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GUIDANCE ON THE IDEA PART B PROGRAM REVIEW PROCESS Research to Practice July 2016 What to Expect When You are Expecting a Monitoring Team
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SUPPORTING THE MISSION AND VISION OF THE SCDE Mission The mission of the SC Department of Education is to provide leadership and support so that all public education students graduate prepared for success. Vision All students graduate prepared for success in college, career, and citizenship. By 2018, at least one school in every district will have implemented personalized learning that supports students meeting the Profile of the South Carolina Graduate. OSES supports the SCDE mission statement and vision by ensuring that all students with disabilities in SC have available a free appropriate public education (FAPE) in order to be ready for success in college, careers, and citizenship.
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PROFILE OF THE SOUTH CAROLINA GRADUATE
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OVERSIGHT AND ASSISTANCE TEAM Peter Keup, Team Lead Brenda Turner, Administrative Assistant Cheryl Fitts, Ombudsperson (informal dispute resolution) Kathleen Heiss, Program Monitor Ann Moore, Program Monitor Mary Etta Taylor, Program Monitor Dianne Bennett, TAC Lisa McCliment, TAC LaShawn Thomas-Bridges, TAC Tabitha Strickland, TAC (TAC-Technical Assistance Contact)
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SESSION AGENDA A.Explanation of the IDEA Part B program review process (including what is new for the new monitoring cycle) B.Discussion of the program review and findings of noncompliance C.Explanation of the correction process following a program review
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HANDOUTS The Compliance Seekers’ Guide to the Universe (2016-2017 Edition)
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“OLD” MONITORING CYCLE (2011-2016) IDEA Part B monitoring cycle was a 5 ½ year cycle that began in the Spring of 2011 and ended in the Spring of 2016. Five districts were reviewed in the Spring of 2011, and an average of 16 schools districts were reviewed each school year thereafter. (Several SOPs were also reviewed in 2015-2016.) For the first three school years (2010-2011, 2011-2012, and 2012- 2013), an 88 item rubric (recorded on a multi-sheet Excel document) was used to conduct IEP development reviews. The monitoring process also included a review of LEA policies and procedures, on-site interviews, and Indicator 13 reviews. At the beginning of the 2013-2014 school year, we switched to a 12 inquiry web-based form for IEP development reviews that generates spreadsheets and user-friendly summary graphs. At the beginning of the 2013-2014 school year, we added staffing reviews, electronic surveys, and IEP implementation reviews to the monitoring process to provide a more comprehensive diagnostic report for districts.
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“NEW” MONITORING CYCLE (2016-2022) Cycle will begin at the beginning of the 2016-2017 school year and end at the end of the 2021-2022 school year. Each school year we will review 15 LEAs/SOPs. As with previous cycle, the subset of students reviewed will vary depending on district size. Monitoring activities will continue to include reviews of policies, staffing, IEP development, IEP implementation, interviews, and electronic surveys. Indicator 13 reviews will be removed from the process and performed separately (see Indicator 13 proposal).
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2016-2017 SCHEDULE LEA NameDate of VisitLead Monitor CalhounSeptember 6-8Mary Etta Taylor NewberrySeptember 20-22Ann Moore Spartanburg 2October 4-6Kathleen Heiss Florence 4October 17-19Mary Etta Taylor Florence 3November 2-4Mary Etta Taylor SCSDBNovember 15-17Ann Moore York 3/Rock HillDecember 5-8Kathleen Heiss Richland OneJanuary 9-12Ann Moore
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2016-2017 SCHEDULE (CONTINUED) LEA NameDate of VisitLead Monitor SaludaJanuary 24-26Mary Etta Taylor MarlboroFebruary 7-9Kathleen Heiss ChesterFebruary 21-23Ann Moore AikenMarch 6-9Mary Etta Taylor Anderson 4March 21-23Kathleen Heiss Greenwood 51April 4-6Ann Moore Bamberg 2April 18-20Kathleen Heiss
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OSES IDEA PART B PROGRAM REVIEW PROCESS Data/Info Collection Policy Review Surveys On-Site Visit Findings (Report) Technical Assistance and Support Systemic and Individual Student Corrections SEA Verification
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COMPONENTS OF THE REVIEW 1.Policies and Procedures 2.Staffing 3.IEP Development 4.IEP Implementation
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REVIEW OF LEA/SOP POLICIES AND PROCEDURES Under the regulatory provisions of the Individuals with Disabilities Education Act, Part B (IDEA-B), to be eligible for funds the LEA/SOP must, among many things, demonstrate to the satisfaction of the State Education Agency (SEA) that it meets the conditions in §§300.101 through 300.163, and §§300.165-300.174. As set forth in §300.201, LEAs are required to have in effect policies, procedures, and programs that are consistent with the State policies and procedures established under §§ 300.101 through 300.163, and §§300.165-300.174.
