Procedural Compliance Review (PCR): The new form, data entry process, and corrective action

1. Procedural Compliance Review (PCR): The new form, data entry process, and corrective action 2008-2009 Regional SPR&I Training

2. Purpose • Understand general supervision and procedural compliance review (PCR) process – past and present • Review revised file review form and corresponding corrective action document • Demonstrate data entry process • Focused monitoring

3. Components of General Supervision Policies, Procedures, and Effective Implementation State Performance Plan Integrated Monitoring Activities Data on Processes and Results Fiscal Management Improvement, Correction, Incentives & Sanctions Targeted Technical Assistance & Professional Development Effective Dispute Resolution

4. Integrated Monitoring Activities Monitoring Priority Areas • Provision of a free appropriate public education (FAPE) in the least restrictive environment (LRE) • State exercise of general supervision, including child find, effective monitoring, the use of resolution meetings, mediation, and a system of transition services as defined in §300.43 and in 20 U.S.C. 1437(a)(9) • Disproportionate representation of racial and ethnic groups in special education and related services, to the extent the representation is the result of inappropriate identification

5. State Performance Plan – Part B • Indicator 1: Graduation • Indicator 2: Dropout • Indicator 3: Statewide Assessment • Indicator 4: Suspension/Expulsion • Indicator 5: LRE Placement • Indicator 6: Preschool Settings • Indicator 7: Preschool Skills • Indicator 8: Parent Involvement • Indicator 9: Disproportionate Rep. in Sped • Indicator 10: Disproportionate Rep. in specific disability category • Indicator 11: Child Find • Indicator 12: Part C to B Transition • Indicator 13: Secondary Transition w/IEP Goals • Indicator 14: Secondary Transition/Post School Outcomes • Indicator 15: Monitoring, Complaints & Hearings • Indicator 16: Written Complaints • Indicator 17: Due Process Hearings • Indicator 18: Hearing Requests that went to Resolution • Indicator 19: Mediations • Indicator 20: Timeliness of State Reported Data & Reports State Performance Plan

6. 3 Year PCR Cycle and the Ever Changing File Review Form • 2005 -2006 • Comprehensive file review • LEAs reported on approximately 100 standards • State identified 2717 findings (through file reviews only) • 100% compliance achieved by July 08 • 2006-2007 • Targeted file review, slight wording changes within standards • LEAs reported only on previous noncompliance (plus 11 required standards) • State identified 1095 findings (through file reviews only) • 99% corrected within one year!!! • 2007-2008 • Revised comprehensive file review with embedded directions • LEAs reported only on previous noncompliance (plus 11 required standards) • State identified 369 findings (through file reviews only) • Currently 66% corrected within one year

7. Average Number of Standards Reported on by Districts by Year 2717 findings 1095 findings 369 findings

11. What was learned from the last 3 years? • Districts were unclear about the annual process for reporting compliance and how/when/where to correct noncompliance • Confusion existed with the various file review forms (comprehensive/targeted/revised) • There was difficulty interpreting the standards as they were presented • Documentation of noncompliance and correction within SPR&I needed to be more specific and efficient

12. 2008-2009 PCR Process • File Review Form • Revised file review form to be comprehensive review (same content as first year with fewer standards) • Restructured standards to better stand alone and allow for tracking correction of noncompliance • Directions/guidance/citations included within form • Word document districts may edit format • Corrective action Document • Identified corrective actions for each standard • PCR Entry • Student by student data entry instead of aggregate findings across files • Increased efficiency for reporting to ODE

13. 2008-2009 File Review Form • Standards are numbered for easy reference (1-64) • Front end questions provide critical information to increase efficiency during data entry and aid in verification • Removes standards that don’t apply • SLD/Transition • Reduces the need for NA and required comments • Drop down menus for standards that still use NA • Follows the IEP form in content

14. 2008-2009 Required Corrective Action Form • Mirrors the file review form • Identifies specific actions districts must take when standard is verified as out of compliance • Districts may engage in corrective action prior to submission of PCR data, but should indicate noncompliance and corrected status at time of submission • Review additional files……

15. Correcting Noncompliance: Evidence of correction and evidence of compliance • No noncompliance is good noncompliance • All noncompliance must be reported • The state is required to track and report every instance of noncompliance until corrected • Correction must occur as soon as possible, but no later than one year from verified noncompliance • LEAs must provide evidence of correction by standard for individual files • When files cannot be individually corrected evidence of compliance needs to be established

16. Non-systemic Noncompliance (localized) • In the case of non-systemic noncompliance (<33% of files) for a standard that cannot be corrected by an individual file correction (e.g. 60 day evaluation) the ODE requires LEAs to: • Review an additional number of files equal to 50% of the original number of files reviewed (round up in the case of an odd number), and; • Report in SPR&I the number of files by SSID that are compliant and any that are noncompliant for that standard. • If after completing the additional file review, the LEA finds further noncompliance they will need to: • Conduct localized training on the noncompliance, and; • Conduct a third review of files (50% of the original number reviewed) on the same standard after the localized training, and; • Report on the number of files that are compliant (must be 100% for the ODE to sign off on the correction).

