Part C General Supervision Monitoring Procedures Checklist
Updated September 11, 2026, 12:10 PMA lead agency's A lead agency's general supervision system is the mechanism for enforcing federal requirements and for ensuring continuous improvement.
This system includes multiple components:
- Integrated monitoring activities
- Data on processes and results
- State Performance Plan/Annual Performance Report (SPP/APR)
- Fiscal management
- Dispute resolution
- Targeted technical assistance (TA) and professional development (PD)
- Implementation of policies, procedures, and practices
- Improvement, correction, incentives, and sanctions
This checklist will be useful in:
- Assessing whether the state's procedures are meeting all requirements in Guidance on State General Supervision Responsibilities under Parts B and C of the IDEA (July 24, 2023).
- Evaluating, prioritizing, or improving specific parts of your general supervision system.
- Preparing for the Differentiated Monitoring and Support (DMS 2.0) process.
- Supporting your work with the Accountability and Quality Improvement Component of the System Framework.
Introduction
"The primary focus of the State's monitoring activities must be on —
- Improving early intervention results and functional outcomes for all infants and toddlers with disabilities; and
- Ensuring that EIS programs meet the program requirements under part C of the Act, with a particular emphasis on those requirements that are most closely related to improving early intervention results for infants and toddlers with disabilities."
General supervision, including integrated monitoring activities (which includes correction and improvement), should be reasonably designed and used to evaluate local programs and providers. This includes oversight and monitoring of the implementation of IDEA statewide to ensure every infant and toddler with disabilities and their family have access to high quality supports and services, fully participate in the program, and achieve positive outcomes. To ensure effective oversight and monitoring, a process for collecting and reporting valid and reliable data should be included in the general supervision system.
"Early intervention service program means an entity designated by the lead agency for reporting performance in the State Performance Plan/Annual Performance Report (SPP/APR) under §§303.700 through 303.702."
"Early intervention service provider or EIS provider means an entity (whether public, private, or nonprofit) or an individual that provides early intervention services under part C of the Act, whether or not the entity or individual receives Federal funds under part C of the Act, and may include, where appropriate, the lead agency and a public agency responsible for providing early intervention services to infants and toddlers with disabilities in the State under part C of the Act."
Integrated Monitoring Activities
All EIS programs and providers are subject to integrated monitoring at least once every six years under the general supervision system.
"Specifically, integrated monitoring activities are a multifaceted formal process or system designed to examine and evaluate a Lead Education Agency's (LEA's) or EIS program's or provider's implementation of IDEA with a particular emphasis on educational results, functional outcomes, and compliance with IDEA programmatic requirements."
Data
Lead agencies are encouraged to consider data-informed decision-making, and continuous improvement when developing, implementing, and revising their general supervision system.
Lead agencies are encouraged to incorporate data-informed decision-making and continuous improvement procedures when developing, implementing, and revising their general supervision system.
Data-informed decision-making is an essential concept for improving results and outcomes for each and every child and their family, as well as ensuring compliance with IDEA requirements. Data-informed decision-making supports continuous improvement efforts and helps ensure that every child and family has access to and can fully participate in high-quality services and supports statewide.
When used as part of monitoring, data-informed decision-making also helps ensure that EIS programs and providers are effectively monitored and supported through the correction of noncompliance and ongoing continuous improvement activities.
Resources
- System Framework, Second Edition: Accountability and Quality Improvement Component (ECTA Center, 2026)
- Developing and Implementing an Effective System of General Supervision (National Center for Special Education Accountability Monitoring, 2007)
- Guidance on State General Supervision Responsibilities under Part B and C of the IDEA (July 24, 2023)
- Identifying, Correcting, and Reporting Noncompliance in Accordance with IDEA Requirements: A State Guide (NCSI, DaSy, ECTA, IDC, 2021)
- Look! Think! Act! Using Data for Program Improvement
- SPP/APR Package (See Part C SPP/APR Measurement Table and related requirements)
Instructions
Rate each item as Included, Developing or Revising, or Not Included. Cite Evidence for the rating (including where it is located). Take Notes related to the item (for example, specific information that needs modification).
You can modify the rating system so it provides the most useful information about your system's design and function.
I. Overview of General Supervision System
The lead agency is responsible for the general administration and supervision of all early intervention service (EIS) programs and providers as well as activities to ensure the state complies with IDEA Part C requirements. States should have a written overview of their general supervision system and how the various components connect to:
- Improve EI results and functional outcomes for infants and toddlers with disabilities and their families.
- Ensure that EIS programs and providers meet the program requirements of the IDEA.
- Ensure that the state has a system that collects and reports valid and reliable data.
