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Wednesday P.M. – General Session

Reporting to OSEP on Correction of Noncompliance. Wednesday P.M. – General Session. Accountability for Correcting Noncompliance. Reporting on Correction of Noncompliance in the APR Compliance Indicators Indicators C9/B15 Overview/Descriptions Other Accountability Mechanisms Audits

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Wednesday P.M. – General Session

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  1. Reporting to OSEP on • Correction of Noncompliance Wednesday P.M. – General Session

  2. Accountability for Correcting Noncompliance Reporting on Correction of Noncompliance in the APR Compliance Indicators Indicators C9/B15 Overview/Descriptions Other Accountability Mechanisms Audits Special Conditions

  3. Reporting on Correction of Noncompliance in the APR

  4. Timelines for Correction and Reporting ( )

  5. Reporting on Correction in Compliance Indicators Look at FFY 2008 data - was it less than 100%/greater than 0% (B9, B10)? If yes, there should be discussion of correction of noncompliance. If the data were below 100% but you did not make any findings, explain. If the you didn’t make findings from FFY 2008 data until FFY 2009 (used FFY 2007 data to make findings in FFY 2008), explain.

  6. Reporting on Correction in Compliance Indicators Describe verification of correction in accordance with OSEP Memo 09-02 (2 steps) Numbers do not have to align with Indicators B15 and C9 but explain if they do not Include subsequent correction up to the date of APR submission Include program-specific follow-up activities (including enforcement/sanctions) for uncorrected findings - in past tense

  7. For purposes of OSEP determinations, OSEP has defined substantial compliance: 95% + 75% + with correction of all previously identified noncompliance < 75% cannot be substantial compliance Subsequent correction is considered (except for Indicators C9 and B15) Substantial Compliance

  8. Part B Examples

  9. Optional APR Template – Indicators B11, B12, B13

  10. Indicators B11, B12, B13Correction Over Multiple Years

  11. Part C Examples

  12. Optional APR Template – Indicators C1, C7, C8

  13. Indicator C1Correction over Multiple Years

  14. Reporting on Correction in Indicators B15 and C9 Describe Findings Include whether findings are made based on individual instances of noncompliance or grouped instances of noncompliance If instances are grouped, assure correction of individual instances as well when possible

  15. Example State used the following definitions for this indicator: Finding: A written notification from the State to an LEA or EIS program that includes a conclusion that the LEA or EIS program is in noncompliance, the citation of the statute or regulation, and a description of the quantitative and/or qualitative data supporting the conclusion that there is noncompliance. For SPP and APR indicators, monitoring inquiries, and dispute resolution findings for which correction can be completed for individual instances, State reports each instance of noncompliance as a finding. For SPP and APR indicators, monitoring inquiries, and dispute resolution findings for which correction cannot be completed for individual instances (i.e., timelines), State groups individual instances of noncompliance into one finding for which the district must demonstrate compliance.

  16. OSEP Memo 09-02 Language re: Verification of Correction In order to demonstrate that previously identified noncompliance has been corrected, an SEA/LA must: (1) Account for the correction of all child-specific instances of noncompliance; and (2) Determine whether each the Schools or Programs with the identified noncompliance are correctly implementing the specific regulatory requirements

  17. Include Subsequent Correction Report separately from timely correction Report program-specific (for each program with uncorrected noncompliance) follow-up activities including sanctions and enforcements Report what has been done, not what is planned or could be done (past tense) • Reporting on Correction in Indicators B15 and C9

  18. Indicator C9 Worksheet

  19. Indicator B15 Worksheet

  20. Indicators B15/C9 Correction over Multiple Years

  21. SPP/APR Resources SPP/APR Calendar http://spp-apr-calendar.rrfcnetwork.org/ Most recent measurement table Optional APR Templates WRRC APR Clinic – planning 2010 clinic for November in San Francisco

  22. Other Accountability Mechanisms Audits Special Conditions Others?

  23. Team Application Activity Reporting to OSEP on Correction of Noncompliance

  24. Application Activity –Guiding Questions What does your OSEP Response Table say about correction of noncompliance? Has OSEP identified any other issues with correction of noncompliance? Is there any language in your SPP/APR that could be revised to be clearer for next year’s submission?

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