstrating substantial compliance (95%) on one or more of compliance indicators and not making significant progress in correcting noncompliance previously identified on those indicators One or more indicators, including performance indicators, are missing valid and reliable data and not making significant progress in correcting previously identified data problems Not demonstrating timely correction of noncompliance and not making significant progress in correcting that noncompliance

66 Needs Intervention 3 consecutive years in Needs Intervention –Require development of CAP –Require “compliance agreement” if cannot correct within one year (3 years to correct) –Withhold percentage of funds –Recover funds –Withhold future payments –Impose other enforcement actions

67 Needs Substantial Intervention The failure to substantially comply significantly affects the core requirements of the program, such as the delivery of services to children with disabilities; and/or The Regional Program has informed the State that it is unwilling to comply

68 Needs Substantial Intervention At any time – –Recover funds –Withhold further payments –Legal action such as discontinue contract –Refer matter for appropriate enforcement action

69 Contracts

70 Summary of Expectations