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INITIAL LEA/SOP SUBMISSION LEA/SOP policies, procedures, and forms, DUE SEPTEMBER 16, 2016 See Compliance Seekers’ Guide – 2 & 3
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SECOND LEA SUBMISSION Required information: LEA Special Education Staffing Spreadsheet Student Information Spreadsheet E-mail lists for general education teachers & parents The second submission is due 30 days prior to your scheduled on-site visit See Compliance Seekers’ Guide – 4-8
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ON-SITE MONITORING ACTIVITIES On- Site Event Record Review/IEP Development Notices Forms IEPs Interviews SE TeachersSchool Site Administrators Parents School Site IEP Implementation Review Progress ReportingService Provision/Instructional Delivery/LREAccommodations/BIPs
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REVIEW OF RECORDS STUDENT SELECTION Subset of 35 to 50 students (depending on district size) that includes students who, in the past year, have: Transitioned from Part C to B Received an initial evaluation Been removed from school more than 10 days or placed at an alternative placement Revoked consent for services
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STUDENT SELECTION (CONTINUED) A broad range of students will be selected to cover: Different grade levels (PK, ES, MS, HS) Different eligibility categories Different LRE status (80-100%, 40-79%, 0-39%) Different schools & settings
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STUDENTS’ RECORDS FOR IMPLEMENTATION For the school visit, the LEA/SOP must make the following records available with the file to the monitoring team for each student selected: 1.Complete special education file 2.Attendance records for past year 3.Current class schedule 4.Evidence of service provision (for current school year) Service logs Special education teacher/service provider schedules 5.Incident management reports from PowerSchool 6.Progress Reports See Compliance Seekers’ Guide - 9
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ON-SITE AGENDAS All on-site monitoring visits will include record reviews, interviews, and school visits. Depending on the size of the LEA/SOP 2 1/2 day visit (small/medium) 3 1/2 day visit (large) See Compliance Seekers’ Guide – 10 & 11
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LEA/SOP PRESENTATION LEA/SOP provides an overview (max. 30 min.) to OSES and LEA/SOP staff that addresses: Overall and SWD Population Profile Data-based Decisions Administrative Structure and Staffing Internal Monitoring/Quality Assurance Specific Programs and Initiatives Staff Development/Professional Learning Opportunities See Compliance Seekers’ Guide – 12
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IEP DEVELOPMENT REVIEWS IEP development reviews are guided by the Monitoring Overview and Rubric (MOR) The MOR, and the data collection rubric used to collect the data, are organized into twelve inquiries. The MOR provides a detailed list of the relevant IDEA provisions and regulations. It also lists the documents that will be reviewed for each inquiry. See Compliance Seekers’ Guide – 13 & 14
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INQUIRIES 1.Did the LEA/SOP take the required steps to ensure that the parents could meaningfully participate in the IEP process, and did the LEA/SOP obtain parent consent when necessary? 2.Did the LEA/SOP ensure that necessary parties were invited to and/or participated in the IEP process? 3.Did the LEA/SOP adhere to required time lines and procedures, including those for initial evaluations and reevaluations? 4.Did the IEP team appropriately consider all relevant special factors?
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INQUIRIES 5.Did the IEP team develop an appropriate statement of present levels of academic achievement and functional performance? 6.Did the IEP team develop appropriate, measurable annual goals and designate how and when the goals would be measured and progress reported to parents? 7.Did the IEP team appropriately develop: measurable post- secondary goals; a statement of transition services; course of study; and, when appropriate, a notice to the student and parents of the transfer of rights?
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INQUIRIES 8.Did the IEP team appropriately identify in the IEP: special education and related services, supplementary services, testing participation, and classroom and testing accommodations and modifications? 9.Did the IEP team appropriately explain the extent to which the student will not participate in general education classes and activities, and the IEP team's decisions with respect to least restrictive environment (LRE)? 10.Did the IEP team appropriately consider the need for extended school year services (ESY)?
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INQUIRIES 11.Did the LEA/SOP provide appropriate notice (PWN) to the parents in a reasonable time before changing, or refusing to change, the student's eligibility, evaluation, program, or placement? 12.If there was disciplinary action that involved a potential change in placement for the student, did the LEA/SOP follow the applicable procedures?
