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School Compliance Procedures Janet Dinnen Quality Assurance & Accountability Director Charter School Institute 1
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CSI Statutory Responsibilities o Approve and deny applications as well as to revoke, renew, or non-renew charter school contracts o Monitor the operations of Institute schools to ensure compliance with state and federal regulations 2
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School Compliance Policy o Adopted by CSI Board in 2011 o Guide for addressing and remedying situations of noncompliance before getting to non-renewal or revocation of a charter contract o Utilized by all CSI Departments Data on noncompliance roll into a school’s annual evaluation and rating by CSI schools with more than three Notices of Concern in a year may have their rating lowered Performance used to determine tier of support o fewer notices = more autonomy o more notices = heightened monitoring 3
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Frequency of Notices On average, schools receive 0.9 Notice of Concern per year Over the last 3 years, 2 Notices of Breach have been issued in total Over the last 3 years, 1 Charter Review has been issued 4
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School Compliance Policy (2015) 5 Notice of Concern Noncompliance with contract, rule, law, or policy Concern about academic, financial, or operational performance Notice of Breach Failure to meet Notice of Concern requirements Material breach of charter contract or applicable law More than 3 Notices of Concern within a year Situations identified under C.R.S. § 22-30.5-511 and 1 C.C.R. 302-1 Charter Review Failure to meet Notice of Breach requirements Revocation Corrective Action Notice
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6 CAN vs. NoC Decision Tree
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Compliance Process Initiated when a school is identified to be out of compliance with CSI requirements, rule, law, policy, or the charter contract While all situations of potential noncompliance will be investigated, the majority of situations do not result in a Notice of Concern The context surrounding issues of noncompliance will be reviewed and the situation will be evaluated against the following criteria 8
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Compliance Process Criteria 1.Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? 2.Does the issue impact the ability of CSI to fulfill its obligations to various stakeholders (including other schools in the portfolio and CDE)? 3.Does the issue represent a pattern of noncompliance or indicate larger systemic issues within the school? 4.Did the school fail to remedy identified issues of noncompliance from a previous Corrective Action Notice? 5.Does the issue jeopardize student and/or staff safety or represent a serious threat to the school or community? Is the response to any of the above questions a “Yes” ? 10 A Corrective Action Notice is issued A Notice of Concern is issued NO YES
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Communicating Compliance CSI staff will notify the school in writing of the area of noncompliance and provide a timeline and actions necessary to remedy the situation. The school will submit the necessary information to the appropriate CSI contact by the deadline to remedy the situation. 12 Corrective Action Notice Notice of ConcernNotice of Breach Issued by CSI DepartmentCSI Executive Director Sent toDepartment’s school level contact School leader & Board chair
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The Process in Action Scenario 1: Issue: o Schools receives an application, and the IEP box is checked o There has been no enrollment determination Context: o The student’s IEP requires an OT o The student shows up on the first day of school o It is identified in week 3-4 that student had IEP Outcome: o Notice issued: Notice of Concern is issued to the school leader and board chair, which provides the actions and timeline for remedying the situation o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? 13
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The Process in Action Scenario 2A Issue: o IEP meeting isn’t held by annual date Context: o In the 14-15 school year, the 15-16 annual IEP review date was set for October 15, 2015 o Parent isn’t able to attend on October 15 th and reschedules for later in the month Outcome: o No notice of noncompliance is issued since the parent was unable to make the annual review date and reschedules 14
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The Process in Action Scenario 2B Issue: o IEP meeting isn’t held by annual date Context: o In the 14-15 school year, the 15-16 annual IEP review date was set for October 15, 2015 o Teacher isn’t able to attend on October 15 th Outcome: o Notice issued: Notice of Concern is issued to the school leader and board chair, which provides the actions and timeline for remedying the situation o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? 15
