Procedural Compliance Self- Assessment Webcast Section 5: Correcting Noncompliance and Systems of Internal Control

Each public agency must correct all errors identified during the self-assessment. All corrections must be completed  As soon as possible, and  No later than one year from the date WDPI notifies the district of noncompliance. Individual student corrections must be completed by February 15 when the assurance is due to DPI. Correcting Noncompliance May, 2013

Correcting noncompliance is a two-step process:  Step One: Correcting student-level noncompliance.  Step Two: Taking actions to ensure current compliance with the requirements and implementing a system of internal controls. Correcting Noncompliance May, 2013

For each instance of student-level noncompliance, implement the corrective actions specified in its Self- Assessment Report (also in Standards and Directions document). Corrective actions for student-level noncompliance are prescribed. Maintain documentation of all corrective actions. Step One: Correcting Student-Level Noncompliance May, 2013

ItemCompliance Statement Standards and DirectionsCorrection EVAL-1. The student’s parents were contacted and afforded an opportunity to participate in the review of existing evaluation data. 34 CFR § (a), (a)(1) Wis. Stats., § (2)(b)1 Indicator 8 After a parent is notified in writing of the start of an initial evaluation or reevaluation, IEP team members must review existing data to determine what additional data are needed, if any. The student’s parents, as members of the IEP team, must have the opportunity to participate in this review. After the review is complete the LEA must either notify the parent no additional assessments are needed or request parental consent for additional assessment. This requirement has three components: The review of existing data must occur afterthe parent is notified in writing of the start of an evaluation (IE-1 or RE-1). The date and method of the parent’s input must be documented. This information is often located on the Worksheet for Consideration of Existing Data (EW-1). The review of existing data must occur on or before the date on the form requesting parental consent for additional assessment or the notice no additional assessments are needed (IE-2, IE-3, RE-4, or RE-5). * * Student-level Noncompliance: If the parent was not afforded an opportunity to participate in the review of existing data, review evaluation data with the parent and determine whether additional evaluation data were needed at the time of the evaluation. If additional data were needed, decide whether a reevaluation is warranted at this time. Document the results of the discussion with the parent and the decision reached. If the parent was afforded an opportunity to participate in the review of existing data, but the review occurred before the parent was notified in writing of the start of the evaluation, no student-level corrective action is required. There must be evidence of the parent’s participation. The department will verify correction of student-.level noncompliance * * Evaluation Sample

Each public agency must take actions to ensure current compliance and implement a system of internal controls. Public agencies may choose from a menu of possible corrective actions. Examples include revising policies, procedures, or forms; training staff; or adding resources. Maintain documentation of all corrective actions. Step Two: Actions to Ensure Current Compliance May, 2013

An ongoing process for identifying noncompliance after completion of the Self-Assessment. System is both preventative and detective. Components of an effective system:  Infrastructure  Ongoing training on compliance standards  Consistent use of tools/techniques throughout the public agency. System of Internal Controls May, 2013

Step One: To verify correction of student-level noncompliance, WDPI reviews corrected student records and other documentation of correction for all areas for which noncompliance was identified. If any student records are not corrected, WDPI will provide technical assistance and direct the public agency to correct the student record(s). WDPI will review additional student records until correction is demonstrated. WDPI Verification of Correction May, 2013

Step Two: To verify current compliance, WDPI reviews student records created after the self-assessment. If the newly-created records do not demonstrate current compliance, WDPI provides technical assistance and directs correction of this noncompliance. In addition, WDPI reviews additional records until the public agency demonstrates current compliance WDPI Verification of Correction May, 2013

More information about verification is available in a subsequent webcast. Throughout the process of correcting noncompliance, the public agency should maintain documentation of all corrective actions and systems of internal control. WDPI Verification of Correction May, 2013

Janice Duff, , Courtney Reed Jenkins, , Allison Markoski, , Marge Resan, , Paul Sherman, , Christina Spector, , Paula Volpiansky, , Patricia Williams, , Questions? 11May, 2013