Module 11: Federal Monitoring of the State Migrant Education Program

1. Module 11: Federal Monitoring of the State Migrant Education Program New Directors’ Orientation Tutorial

2. Table of Contents

3. Getting Started In This Section Tutorial Objectives How to Use the Tutorial Icons to Guide You Key Readings and Resources

4. Tutorial Objectives Module 11 will enable new state directors to • Understand the purpose of federal monitoring, • Become familiar with the monitoring process, • Prepare for federal monitoring, • Respond to findings, • Ensure ongoing compliance, and • Develop an action plan to avoid findings.

5. How to Use the Tutorial For optimal benefit from the tutorial, you should • Allow sufficient time to read the slides, reflect on the information, and complete all activities on the slides or on the Quick Resource and Reflection Sheets (QRRS) that can be downloaded as worksheets; • Read each slide as well as the information referenced in the slides; • Engage with the “What Do You Think?” slides to facilitate interaction with the information (Answers will be provided directly following each of these slides.);

6. How to Use the Tutorial For optimal benefit from the tutorial, you should (continued) • Pause to reflect on your state program at the “Check-in” slides (A QRRS document will typically accompany these.); • Complete the “Pop Quiz!” slides to reinforce key concepts; • Review your state’s Migrant Education Program (MEP) documents and reports as directed; • Develop an action plan using the worksheets provided; • Add actionable items to your MEP planning calendar (See QRRS 14.2.); and • Contact your OME Program Officer for follow-up questions.

7. Icons to Guide You The following icons will guide you in making the best use of this tutorial: What Do You Think? Check-in Pop Quiz! Quick Reference and Reflection Sheet (QRRS) Action Planning Calendar Item

8. Key Readings and Resources You should have these documents readily available while completing the module, as the module will refer to these documents for more complete information on various topics. • MEP Guidance on the Education of Migratory Children under Title I, Part C of the Elementary and Secondary Education Act of 1965 • Your state’s most recent Title I, Part C federal monitoring report for the state MEP and any subsequent responses

9. Purpose of Federal Monitoring In This Section Purposes of the U.S. Department of Education’s Monitoring of State Migrant Education Programs (MEPs)

10. Purposes of ED Monitoring of State MEPs Monitoring of MEP grantees allows ED to: • Understand the state context within which each MEP operates; • Examine the results achieved by the MEP, particularly with regard to: • The U.S. Department of Education’s Strategic Plan, • Government Performance and Results Act (GPRA) indicators, and • The state’s performance targets/ Annual Measurable Outcomes (AMOs) with regard to migrant students; • Examine the implementationof the MEP with a focus on assessing program quality and identifying areas where improvements can be made;

11. Purposes of ED Monitoring of State MEPs • Document the state’s compliance with applicable statutes and regulations; • Examine the state’s resolution of prior findingsfrom audits/monitoring reviews; • Identify exemplary practices that can be used as a model for others; and • Determine where the state could benefit from federal technical assistance.

12. Pop Quiz! List four reasons why ED/Office of Migrant Education (OME) conducts monitoring of state MEPs: 1. 2. 3. 4. Review the previous three slides to see if you remembered correctly.

13. What Do You Think? Win-Win-Win Instructions: Think of three ways ED/OME, the state MEP, and migrant children can benefit from Federal monitoring.

14. What Do You Think? – Reflection Did some of your responses match those in the table below?

15. Overview of the Monitoring Process In This Section How ED/OME Monitors State MEPs Documents state educational agencies (SEAs) Need to Provide for the Review Role of the State Director

16. How ED/OME Monitors State MEPs • Approximately 90 days before federal monitoring, the MEP Officer will contact the state director to discuss possible dates for monitoring. • Approximately 60 days before federal monitoring, OME will send a letter to: • The Chief State School Officer (CSSO) to confirm the monitoring dates and • The state director to provide the following details for the visit: • A list of personnel to be interviewed— SEA staff and any non-SEA staff that work on the MEP, • Local sites to be reviewed, • Documents the SEA needs to send prior to the review, and • State director responsibilities for arranging and coordinating the review.

17. How ED/OME Monitors State MEPs • Approximately 60 days before federal monitoring, the MEP Officer and state director will begin communicating frequently to discuss the agenda and clarify expectations.

