1. Part C State Performance Plan/Annual Performance Report: 1820-0578
Revisions and Proposed Final Language to SPP/APR Package: Information Collection
Part C State Performance Plan/Annual Performance Report:

2. Agenda Purpose Process Package Documents
Revisions and Proposed Final Language
Questions
As you can see, we want to highlight a few areas regarding the Information Collection:
An Overview of Information Collection: Purpose and Package Documents
Proposed Revisions to the Part C SPP/APR; and
We are reserving time at the end of the presentation for questions, so please take note of any questions you have along the way

3. Purpose The proposed revisions to the SPP/APR focus on:
Aligning the SPP/APR with the vision and goals of OSEP’s results driven accountability system
Further clarifying existing reporting within the parameters of the current IDEA statutory and regulatory requirements.
The SPP/APR IC was originally approved in 2005, and was reapproved most recently in 2014, when the SPP/APR information collection for FFY through FFY 2018 was revised to align with the vision and goals of OSEP’s Results-driven accountability system, or RDA.
With this request, the Department is proposing to make minor revisions to the previously- approved information collection.
The proposed revisions to the SPP/APR are focused on further clarifying existing reporting within the parameters of the current IDEA statutory and regulatory requirements.
These revisions will go into effect with States’ FFY 2016 SPP/APR, to be submitted in February 2018.

4. Process
Proposed revisions submitted for a 60 day comment period (Closed: May 8, 2017).
Received and considered 147 comments representing States, national membership organizations, advocacy organizations, and individuals.
Proposal final package was submitted for a 30 day comment period (Closed: June 29, 2017).
OSEP reviews comments and finalizes in partnership with the Office of Management and Budget.
New SPP/APR package goes into effect with FFY 2016 SPP/APR, to be submitted in February 2018.

5. Key Package Documents Measurement Table SPP/APR General Instructions
Supporting Statement (first submission)
Explanation and Rationale (first submission)
Response to Comments (second submission)
This slide lists the key documents contained in the SPP/APR Information Collection:
The Measurement Table
SPP/APR General Instructions
Supporting Statement- a set of questions with required responses related to public burden
Explanation and Rationale- document providing the public with a concise and accessible explanation and rationale of the proposed revisions to the SPP/APR packages
Response to Comments

6. Part C SPP/APR Revisions and Proposed Final Language

7. Indicator 3- Early Childhood Outcomes
Proposed Revision:
Revise the instructions to:
explicitly require that only infants and toddlers who received early intervention services for at least six months before exiting Part C be included in the measurement
require that States report: (1) the number of infants and toddlers who exited the Part C program during the reporting period, as reported in the State’s Part C exiting data under Section 618 of the IDEA (these data would be pre-populated into GRADS); and (2) the number of those infants and toddlers who did not receive early intervention services for at least six months before exiting the Part C program.
This indicator is revised to explicitly require that only infants and toddlers who received early intervention services for at least six months before exiting Part C be included in the measurement.
This revision, requested by Part C Coordinators, will enable the Department to better evaluate the extent to which States are providing complete data for this indicator.
The final revision to indicator 3 would require States to report:
(1) the number of infants and toddlers who exited the Part C program during the reporting period, as reported in the State’s Part C exiting data under Section 618 of the IDEA (these data would be pre-populated into GRADS); and
(2) the number of those infants and toddlers who did not receive early intervention services for at least six months before exiting the Part C program.

8. Indicator 3 – Early Childhood Outcomes
Comments:
Some States may need to revise their data collection and reporting and will need additional time.
Give States the option to report these data in the FFY 2016 SPP/APR, due February 2018, and only require that all States report these data in the FFY 2017 SPP/APR, due February 2019.
OSEP recognizes the timeline concerns expressed by commenters and is adjusting the timeline for reporting on this requirement to permit States to have the option to report, with the FFY 2016 SPP/APR due in February 2018, the data on the number of children who exited before receiving six months of service, and to require that all States report this data with the FFY 2017 SPP/APR submission, due in February 2019.

9. Indicator 3 – Early Childhood Outcomes
Proposed Final:
“States have the option to report, with the FFY 2016 SPP/APR due February 2018, the data on the number of infants and toddlers who did not receive early intervention services for at least six months before exiting the Part C program. States must report this data starting with the FFY 2017 SPP/APR submission, due February 2019.”
The measurement table instructions were revised to include this language

10. Indicator 4 – Family Outcomes
States report on the extent to which the response data (i.e., data regarding the demographics of the respondents) for these indicators are representative of the demographics of the State.
Proposed Final: Instructions are revised to suggest that States consider providing more detailed information about the State’s effectiveness in collecting data that are representative of the demographics of infants and toddlers and families who receive EIS.
Comment: Several commenters expressed concern that OSEP is expanding the requirements related to reporting on data representativeness. Specifically, the commenters cited that reporting on demographic categories and on the number of families to whom surveys were distributed is unnecessary and burdensome. Additionally, commenters did not support the inclusion of instructions on addressing non-representative data.
Discussion: The current measurement table requires States to report on the extent to which the response data (i.e., data regarding the demographics of the respondents) for this indicator are representative. As part of its response to a State’s SPP/APR, where the State has not addressed representativeness or has reported that the response data were not representative, the Department has required the State to report, as part of the next year’s SPP/APR, whether the following year’s data are from a response group representative of the population, and, if not, the actions the State is taking to address this issue.
The instructions are revised to suggest, not require, that States consider providing more detailed information about the State’s effectiveness in collecting data that are representative of the demographics of infants and toddlers and families who receive EIS, including disaggregation by race or ethnicity, age of the infant or toddlers, and geographic location. In addition, the Department proposes requiring States that have not addressed representativeness or have reported that the response data were not representative to include strategies for improving the representativeness of the data in the current year’s SPP/APR, rather than next year’s SPP/APR, to increase the timeliness of the State’s development and implementation of such strategies.
Changes: None.

