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The primary focus of state monitoring activities is on improving educational results and functional outcomes for all children with disabilities; and ensuring that states meet the program requirements of IDEA, with a particular emphasis on those requirements that are most closely related to improving educational results for children with disabilities. As a result, states must have in place a general supervision system that monitors implementation of IDEA by early intervention programs (whether or not they receive Part C funds), and local education agencies statewide. [IDEA 2004, Section 616(a)(2)] Overall, each state's General Supervision System must include multiple methods to ensure implementation of IDEA 2004, identify and correct noncompliance, facilitate improvement, and support practices that improve results and functional outcomes for children and families. Core Components of an Effective State General Supervision SystemAn effective general supervision system includes the following interrelated core components:
• State Performance Plan and State Goals with Measurable Targets
• Effective Policies, Procedures, and Memorandum of Understanding • Data on Processes and Results • Effective Dispute Resolution System • Integrated On-Site and Off-Site Monitoring Activities • Targeted Technical Assistance and Professional Development • Improvement and Corrective Action Planning, Incentives, and Sanctions • Fiscal Management • Evaluation of Effectiveness and Efficiency of the General Supervision System Although the components are described separately, they connect, interact and articulate to form a comprehensive system. Each component informs and gains information from the others. States have flexibility regarding how they implement each of these components and design how these components interrelate with other initiatives and needs within their state systems including their organizational structure (see State Structures for Part C Service Provision and Implications for Accountability), and other factors relevant to how they are accountable. Through the activities of general supervision, the state supervises the districts/programs and activities that directly provide the necessary services and supports to fulfill the requirements of law and achieve the expected results. For more information on the components of an effective general supervision systems, see the following resources developed by the National Center for Special Education Accountability Monitoring (NCSEAM) in collaboration with the six regional resource centers, the Federal Regional Resource Center, the National Early Childhood Technical Assistance Center, and representatives from state agencies, the National Association of State Directors in Special Education, and the IDEA Infant and Toddlers Coordinators Association:
An Integrated Timetable
for 2007-2008 APR Development and Part C General Supervision/Monitoring Activities
A state specific example, Connecticut General Supervision Activities for Part C to B Transition: FAPE by Three, is also available. Connecticut provided a description its general supervision activities (including data verification, data review and analysis, optional on-site visit, feedback to district, improvement planning, and closure) specific to a priority indicator (B-12), transition from Part C to Part B - FAPE by Three. • State Performance Plan and State Goals with Measurable TargetsIDEA 2004 requires that each state complete and submit a State Performance Plan (SPP) that includes rigorous and measurable targets to ensure improved performance on each indicator. States may also select additional indicators that are critical for the state. Many states are currently in the process of modifying their general supervision systems, selecting indicators that most closely align with results, and improving other general supervision components to ensure compliance and improvement. States are required to annually report their performance on SPP indicators through an Annual Performance Report (APR) to OSEP and to the public (see Reporting Data to the Public). State Monitoring Indicators - The following are examples of state monitoring indicators that states have selected as being critical:
Measurable and Rigorous Targets - IDEA 2004 Report language indicates that accurate data-driven decision-making with regard to enforcement of IDEA is required to ensure that federal dollars are being spent productively and that monitoring and enforcement is administered fairly. As a result, measurable and rigorous targets must be established with broad stakeholder input and specify a challenging level of improved performance to be reached for each SPP indicator annually. Overall, targets serve as improvement goals for the state as well as for each district/program. For some indicators, called compliance indicators, the measurable and rigorous target must be 100%. Additional information on measurable and rigorous targets is available as follows:
The SPP indicators and other state monitoring indicators and their targets are the foundation from which all other components of the state's general supervision system flow. • Effective Policies, Procedures and Memorandum of UnderstandingWhat providers do directly impacts compliance with requirements and results for children and families. Provider practices are influenced by state and local policies, procedures, and written agreements (e.g. interagency agreements, memorandum of understanding, etc.). The clarity of these materials, as well as their consistency with statutory and regulatory requirements of IDEA and scientifically-based research, impact their implementation and results for children and families. As a result, effective policies, procedures, and written agreements are important aspects of the state's general supervision system. Policies and procedures must be enforceable and allow for the use of sanctions when necessary. Descriptions of methods that the state will use to identify noncompliance with requirements and ensure correction of noncompliance must be included. Policies and procedures related to written agreements must address mechanisms to determine financial and service provision responsibility as well as methods for the resolution of disputes between the agencies involved in providing services. The state must establish an effective method for ensuring that providers follow state policies, procedures and implement effective practices. States should also have processes in place for improving policies, procedures and written agreements as well as related guidance materials. Monitoring results and findings from the dispute resolution system can be effective means of improving these state documents and subsequently supporting provider practices, compliance, and results for children and families. • Data on Processes and ResultsData-driven decision-making is a key aspect of accountability. Over the past several years, national attention has been given to the collection and use of critical and meaningful data. States have been working on improving their data collection systems to respond to federal reporting requirements as well as state accountability requirements. A number of states are attempting to align their data system with SPP/APR (including child and family outcomes) and other state monitoring indicators in order to measure performance on an ongoing basis. More and more states are also investing in data collection systems that collect real time data at the child/student level. The collection, analyses, and reporting of child/student level data are essential for documenting results for children and families and for use in monitoring programs. States should be able to look at data over time and to disaggregate data in order to determine performance at various levels of the system (e.g., provider, team, program/LEA, region/district). Effective data systems typically require that individual child/student data is updated at least quarterly and that historical data for each child/student is maintained. A paperless system that interfaces or communicates with other databases or systems within the SEA or Lead Agency and across agencies is critical. This includes linking with the state's complaints, mediation and due process data to provide a complete picture of district/program compliance and performance. Some states have developed their data system to serve as an electronic record for each child. Data Accuracy and Verification - All collected data should be verified on a regular basis to improve reliability and accuracy. Verification includes not only electronic edits to check that data are entered according to the definitions established by the state, but includes a process for regularly testing the accuracy of the entered data with the information in child/student records to ensure that data reflects actual practice. A variety of methods for ensuring data accuracy should be used.
Reporting Data to the Public - Data reports should be routinely generated and analyzed at both the state and district/program levels. Data reports should also be designed to meet the needs of districts/programs. Analysis of data trends at the state and district/program level should be completed and district/program data should be compared to the rigorous targets in the SPP and other state selected monitoring indicators and targets. Data should also be analyzed to track performance and continuous improvement as well as to ensure that children are making progress (e.g., child outcomes). States also use data to make determinations of the status of each district/program (see Status Determination). States are required to annually report both state performance and district/program performance data (e.g., 618 and SPP/APR data) to the public. A program/district profile or report card is an example of an effective method of reporting data to the public. The following resources are available regarding reporting data to the public:
Part B - Data Reporting to the Public on State Web Sites: 10 Examples (2006)
 (DOC: 109kb) Part C - Data Reporting to the Public on State Web Sites: 10 Examples (2006) (DOC: 107kb)
Aligning Part C and Part B Data - Many states are working to align their data with other agencies' and initiatives' data. Alignment of data has become an important issue especially for tracking children who transition from Part C to Part B in order to respond to SPP/APR transition indicators. States are in various stages of aligning their data between Parts C and B. Many states are still in the initial stages of alignment. States who have made some progress with the alignment of data have used a variety of strategies including: (1) manually matching child data; (2) using different unique identifiers but sharing the identifier across Parts C and B; (3) transferring records through a data protocol across both systems; and (4) both systems using the same unique identifier for a specific child. Several resources on aligning Parts C and B data are also available.
Other Resources on Data and Data Systems - Several general resources are available regarding data systems and an example of how one state is using their data system as an integral part of their general supervision systems.