The overview should describe how the lead agency:
- Conducts its integrated monitoring activities (which include ensuring and sustaining correction and improvement).
- Selects EIS programs and providers.
- Prioritizes specific compliance and results areas based on emerging issues and performance.
- Engages families, program representatives, and other partners, in meaningful activities.
- Collects, analyzes, and shares data to promote access to and receipt of authorized IFSP services.
Content can also help lead agencies as they develop the required description of their general supervision system in the introduction of the SPP/APR.
- Purpose and use of lead agency general supervision/monitoring procedures.
- Authority and role of the lead agency in supervision, monitoring, funding, interagency coordination, and other responsibilities defined in 34 CFR §303.120 and 34 CFR §303.700.
- How the integrated monitoring process aligns with the lead agency's mission, vision, and purpose of Part C.
- How the integrated monitoring process reflects and impacts the lead agency's current priorities.
- How compliance and results are addressed in alignment with RDA principles.
- Who conducts monitoring activities (such as the Part C monitoring coordinator, other lead agency staff, peers, and parents).
- Statement that all EIS programs and providers, including vendors, are subject to integrated monitoring at least once every six years under the general supervision system.
- Monitoring process(es) used for other state agencies who provide Part C services.
- Process used to identify, investigate, and address emergent issues.
- Role of the state ICC and other partners such as state and local administrators, families, and practitioners, in the development and implementation of the general supervision plan.
- How the state uses its data system as a component of its general supervision system.
- How the capacity and data literacy of families, program representatives, and other partners are supported to effectively participate in the review and analyses of the data, and the development and implementation of the general supervision plan.
- How the lead agency's fiscal monitoring is embedded in the integrated monitoring process, including how Part C Fiscal Monitoring Indicators for State Lead Agencies are selected and revised over time.
- How the state examines and analyzes data and other information from the child find system and conducts monitoring to ensure compliance with related requirements under SPP/APR C5 and C6.
- The interconnectedness of each of the following general supervision components to ensure implementation of IDEA:
- Integrated monitoring activities
- Data on processes and results
- SPP/APR
- Fiscal management
- Effective dispute resolution
- Targeted TA and PD
- Policies, procedures, and practices resulting in effective implementation
- Improvement, correction, incentives, and sanctions.
- A web link to information about the state's general supervision policies, procedures, and process that is made available to the public.
II. The Plan
The general supervision monitoring plan should include a clear and concise description of the states' integrated monitoring procedures. It should also include how families, program representatives, and other partners are engaged in related activities.
The integrated monitoring procedures should sufficiently describe:
A. Partner Engagement
- How families, program representatives, and other partners are engaged in the following:
- Developing the monitoring plan.
- Selecting the state priority areas or monitoring indicators.
- Selecting tools used to collect data on each monitoring indicator and state priority, including data elements and criteria for rating performance.
- Reviewing data and identifying strategies for making and sustaining correction and improvement.
- Reviewing and providing input on improvements and revisions to the monitoring plan and all its components.
B. Monitoring Cycle for EIS Programs and Providers (at least every six years)
- Frequency and process for monitoring programs and providers, such as annually, every two years, or when data trends or patterns warrant an investigation or additional monitoring.
EIS programs and providers must be monitored at least once every six years.
EIS program and provider monitoring can be simultaneous or separate.
C. Monitoring Indicators and Data Elements
- Complete list of monitoring indicators and additional areas to monitor, including those from the SPP/APR, fiscal, and OSEP stated priorities, such as IFSP implementation, Child Find, and Transition for EIS:
- Programs
- Providers
EIS program and provider monitoring can be simultaneous or separate.
- Procedures and timelines used to select, review, and revise the list of monitoring indicators, additional areas, and OSEP-stated priorities, such as implementation of IFSPs, Child Find, and Transition.
- Data elements needed to monitor each indicator, and additional areas, as well as source of the data are listed.
- Criteria that will be used to rate performance for each indicator, and additional area.
D. Monitoring Methods and Data Collection
- Process for scheduling integrated monitoring of EIS programs and providers at least every six years on SPP/APR indicators, additional areas, and OSEP-stated priorities.
- Method(s) used to monitor:
- EIS programs on SPP/APR indicators, additional areas, and OSEP-stated priorities.
- EIS providers on SPP/APR indicators, additional areas, and OSEP-stated priorities.
- Description of how child records are selected, including the number or percent of records, to ensure data accurately reflects an EIS program or provider’s compliance and that the child records data is representative of the population served by the EIS program or provider to ensure validity and reliability of the data
- Strategies used to improve reliability of monitoring? data collection and how these are implemented, such as:
- Clear standards for coding decisions.