11. Indicator 4 – Family Outcomes
Proposed Final:
Require States that have not addressed representativeness or have reported that the response data were not representative to include strategies for improving the representativeness of the data in the current year’s SPP/APR, rather than next year’s SPP/APR.
(Family Outcomes Continued)
For States that have not addressed representativeness or have reported that the data are not representative: The Department proposes requiring States to include strategies for improving the representativeness of the data in the current year’s SPP/APR, rather than next year’s SPP/APR, to increase the timeliness of the State’s development and implementation of such strategies.

12. Indicators 5 and 6
Proposed Final: Remove “compared to national data” as part of the measurement itself, as the percentage reported by States only reflects the other components of the measurement.
This language will continue to be reflected in the instructions, as States should provide a description of how the State data compare to the national average.
The instructions are revised to suggest, not require, that States consider providing more detailed information about the State’s effectiveness in collecting data that are representative of the demographics of infants and toddlers and families who receive EIS, including disaggregation by race or ethnicity, age of the infant or toddlers, and geographic location. In addition, the Department proposes requiring States that have not addressed representativeness or have reported that the response data were not representative to include strategies for improving the representativeness of the data in the current year’s SPP/APR, rather than next year’s SPP/APR, to increase the timeliness of the State’s development and implementation of such strategies.

13. Indicator 8C Early Childhood Transition Conference
Proposed Final:
The instructions for this indicator are revised to clarify the measurement is intended to capture those children for whom a transition conference must be held within the required timeline and, as such, only children between 2 years 3 months and age 3 should be included in the denominator.
The instructions for the Early Childhood Transition indicator were revised to clarify the measurement is intended to capture those children for whom a transition conference must be held within the required timeline. Many States have a transition conference for all children exiting their Part C program however, only children between 2 years 3 months and age 3 should be included in the denominator.
Comment: One commenter suggested that any changes to 8C should have an implementation date beginning with the FFY 2017 SPP/APR, due February 2019, because States have already collected data for the FFY 2016 SPP/APR, due February 2018.
Discussion: The proposed instructions for this results indicator were revised to clarify that the measurement is intended to capture those children for whom a transition conference must be held within the required statutory timeline and, as such, only children between 2 years 3 months and age 3 should be included in the denominator. This is a longstanding statutory requirement that many States have been required to implement since it was codified in the 2011 regulations. We do not agree that this clarification warrants delayed implementation.
Changes: None.

14. Compliance Indicators (1, 7, 8A, 8B, 8C)
Proposed Revision:
Revise the instructions to include: “If the State’s data for this indicator for the previous reporting period (e.g., for the FFY 2016 SPP/APR, the data for FFY 2015) reflected less than 100% compliance, and the State did not identify any findings of noncompliance during the previous reporting period, explain why the State did not identify any findings of noncompliance during the previous reporting period.”
Part C Compliance Indicators - “If the State’s data for this indicator for the previous reporting period (e.g., for the FFY 2016 SPP/APR, the data for FFY 2015) reflected less than 100% compliance, and the State did not identify any findings of noncompliance during the previous reporting period, explain why the State did not identify any findings of noncompliance during the previous reporting period.”
e.g. if the local EI program was able to make corrections before the finding was issued, that should be explicitly stated in the APR.

15. Compliance Indicators (1, 7, 8A, 8B, 8C)
Comment:
Request for clarification of the expectation that States report on the status of findings of noncompliance when the previous year’s data is below 100%. Specifically, the commenter indicated that the paragraph is confusing as written.
We agree that the proposed language regarding reporting on the status of findings of noncompliance could be rephrased to more clearly convey the intent.

16. Compliance Indicators (1,7, 8A, 8B, 8C)
Proposed Final:
The measurement table instructions were revised to reflect the following language: “If the State reported less than 100% compliance for the previous reporting period (e.g. for the FFY 2016 SPP/APR, the data for FFY 2015), and the State did not identify any findings of noncompliance, provide an explanation of why the State did not identify any findings of noncompliance.”

17. Indicator C-11 State Systemic Improvement Plan
Proposed Revision:
Revise the instructions to further clarify the content that States must report during their Phase III submissions, which are in effect until the end of this Part C SPP/APR period (i.e., FFY 2018 submission due February 2020).
The SSIP changes will be discussed further in a subsequent session. However, we would like to highlight a few responses to the comments received.
Comment:
OSEP should not require that information submitted as part of Phase I or II of the SSIP be repeated again in Phase III of the SSIP unless outcomes, strategies, and/or practices have been added or changed.
Proposed Final:
Language has been added to clarify that Phase III should only include information from Phase I or Phase II if changes or revisions are being made by the State and/or if information previously required in Phase I or Phase II was not reported.
Comments:
the proposed language in Section C “Stakeholder Engagement” should be removed. States have already provided information regarding stakeholder engagement in previous submissions and the requirement, as currently written, is sufficient.
the proposed language should be modified to only require information regarding stakeholder engagement if there are changes to the State’s plan
“The State must describe the specific strategies implemented to engage stakeholders in key improvement efforts and how the State addressed concerns, if any, raised by stakeholders through its engagement activities.”

18. SPP/APR General Instructions
Comments:
Support for maintaining the requirement in the current instructions, approved by OMB in 2012, that States must include an explanation of slippage in indicators where the State did not meet its target.
Proposed Final:
The General Instructions document language has been revised to require that States’ SPPs/APRs include “the reasons for slippage” as we believe this more accurately captures the intent to conduct an initial analysis of the data for possible reasons for slippage.

19. Questions ?