• Effective Dispute Resolution SystemHaving effective and efficient mechanisms to respond to and analyze findings from complaints, mediation, the new Part B resolution process, and due process hearings are important components of an effective general supervision system. Timely resolution of disputes can facilitate the identification and correction of noncompliance as well as identify components of the system that need improvement (e.g., policies, procedures, guidelines, written agreements). As part of monitoring activities, states need to examine district/program dispute resolution data to identify issues related to performance and help plan on-site or other district/program-specific monitoring activities. Annually assessing the effectiveness of each dispute resolution option, examining trends, exploring themes and issues that may be common across options is important to improve the various dispute resolution processes as part of the state's general supervision system. For states with few or no complaints, hearings or other dispute resolution requests, states should develop strategies to measure parent and/or student understanding of their rights (e.g., family survey) and how using dispute resolution options can assist in improving performance. The following dispute resolution system resources are available:
• Integrated On-Site and Off-Site Monitoring ActivitiesStates use a variety of methods to monitor local districts/early intervention programs including off-site activities (e.g., district/program self-assessment; analysis of data reports; desk audit activities including review of self-assessment data, analyses of family survey, child outcome and complaints data, review of previous monitoring reports, review of rank-ordered district/program data on SPP and other state monitoring indicators) and on-site activities (e.g., record reviews, interviews with parents and staff) to investigate program/district performance, especially in areas of low performance or noncompliance. States typically use a combination of on-site and off-site monitoring activities that are linked or integrated to provide a comprehensive picture for each district's/program's level of compliance and results. It is critical that these activities: 1) be implemented fairly and consistently across districts/programs; 2) identify areas of noncompliance; 3) trigger effective corrective actions, technical assistance, improvement strategies, fiscal decisions, and other investments, sanctions, and incentives that ensure timely correction; and 4) lead to status determination of districts/programs. Examples of state monitoring manuals that describe integrated monitoring activities:
Self-Assessment - Many states require districts/programs to complete a self-assessment at regular intervals to assist in determining performance on critical state indicators. To assist districts/programs in completing their self-assessment, some states have linked data from their state data system with the self-assessment indicators or measures and limit the number of other required self-assessment data collection strategies (e.g., record reviews, interviews). Some states have made their self-assessment document and instrument(s) publicly available.
Other resources:
Focused Monitoring - Many states are implementing onsite focused monitoring, in which a small number of carefully chosen priorities drive the process. The focused monitoring process includes: rank-ordering districts'/programs' performance on selected priority indicators; selecting a number of districts/programs for on-site review; targeting technical assistance; and ensuring correction of noncompliance. Focused monitoring on-site visits are used to investigate hypotheses as to why a program/district's performance is not meeting expected targets. The National Center for Special Education Accountability Monitoring provides documents, information, and reference sources relevant to the development, implementation, and evaluation of focused monitoring. Desk Audit - A desk audit is the process of reviewing materials and information that are representative of a district or program's performance. Such information and materials may include a district's/program's data from the state data system, self-assessment, family surveys, complaints and previous monitoring reports. Desk audits are used for several different purposes, but frequently as a part of state staffs' preparation for an on-site visit. In this case, the desk audit provides the opportunity for the state team to formulate potential reasons for poor performance including why a district/program may be having difficulties meeting targets (establishing hypotheses). This allows the team to plan what needs further investigation during the on-site visit. Desk audits are also used by many states as an off-site means of conducting annual monitoring of districts/programs on specific indicators. This process allows states to identify noncompliance and ensure corrective action of noncompliance without having to go onsite to the LEA/program. The following resource is an example of how one state uses the desk audit process in preparation for on-site focused monitoring:
On-site Visits (Cyclical or Focused) - The on-site visit is a critical monitoring activity used by states to examine performance of local programs. Onsite visits may include the verification of data (e.g., data system, self-assessment) and/or collection of data to determine district/program performance. In the case of a focused onsite visit, the team will test hypotheses formulated during pre-site preparation. On-site Selection Methodology - Some states implement on-site monitoring of a district/program on a cyclical basis (e.g., once every three years). States that implement focused monitoring select a limited number of districts/programs for on-site monitoring annually using an established methodology (e.g., based upon rank-ordered data of selected priorities). The following is a resource for state regarding on-site selection methodology:
On-site Activities - On-site visits for districts/programs are typically conducted by
a team, which includes family members. On-site visits should be individualized based upon the review of
information and materials during the desk audit. A number of appropriately planned activities should be
included in the on-site visit (e.g., interviews with directors/administrators, open meeting or focus group