18. How ED/OME Monitors State MEPs Monitoring Topics

19. How ED/OME Monitors State MEPs Monitoring Topics • State Context • State Demographics • Migrant Populations • GRPA Indicators • Education Improvement Agenda • Overall Program Design • MEP Goals • Organizational Structure and Staffing

20. How ED/OME Monitors State MEPs Monitoring Topics (continued) III. Program Operations • Identification and Recruitment (ID&R) • Provision of Services • Fiscal Management IV. Program Results V. Prior Findings • See QRRS 11.1 – Onsite Monitoring Instrument: State Level

21. How ED/OME Monitors State MEPs On-site Review • The on-site review is usually a comprehensive examination of several topic areas. • Typically, the state’s assigned MEP Officer and a team of one to five OME staff members will participate in the review.

22. How ED/OME Monitors State MEPs Individuals typically requested for interview at the State level include: • MEP State director, • SEA staff who work with the MEP, including those who work with migrant student records and/or the state’s student database, • State evaluation coordinator, • Fiscal/budget office staff, and • Members of the State Migrant Parent Advisory Council (PAC).

23. How ED/OME Monitors State MEPs OME will select local sites for the on-site review based on the following criteria: • Geographic proximity; • Size - • Sites with a large number of migrant children or sites that receive a large portion of funds are more likely to be selected; • Random selection after sites that are too remote or too small are eliminated - • Some local sites may be selected even if they were visited during a prior monitoring visit if, for example, they are very large sites or if the sites had challenges;

24. How ED/OME Monitors State MEPs OME will select local sites for the on-site review based on the following criteria (continued): • Implementation difficulties - • Sites with significant audit or site visit findings, complaints; • Promising program models; • Distinctive characteristics (e.g., rapidly changing demographics, model partnerships); • Length of time since last visit; and • Varied programs (schoolwide and targeted assistance, elementary and secondary, extended day, summer programs).

25. How ED/OME Monitors State MEPs Possible interviewees at local sites include: • LOA administrators; • Migrant coordinator and program staff; • Federal programs staff; • School principal, teachers, aides, home-school liaisons, health staff, migrant counselors; • ID&R staff; • Migrant parents and students; • Data entry specialists and staff working with the exchange of student records; and • Staff from local agencies that coordinate with the MEP.

26. How ED/OME Monitors State MEPs Desk Monitoring (via telephone and/or webinar): • A desk or targeted review is usually based on a risk assessment, outstanding findings, and/or unresolved audit findings. • Remote interviews may include the following: • SEA level • State director • SEA staff who work with the MEP, including those who work with migrant student records and/or the state’s student database • LOA level • Local migrant program coordinator • Local MEP staff

27. Documents SEAs Need to Provide for the Review OME will request MEP-related documents and necessary information from the SEA prior to the on-site or desk monitoring review. • State directors are encouraged to: • Keep documents on hand (electronic or hard-copy) for easy access, and • Determine where to find the most up-to-date information. • See QRRS 11.2 – Locating Documents for Review

28. Role of the State Director • Planning and coordinating review activities and logistics, including developing an agenda with the OME review leader; • Sharing review expectations, goals, and objectives with appropriate state and local officials; • Serving as liaison between OME and the local project sites selected for review; and • Providing requested documents to OME prior to the review.

29. How to Prepare for Federal Monitoring In This Section Benefits of Monitoring Organizing the Review

30. Benefits of Monitoring A positive attitude, andkeeping the benefits of monitoring in mind, will make the experience valuable. Consider: • The shared goals of OME and the state MEP: positive outcomes for migrant children and youth; • You are not a target, but a partner in the process to improve outcomes for migrant children and youth; • An external perspective will help you see aspects of the program that you may have overlooked and that need improvement; and • Federal monitoring can be the leverage you need at the state level to get buy-in and support to make program improvements.

31. Organizing the Review • Read all correspondence from the OME review coordinator to determine your responsibilities; contact the coordinator with any questions. • Develop a detailed agenda for yourself that includes activities, times, logistics, and people involved to help you attend to all details; develop a more basic agenda to share with others. • Keep SEA administrators apprised of upcoming monitoring activities and any roles they are asked to play (share the basic agenda). • Communicate with administrators in LOAs selected for a visit and all others whom OME will interview (share the basic agenda).

32. How to Respond to Findings In This Section ED/OME Requirements and Expectations Plan and Implement Improvements Ongoing Compliance

33. Post-Monitoring:ED/OME Requirements and Expectations • OME sends a report to the Chief State School Officer (CSSO) that contains the following: • A Program Overview, • Noteworthy Areas, • Areas of Non-Compliance (“Findings”) and Required Corrective Actions, and • Recommendations for Improvement. • The SEA must respond to each finding and corrective action and return the report to OME. • The timeline for response will vary according to the number and nature of the findings. Timelines or due dates will be clearly stated for each corrective action.