- Training for consistent use of criteria for scoring monitoring tools.
- Methods for collecting the monitoring? data, such as the data system, desk audit, self-assessment, onsite review, interviews, family and provider stories, observation, record review, and how these are used to:
- Complement each other.
- Issue findings of noncompliance in a timely manner when identified, including correction in a timely manner.
- List of tools and criteria for rating each item during monitoring.
- Timelines for monitoring data collection.
- Process for periodic review and revision of monitoring methods and data collection.
E. Data Analysis (that provides conclusions regarding results and compliance)
- Process of verifying monitoring data to ensure validity, reliability, accuracy, and timeliness prior to analysis.
- Steps taken to ensure reliability of data analyses. These may include verifying results with multiple data sources and engaging multiple perspectives in the review of the analyses.
- Process for using qualitative data. These include interviews and family, and provider stories.
- How data are disaggregated by variables that can identify contributing factors impacting performance. These include age, race, gender, disability, family income, individual EIS providers or agencies, provider disciplines, and other data.
- Timelines for analyses.
- Process for analyzing, interpreting, and making conclusions about noncompliance and results, the need for correction, and/or improvement.
- Procedures for identifying noncompliance through the states integrated monitoring system.
- If applicable, a description of the procedures and timelines for pre-finding correction, which is permitting providers/programs to correct noncompliance prior to issuing a finding, including how the state verifies:
- Each instance of noncompliance was corrected.
- The program is correctly implementing the requirement and is at 100% compliance.
- Description of the timelines and how the state issues findings and whether findings are issued by the number of instances of noncompliance or by EIS program or provider.
- Description of how child records/data are selected to verify correction of noncompliance and how the number or percent of records are:
- Sufficient to reach a sound conclusion that the EIS program or provider is at 100% with the monitoring indicator or state priority.
- Reflects the population served by each EIS program or provider.
- Procedures for identifying the improvements needed and how progress is sustained over time.
F. Communication and Data Use (for improved results, correction of noncompliance, and continuous improvement)
- Methods used for public reporting of local performance to meet the 120-day timeline. Include how the lead agency establishes a common language for public understanding of the data.
- Description of the types of dissemination products that will be used to communicate conclusions.
- Procedures and timelines (generally within 90 days of identification) for communicating monitoring conclusions through notification of findings letter, monitoring report, and/or other correspondence.
- Description of content that must be included when issuing a finding of noncompliance:
- Description of noncompliance.
- IDEA requirement that is noncompliant.
- Data supporting the conclusion of noncompliance.
- Statement that noncompliance must be corrected as soon as possible but no later than one year from written notification.
- Any necessary corrective actions.
- Timeline for submission of corrective action plan or evidence of correction.
- Process for communicating required next steps related to correction of noncompliance and improvement.
- PD/TA process used to support and sustain improvement and compliance and how the PD/TA is tailored to EIS programs and providers to increase their capacity to identify factors that contribute to performance issues.
- State resources allocated to the development and implementation of effective correction or improvement strategies (including funding and people), and how these resources are targeted to EIS programs and providers based on contributing factors, performance, and identified EIS program or provider and population needs.
- Process to determine if the EIS program or provider is currently implementing IDEA requirements correctly by:
- Reviewing and tracking data.
- Documenting updated data, including the amount and frequency of the data.
- Reviewing subsequent data until the EIS program or provider has reached 100%.
- Process for ensuring, tracking, and documenting that all individual instances of noncompliance are corrected.
- Process and timelines for communicating written verification of correction according to federal requirements.
- Strategies used to facilitate correction of noncompliance and improve results. Include TA, corrective action or improvement plans, IDEA determinations, or sanctions.
- A description of the system of graduated and progressive sanctions to ensure correction of identified noncompliance and to address areas that need improvement.
- Procedures for developing annual local determinations process with criteria for performance and schedule for notifying EIS programs, including input from relevant partners. The process must include the following factors:
- Performance on compliance indicators.
- Valid and reliable data.
- Correction of identified. noncompliance.
- Other data available to the state about the EIS program's compliance with IDEA, including any relevant audit findings.
- Procedures for reviewing and revising the annual local determination process, including input from relevant partners.
- How continuous improvement strategies are aligned with existing early childhood and education initiatives, whenever appropriate.
The contents of this document were developed under a cooperative agreement #H326P220002 (ECTA Center) and grant #H373Z240001, from the Office of Special Education Programs, U.S. Department of Education. However, the content does not necessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement by the Federal Government.
ECTA Center Project Officer: Julia Martin Eile
DaSy Center Project Officers: Meredith Miceli and Alexis Lessans


