Interactive Guide to Streamlining and Integrating Part C General Supervision Activities: Monitoring and Program Improvement

Welcome to the overview of the framework for Streamlining and Integrating Part C General Supervision: Monitoring and Program improvement. In this presentation, we will share a process for organizing your general supervision and monitoring systems and ensure that you are getting the results that you desire for early intervention.

This framework may be used for organizing the process of streamlining and integrating Part C General Supervision monitoring and program improvement activities. It was developed around six steps that describe what a general supervision system does. The framework incorporates the puzzle pieces of general supervision that relate to monitoring and program improvement and it is based on OSEP’s requirements for an effective general supervision system.

The six steps of general supervision are:

1. Identify an Issue
2. Determine the Extent/Level of the Issue
3. Determine the Cause of the Issue
4. Assign Accountability for the Issue and its Resolution
5. Ensure and Verify Resolution of the Issue
6. Follow Up on Resolution of the Issue

Each of the six steps builds on the prior step and incorporates inputs from a variety of sources. The online interactive guide discusses each of the six steps in detail and provides a list of state challenges as well as available national and state resources for each step.

Various integrated on-site and off-site monitoring activities as well as data on process and results will contribute to actions taken in the six steps. Let’s take a few minutes and talk about each of these inputs.

States typically use a combination of activities to provide a comprehensive picture of the level of compliance and results for each local early intervention program. Such activities can be conducted during on-site visits, but can occur off-site as well.

The on-site visit is a critical monitoring activity used by states to examine performance of their local programs. On-site visits may include the verification of data from the data system or a self-assessment. The visit may also be used to collect additional data to determine program performance. This may also include record reviews (at both the child and program level), interviews with providers, administrators and families, and observations of various program practices, to name a few.

Off-site monitoring activities can include the use of a self-assessment, desk audit, surveys of families and providers, contract management, and the state’s dispute resolution process.

A self-assessment, completed at regular intervals by local programs, assists states in determining local program performance on critical state indicators.

A desk audit is the process of the state reviewing materials and information that are representative of a program's performance. Such information may include data from the state data system, completed self-assessment, family survey, dispute resolution process, and previous monitoring reports. The desk audit can assist the state in identifying what issues need further investigation during an on-site visit, and can also be used as an off-site means of conducting annual monitoring of programs on specific indicators.

Surveys of families and providers can be used instead of or in addition to conducting interviews during an on-site visit. This data can assist the state in determining if an on-site visit is needed and if so, what areas need to be further investigated.

Contract management is also a critical component of oversight and monitoring that can help provide a comprehensive picture of the local program’s performance with programmatic and fiscal requirements.

States also rely on data from their dispute resolution system, including complaints, mediation, resolution sessions, and due process hearings. These data help facilitate the identification and correction of noncompliance as well as identify components of the system that need improvement, such as policies, procedures, guidelines, or written agreements.

Data from these various on- and off-site activities are analyzed along with data from the state’s data system to measure the state’s performance and compliance with IDEA requirements, including the State Performance Plan and Annual Performance Report indicators, and the state’s monitoring priorities.

Let’s talk through a short example of how local program data from these on- and off-site activities might be used throughout the six steps. Data from a state’s self-assessment, state dispute resolution system , and the state’s data system might form the basis to identify an issue in Step 1.

Step 2 and 3 look deeper into this data, possibly using additional data from root cause analyses tools, to determine the level and extent as well as the cause of the issue.

Based upon the data analyses in Steps 1 to 3, the state then notifies the local early intervention program of noncompliance or performance issues and any required corrective actions or improvement activities. This is Step 4.

In Step 5, new data from the state’s data base, or data reported by local programs, are used to verify correction of noncompliance or resolution of the performance issue.

Finally, in Step 6, new data from the state’s self-assessment, state dispute system, and the state’s data system are used to follow up on the resolution of the issue to ensure long term resolution.

In completing the six steps, there are a number of resulting outputs. These outputs include:

• Corrective action or improvement plans
• Incentives or rewards
• Targeted training and technical assistance
• Follow-up activities to verify correction
• Sanctions as appropriate, and
• Public Reporting

Let’s look briefly at each of these in a little more detail.

States are expected to enforce compliance with IDEA requirements. When the state identifies findings of noncompliance or areas needing improved performance, they typically use corrective action (or CAPs) and/or improvement plans to ensure meeting of targets and correction of noncompliance as soon as possible but no later than one year after identification. In some states, local programs develop CAPS or improvement plans that are approved by the state. In other states, the state provides the CAP or improvement activities that must be implemented. Corrective action or improvement plans are an output of Step 4.

States also use incentives or rewards to support high performance. These can include funding, public recognition, less frequent monitoring, or other activities.

Incentives or rewards can be an outgrowth of Step 1: Identify an issue, Step 5 – Ensure and verify the resolution of an issue, or Step 6 – Follow-up on resolution of an issue.

Training and Technical Assistance are critical for ensuring implementation of IDEA requirements and assisting early intervention programs in enhancing their performance, correcting noncompliance, and improving results for children and families. Training and Technical Assistance should be provided around the state's monitoring indicators including the SPP/APR and other state indicators, as well as supporting implementation of corrective action or improvement plan activities that occur as a result of Step 4. Some states require targeted technical assistance and training as one of a number of state actions that can be used to ensure that programs correct noncompliance in a timely manner.

States are also expected to provide follow-up and track improvement and correction of noncompliance on an ongoing basis. All correction of noncompliance must be verified within one year of identification. This is an output of Step 5 of the framework.

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. Such sanctions may include:

• Requiring the use of training and technical assistance;
• Directing the use of funds;
• Imposing special conditions on contracts;
• Denying or recouping payments; and
• Terminating contracts
• Sanctions are an output of Step 6.

Finally, as a result of all six steps of the framework, states’ reporting on the status of local program performance is a critical output. Reporting is completed through the Annual Performance Report, publicly reporting of local program data, and making local program determinations.

In summary, the inputs obtained through on-site and off-site monitoring activities and data on process and results impact the outputs throughout their use in the six steps. The outputs generated as a result of the six steps are in turn valuable sources of inputs when the cycle is initiated again.

We hope you have found this overview of the framework for streamlining and integrating Part C general supervision helpful and invite you to further explore each of the six steps, including state challenges and resources, through the online interactive guide.