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INTERVIEWS AND SURVEYS General Education Teacher Survey (online) Parent Survey (online) Focus Group Interviews During On-Site Visit School Site Administrators Special Education Teachers Parents of Students with Disabilities See Compliance Seekers’ Guide – 7 & 8
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IEP IMPLEMENTATION Members of the monitoring team will: review individual student records (e.g., teacher and student schedules, attendance and discipline records, progress reports, services logs, etc.) visit schools to determine if IEPs are being implemented as written See Compliance Seekers’ Guide – 15
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IEP IMPLEMENTATION INQUIRIES 1.Is there evidence that the LEA/SOP is providing specialized instruction and related services as delineated in the student's IEP? 2.Is the LEA/SOP providing appropriate reports to parents on the student's progress towards meeting IEP goals with the frequency set forth in the IEP? 3.Is the student participating in educational activities with non- disabled peers for the amount of time designated in the IEP? 4.Is there evidence that the student's teachers received notice of, and have a system in place to implement, the accommodations listed on the IEP? 5.Is there evidence that the school site administrators and the student's teachers are familiar with, and are prepared to utilize when necessary, the student's behavioral intervention plan (BIP)?
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SWDS IN ALTERNATIVE PLACEMENTS LEAs are to ensure the following materials are included for the monitoring visit with respect to students who are placed in alternative programs/schools or placements (e.g., homebound or homebased): Policies and procedures relating to placement of students in, and out of, alternative placements or programs Policies and procedures that address behavior of students in alternative placements or programs Instructional and service schedules for selected students See Compliance Seekers’ Guide – 2 & 6
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SWDS IN DETENTION CENTERS If an LEA has one or more detention centers within its boundaries, the LEA must provide the following materials with respect to students with IEPs who are placed in the detention center(s) : Policies and procedures relating to identification/notification of students with disabilities in the detention center(s) and the provision of special education services to such students Evidence of service provision for selected students See Compliance Seekers’ Guide – 2 & 6
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RESULTS NOTIFICATION (FINDINGS PACKET) Letter to Director (and copied to Superintendent) with findings of noncompliance identified along with commendations, concerns, and recommendations The letter will include the following sections: General commendations and concerns Discussion and findings related to policies and procedures Discussion and findings related to staffing Summary of IEP development reviews and findings Summary of IEP implementation reviews and findings Summary of interview and survey data Corrections and verification description and timeline
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RESULTS NOTIFICATION (CONTINUED) The Director is provided with the links to: IEP Development Shared Report IEP Implementation Shared Report In addition, the following documents are sent electronically to the Director: Parent Survey Results General Education Teacher Survey Results LEA/SOP Corrective Action Summary Corrections and Ongoing Improvement Plan (COIP) Template LEA/SOP Corrective Action Form Link to Student Correction Form See Compliance Seekers’ Guide 16 – 18
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CORRECTING FINDINGS OF NONCOMPLIANCE LEA/SOP submits a Corrections and Ongoing Improvement Plan (COIP) (See Compliance Seekers’ Guide – 16) Prong 1 LEA/SOP submits evidence of completion of individual student corrections, and the OSES verifies that the corrections have been completed. LEA/SOP submits evidence of systemic corrective actions (e.g., policy and procedure changes, professional learning opportunities, technical assistance, etc.), and OSES verifies that corrective actions have been completed. Prong 2 OSES reviews records for a new, smaller subset of students (with recent/post PLO IEPs) to determine whether those systemic issues identified by the OSES have been effectively addressed. LEA/SOP corrects any continuing systemic issues or individual findings from Prong 2 review.
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CORRECTION TIMELINES Individual student corrections and LEA/SOP corrections for Prong 1 must be made within eight (8) months of the issuance of the findings packet to allow time for verification and Prong 2. All corrections, including systemic corrective actions and verification through Prong 2, must be completed as soon as possible but no later than one year from the date of the findings letter.
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OSES SUPPORT Technical Assistance & Professional Learning Opportunities (PLOs) Provided by OSES staff Brokered by OSES staff Webinars & Online Meetings OSES Special Education Leadership Meetings Research to Practice (RtP) Links & connections to other organizations, LEAs, SOPs & providers
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IF YOU HAVE QUESTIONS, PLEASE CONTACT US The Lead Monitor designated for your LEA/SOP: Kathleen Heiss kheiss@ed.sc.gov (803) 734-8061 Ann Moore acmoore@ed.sc.gov (803) 734-8806 Mary Etta Taylor metaylor@ed.sc.gov (803) 734-0705
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