34. Plan and Implement Improvements • The state MEP director communicates how the SEA will implement all corrective actions required by OME. • Depending on the nature of the finding, some corrective actions may include: • Revision of the state ID&R plan, • Revision of the Service Delivery Plan (SDP), • Revision of training or guidance provided to subgrantees, • Development, or utilization of, parental advisory councils (PACs)

35. Ongoing Compliance The best way for the MEP to avoid findings from a monitoring visit is to maintain ongoing compliance with the program requirements. The following strategies will help ensure the SEA is following the law. • Be familiar with the law, regulations, and MEPGuidance– read these documents periodically to ensure that you are aware of all statutory requirements and OME recommended practices. • Save them on your Desktop or a favorite on your web browser for easy access.

36. Ongoing Compliance • Complete an SEA self-assessment on an annual basis by reviewing the MEP monitoring instrument, and create an action plan to address any areas noted for improvement. • Run the MEP as if it will be monitored every year, and • Make ongoing program improvements.

37. Check-in Complete the OME State Director’s Self-Assessment Tool (QRRS 11.3) to determine: • Which parts of the MEP are in compliance with the law and meet ED/OME expectations, • Which parts of the program need improvement, and • Program aspects on which you need further information to determine compliance and meeting expectations (consider how you will find additional information about the MEP). • See QRRS 11.3 – State Director’s Self-assessment

38. Ongoing Compliance • Review previous federal monitoring reports for your state MEP and any subsequent responses. Questions to Consider: • Were the findings resolved? • Do the findings indicate an ongoing weakness in the program that needs greater focus? • Do the findings indicate a need for increased program capacity that may require a restructuring of staff and/or other resources? • Do the findings indicate a need for clarification or technical assistance from OME?

39. Ongoing Compliance • Be aware of common compliance issues identified by ED/OME across all states, and ensure your SEA is in compliance in these areas.

40. What Do You Think? In the list below, note the top five areas where you think ED/OME has had the most findings in monitoring state MEPs. • State Assessment • ID&R: Child Eligibility • ID&R: Child Counts • Comprehensive State Plan: • Needs Assessment (CNA) • Service Delivery Plan (SDP) • Priority for Services (PFS) • Evaluation & Improvement: Program Effectiveness • Evaluation & Improvement: Program Improvement • Continuity of Instruction • Subgranting Formula • Program Monitoring • Unique Administrative Activities • Parent Advisory Councils (PACs)

41. What Do You Think? – Reflection The top five areas of OME monitoring findings are listed below. How similar is this list to the top five areas you identified? • Evaluation & Improvement: Program Effectiveness • Comprehensive State Plan: Service Delivery Plan (SDP) • Comprehensive State Plan: Needs Assessment (CNA) • Evaluation & Improvement: Program Implementation • Priority for Services (PFS) • See QRRS 11.4 – Summary of Common Compliance Findings

42. Wrapping Up In This Section Key Points Action Planning Resources

43. Key Points • The purpose of federal monitoring of the state MEP is to help states improve outcomes for migrant children and youth. • The OME state contact will communicate with you on ways to prepare for the monitoring. • You should keep documents current and easily accessible so that you can provide them expeditiously to OME upon request prior to federal monitoring. • The SEA is required to respond to findings in writing by describing and providing documentation to support corrective actions. • The best way to avoid monitoring findings is to run the MEP as if it will be monitored every year. • An annual review of the monitoring protocol will help you create an action plan to ensure ongoing compliance.

44. Action Planning Consider the following questions to ensure that you are prepared for OME monitoring: • What documents do I need to locate and keep on file? • With what information sources do I need to become familiar? • What findings were in previous monitoring reports? Have these been adequately addressed? • What other areas of common compliance findings do I need to address?

45. Action Planning Consider the following questions to ensure that you are prepared for OME monitoring (continued): • Have I reviewed the State-Level Onsite Monitoring Instrument as a self-assessment? In what areas is improvement needed? • When is my state’s MEP likely to be monitored again? • See QRRS 11.5 – Action Planning for Federal Monitoring • Add any actionable items to your MEP planning calendar.

46. Resources for Federal Monitoring • MEP Guidance on Education of Migratory Children under Title I, Part C, of the Elementary and Secondary Education Act of 1965– Explanation of guidelines to implement the laws and regulations related to the MEP • MEP Officers – List of OME contact information (https://results.ed.gov/about/contact) • Glossary of Terms – Alphabetical listing of key terms applicable to migrant education (see Module 1) (https://results.ed.gov/idr-manual/section/glossary/glossary)