with parents, interviews with staff/providers, review of records and/or written documentation, analysis of
data). For states implementing focused monitoring, the on-site visit is the opportunity to test
hypotheses formulated during the desk audit. All on-site visits should result in a meeting to ensure
consensus among members of the on-site monitoring team. Typically, a team leader assumes the
role of coordinating on-site visit activities. The National Center for Special Education Accountability
Monitoring has developed a team leader checklist
Written Findings Report - When noncompliance is identified through off-site or on-site
activities, a written report is issued to the district/program. Written reports should be issued in a
timely manner. The report should outline findings as well as the methods and sources of information used
to identify noncompliance. The findings report should specify expected actions that programs/districts
must take (e.g., submitting corrective action plans, expected evidence of correction and improvement
including timelines to ensure that noncompliance is corrected in a timely manner but no later than one
year). The National Center for Special Education Accountability Monitoring has developed a
report checklist
Status Determination of Local Education Agencies/Early Intervention Programs Performance - Beginning in 2007, states are required to make determinations annually on the status of the performance of local education agencies (LEAs) /early intervention (EI) programs in accordance with the same four categories that OSEP uses with states (e.g., "Meets Requirements, Needs Assistance, Needs Intervention, and Needs Substantial Intervention"). Data on the performance of each EIS program on the SPP indicators, as well as from other sources (e.g. fiscal audits, previous monitoring data), are used by states to make determinations of the status of each districts/programs. In making determinations, states must consider the following:
In addition, states could also consider:
There is nothing in the Federal statute or regulations that address a timeline for when states must make determinations regarding the performance of the LEAs or EI programs in their states. However, states need to make the determinations as soon as possible after making their annual report to the public on the performance of each LEA or EI program. It is important to ensure that LEAs and EI Programs have time to improve performance prior to the next reporting of the state by each LEA or EI program and the state's next determinations point. In addition, there may be implications for the state's award of funds to LEAs or EI programs so the state would ideally make its determinations before grants are issued or contracts are signed or renewed. States are not required to report the LEAs or EI programs' determinations to OSEP or to the public. States, of course, must inform each LEA or EI Program of the state's determination regarding that LEA or EI program. Additional information on status determination of LEAs/EI Programs performance is available as follows:
• Targeted Technical Assistance and Professional DevelopmentTechnical assistance and training are critical for ensuring implementation of IDEA requirements and distributing evidence-based practices to programs/districts. In addition, technical assistance and training should be directly linked to the SPP/APR and state monitoring activities. This includes providing technical assistance and training around the state's monitoring indicators (e.g., SPP/APR and other state indicators) and state and program/district improvement/corrective action plan activities. Technical assistance and training are critical for assisting programs/districts in enhancing their performance, correcting noncompliance, and improving results for children and families. Some states include required targeted technical assistance and training as one of a number of state actions that can be used to ensure that programs/district correct noncompliance in a timely manner. States should ensure that any technical assistance and training provided is evaluated for its effectiveness and incorporation of adult learning principles and standards for professional development. Information on various states' technical assistance systems is available. • Improvement and Corrective Action Planning, Incentives and SanctionsStates are expected to enforce compliance with IDEA requirements. When instances of noncompliance or
areas needing improved performance have been identified, states typically use corrective action and/or
improvement planning processes to ensure correction of noncompliance in a timely manner (within one year)
and/or meeting of measurable and rigorous targets. States also use incentives to
reward performance. States are also expected to provide follow-up and track improvement and correction of
noncompliance on an ongoing basis. When performance has not improved and noncompliance is not corrected
in a timely manner, states are required to have in place a range of formalized strategies and/or sanctions
for enforcement with written timelines. The National Center for Special Education Accountability
Monitoring has developed a corrective action plan/improvement plan checklist
• Fiscal ManagementFiscal accountability is a critical aspect of a state's general supervision system. The state must
have in place processes, including appropriate oversight, to ensure that funds are used in accordance with
IDEA and state requirements. More information on the fiscal management requirements that states must
meet can be accessed in the Developing and Implementing an Effective System of General Supervision papers for
Part B
• Evaluation of Effectiveness and Efficiency of the General Supervision SystemEvaluation of the each state's general supervision system should occur on a regular
basis to ensure that the system is both effective and efficient and to make improvements as
appropriate. The Developing and Implementing an Effective System of General Supervision papers
for Part B
We encourage you to contact us by e-mail about your state's general supervision documents/tools that have been successfully implemented in your state. Links on this site are verified monthly. This page content was last updated on 09/19/2008 CF.
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