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The Process in Action Scenario 2C Issue: o IEP meeting isn’t held by annual date Context: o In the 14-15 school year, the 15-16 annual IEP review date was set for October 15, 2015 o School forgot to schedule meeting Outcome: o Notice issued: Notice of Concern is issued to the school leader and board chair, which provides the actions and timeline for remedying the situation o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? 16
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The Process in Action Scenario 3A Issue: o Qualified SPED staff is not hired by the start of the school or the position becomes vacant Context: o School completes the Vacant Personnel Action Plan and submits to CSI Outcome: o Notice issued: Corrective Action Notice of issued to school SPED contact, which provides the actions and timeline for remedying the situation o Rationale: “No” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? because they provided an adequate plan for serving students in the interim 17
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The Process in Action Scenario 3B Issue: o Qualified SPED staff is not hired by the start of the school or the position becomes vacant Context: o School does not complete the Vacant Personnel Action Plan for CSI Outcome: o Notice issued: Notice of Concern is issued to the school leader and board chair, which provides the actions and timeline for remedying the situation o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? 18
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For More Information CSI Quality Assurance Webpage [www.csi.state.co.us/school_resources/quality_assurance] 19
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SPED Submissions Janet Dinnen Quality Assurance & Accountability Director Charter School Institute 20
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Submissions Process CDE/Data Pipeline provides reports to CSI on errors and validations CDE Implements timelines for reports CSI Creates and Communicates timelines for schools to ensure deadline is met Provides Training CSI Provides errors reports to schools Troubleshoots errors with school CSI Submits data files to CDE’s Data Pipeline School Obtains error reports and fixes information Provides files to CSI School Attends CSI training Maintains student and staff level data Provides data files to CSI to submit per CSI’s timelines
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School’s Role Under CSI, you have more autonomy Schools are responsible for completing all data submissions School’s Submissions Contact Responsibilities: o Data Integrity o Clearing Errors o Meeting CSI-Imposed Deadlines o Confirming accuracy of reports School’s SPED Contact Responsibilities: o Ensure data is up to date in your school’s plan management system o Work with school’s Submissions Contact to ensure data integrity / accuracy of reports
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SPED Submissions The Special Education IEP Interchange is a set of two files which contain Special Education data for the school year: 1.Special Education Child file: contains data related to the student’s demographic and contact information.Special Education Child file 2.Special Education Participation file: contains data related to the student’s participation in special education.Special Education Participation file 3.For SPED HR files: 2015-2016 File Layout and Definitions for Staff Assignment (PDF) 2015-2016 File Layout and Definitions for Staff Profile (PDF) This information is used to make up the following snapshots: o Special Education December Count Coordinate with your HR Submissions contact to ensure all necessary data is collected for staff providing direct services to students with disabilities o Special Education End-of-Year o Special Education Discipline Coordinate with staff responsible for addressing student discipline to discuss the process for reporting info regarding disciplinary incidents and actions for students with disabilities See more at: https://www.cde.state.co.us/datapipeline/inter_sped-iephttps://www.cde.state.co.us/datapipeline/inter_sped-iep
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SPED Submissions – Collaborating with School Staff Special Education December Count o Coordinate with your HR Submissions contact to ensure all necessary data is collected for staff providing direct services to students with disabilities Special Education Discipline o Coordinate with staff responsible for addressing student discipline to discuss the process for reporting info regarding disciplinary incidents and actions for students with disabilities
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Plan Management System Schools are using one of the following plan management systems to house student plans: o Alpine (see Alpine for training resources) Guide to Data Entry in Student Plans State Reporting utilities o Infinite Campus (see Campus Community for Training Resources) Special Education (Colorado) State Reporting (Colorado) – for Dec Count, SPED EOY, SPED Discipline reports State Reporting (Colorado) Schools are responsible for: o ensuring they have collected all required information Ex: There are additional fields required for the December Count that are not required in the IEP (ex: EDID number for service providers) o extracting the appropriate files from their plan management system and submitting them to CSI
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