17. Systemic Noncompliance (District wide) • In the case of systemic noncompliance (>33% of files), the ODE requires LEAs to: • Complete individual file corrections where possible, and; • Conduct district-wide training on the noncompliance, and; • Conduct a second review of files (50% of the original number reviewed) on the same standard after the district-wide training, and; • Report on the district-wide training content, attendees, and date of training, and • Report the number of files that are compliant (must be 100% for the ODE to sign off on the correction). • If the standard involved a particular "age linked" requirement (ECSE; school age transition) or involved files from a unique program, then the replacement files need to target that age or program.

18. PCR Timeline • Districts received FFY 2006 final determination status in August • Any remaining noncompliance from 06-07 is now second year and must be corrected ASAP! • Corrections can be submitted to ODE • Must include SSID or additional file review as evidence of correction • Districts were also provided (by standard) their noncompliance from 07-08 submission • Corrections can still be made in the 2008-2009 Improvement plan Section 1-2 PCR Correction of SPR&I • ODE will sign off on correction when completed • 08-09 PCR submission open for entry mid October • Deadline for PCR submission will be March 27 to provide more time for correction within the one year time frame

19. New SPR&I PCR Data Entry Process • Student file list: • Still need to lock in students from the list generated by ODE • Algorithm: 25% transition, remaining students based on age and disability type using district disability distribution • Number of files remains the same as last year (see SPR&I overview document for table) • Charter school students already added to list • Districts with LTCT and/or YCEP contracts will need to add a student for each contract (see handouts on unique programs)

20. To access PCR entry from dashboard, select 08-09 year. This will take you to student file selection so you can lock in your students.

21. If you want to see more detail on your students, select More Details. This is your student file list. You can now see what shape the file is in once it is locked in and reviewed

22. To begin the lock in sequence for a student just click on any student in the list.

23. You will not be able to proceed if this is “No.” All of these questions will need to be answered. These help in determining which slides to include and in the verification of your submission by ODE personnel.

24. The system will alert you to missing or incongruent Information (e.g. date of birth and most recent IEP).

25. PCR Entry • Still using PCR sections like previous years • Comprehensive review for each student • Student by student entry with built in skip patterns (SLD-transition) based on information provided during file lock in sequence • Drop down menus for compliance status and comment when NA is allowable • When NA is an option we have provided most common reason, but districts can edit comment if needed • Comment still required when “No” is selected, meaning district identified noncompliance • If corrected before PCR submission, indicate “corrected at time of submission”

26. To begin the file review process for a student just click on any student in the list once they are all locked.

27. This shows you the section and standard being reviewed. These are the sections of the PCR review form just like previous years. To begin, just click on the section and that will show you the numbered standards within. Once a standard is completed, the system shows you your response (Yes/No/NA) next to the standard. In the case of non-transition age or students without SLD, those standards will not appear.

28. For each standard you will need to select “Yes”, “No”, or “NA” if allowed. If you elect “No” you will need to type in a comment. Once done, just hit save and Next. Hitting “Y” will automatically change the status to “Yes” to increase efficiency.

29. For those standards that include “NA”, we have provided the most likely reason for it in the comment box to increase efficiency. District may use that reason if appropriate, but can edit or alter the comment content if needed.

30. The Demo Site • http://sped.csgpro.com/new/ • User name: group1 group2 group3 group4 group5 • Password: tiger17 zebra78 horse41 duck93 beaver13

31. ODE Focused Monitoring • Focus monitoring will be based on: • Final Determination status • Level of noncompliance (PCR) within and across years • Performance indicators with a focus on • (B 1, 2, 3, 5, 14) • Policy to practice reviews for B4 • Compliance indicators with a focus on • (B4, 9, 10, 11, 13) • Policy to practice reviews for B9 & 10 • Legal findings (complaints/dispute/mediation)