Special Education Compliance and the

SC Public Charter School District

Post-Onsite VisitApril 10, 2013

Agenda Onsite Review Small Group Discussion The District The Process

Interventions Referrals Letters of Notification Evaluations IEP Development Progress Monitoring Summary/PWN Special Reviews vs Annual Reviews Reevaluations Exiting Transfers

The IEP Folder Moving Forward

Denial of FAPE Small Group Discussion Corrective Action Plan

Introductions

Post-Onsite Review

SCDE Onsite Follow-up On March 6, 2013, the district received official

follow-up from the SCDE regarding their onsite visit.

What was received: Individual file feedback Global feedback from pre-submission documents:

Student handbooks District Policies School-Level Procedures

SCDE Onsite Follow-up Brief overview of the findings:

Commendations: The SCPCSD offers choice for SWD OEC appreciates the revised language in the

SC Charter School Law re: District Responsibility

General education staff understands IDEA and special education

Offer multiple ways of conducting meetings District professional development is articulated

SCDE Onsite Follow-Up General Area of Concerns:

Procedural issues such as PWN and meeting notifications

Parents may be less involved with their children’s special education programs

Postsecondary transition Large number of “special reviews” that

took place prior to the onsite visit

SCDE Onsite Follow-up Citations

24 out of 24 IEPs cited for noncompliance 19 out of 19 additional folders reviewed from the

two schools cited for noncompliance

Additional Citations: Certification: Services not being delivered by an

appropriately certified and highly qualified teacher Policy/Procedures: Schools didn’t have written

procedures (specific to the school) and District didn’t have their procedures (monitoring/oversight) in writing

SCDE Onsite Follow-up

IEP Compliance: Top Areas of Noncompliance

Are children with disabilities achieving at high levels? Q55: Severity of Disability Statement in PLOP (N=9) Q60: PLAAP (N=8) Q62: Annual Goals Relating to Disability (N=14) Q63: Other Annual Goals (N=11) Q65: Progress Measured (N=8) Q66: When Progress Reported (N=8) Q69: Nonparticipation with Nondisabled (N=13)

Are youth with disabilities prepared for life, work and postsecondary education? Q34: Strengths Considered (N=7)* Q77: Meeting Notice (Transition) (N=8)*

Does the District implement IDEA to improve services and results for children with disabilities? Q6: Parent Right to Assessment (N=7)* Q23: PWN Completion (N=19)

SCDE Onsite Follow-up What does the results from the previous slide

tell us?

Many of our IEPS lack basic IDEA compliance.

Small Group Discussion Groups:

What are your thoughts to the results of the onsite? Are you surprised? What are some of the barriers you face regarding maintaining

minimal compliance at your school?

Groups will be reporting out

Nichole Peggy Karen Samantha

Pam Mariann

Margie L. Marlene Tia Roxane Lucia Shelia

Lisa Marva Leslye Amanda

Margie P.

Jan

The District

The District Growth:

4 school 7 schools 11 schools 13 schools 17 schools (11,500 students) 25 schools (13,500 students)

*Projected 13/14

From hand-holding to Authorizer

What is an Authorizer Maintain High Standards:

Sets high standards for approving charter applicants. Maintains high standards for the schools it oversees. Effectively cultivates quality charter schools that meet

identified educational needs. Oversees charter schools that, over time, meet the

performance standards and targets on a range of measures and metrics set forth in their charter contracts.

Closes schools that fail to meet standards and targets set forth in law and by contract

What is an Authorizer

Authorizers (referred to as “sponsors” in South Carolina regulations and statutes) are charged by law to determine which charter schools should open and which ones should close. They monitor the progress of charter schools and support accountability and achievement while protecting school autonomy. Authorizers are not accountable for the success or failure of the charter schools it sponsors. Rather, they are responsible for holding charter schools accountable for their outcomes.”

The primary role of the SCPCSD is to authorize high-quality charter schools and to monitor the operation of the schools to ensure quality outcomes. A secondary role is to support the district’s charter schools as a local education agency (LEA) and to provide limited programmatic assistance to these autonomous schools.

It goes beyond “we’re an authorizer.”

Other Things to Note SC Charter School Law LEA Status Federal Funds Mandated Responsibilities

Subrecipient Monitoring In the SCDE’s Eyes Corrective Action Plans It’s the Law . . . IDEA is a federal law.

District Corrective Action Plan District creates and implements a district-wide monitoring

plan that includes a formal compliance process and sanctions (8/15/2013).

Provide staff training on the evaluation process/IEP Compliance.

Require schools to submit monthly updates to District regarding evaluations in process

Provide tailored and specific technical assistance to individual charter schools through the creation and assignment of a regional coordinator.

Create an IEP compliance checklist that is used at the school level for peer review.

Individual Student Corrections (10/15/2013). Develop a process to verify certification/qualifications of all

service providers.

Next Year What should you expect:

Regional Coordinator School-Specific Tailored Support and

Development Regional TA

Accountability Rubric/Monitoring Framework

The IEP ProcessFrom Referral to Exit and all stops in-between

Interventions

Before the referral Adequate instruction in reading and

math What instruction has happened in addition

to, on top of, and besides the general instruction that all children get?

How has the student responded to this additional instruction?

Progress monitoring data (CBMs, behavior tallies, anecdotal records)

Interventions by any other name smell ….

All schools’ charters say that you have some sort of intervention, student assistance, RtI process.

It’s not a special education issue; it’s part of just plain good teaching.

If the student is achieving at a low level, how do you know it’s because of a disability?

RtI gives you that info Determine where the student is now Set a goal for him Monitor his progress If he isn’t making progress (3 – 4 data

points below the goal line), then make a data-driven decision

Academics Reading, math, writing

Behavior Behavior plan to address the issues

DATA, DATA, DATA

Referrals

Child Find Part C (BabyNet) Parent School official

Responsibility If anyone at the school has reason to

suspect the child may be “a child with a disability” as defined by IDEA, you have to refer even if the parent does not want you to

If anyone at the school has reason to suspect the child may be “a child with a disability” as defined by IDEA, you cannot delay the referral to put the child through an RtI process.

Do not ever say:

“We can’t refer him until we’ve done RtI”

Evaluations

Purposes of Evaluation

To see if the child is a “child with a disability” as defined by IDEA 2004

To gather information that will help determine child’s educational needs

To guide decision making about appropriate educational program for the child

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Does the child have a disability that requires the provision of special education and related services in order for the child to receive a free appropriate public education (FAPE)?

What are the child’s specific educational needs? How does the child’s disability affect his/her

academic achievement and functional outcomes? What special education services and related

services, then, would be appropriate for addressing those needs?

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The “What” of Evaluation

health vision hearing social and emotional status general intelligence academic performance communicative status motor abilities

All areas related to the suspected disability, including (if appropriate):

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Comprehensive Equals…Identifying all of the child’s special education and related services needs, whether or not commonly linked to the disability category being considered for the child:

If eligible, this information = PLAAFP

If not eligible, this information helps to determine appropriate supports needed in general education

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Initial Evaluation and Eligibility

Two prong testIs this child a “child with a

disability” as defined in IDEA? AND

If so, does the disability create the need for special education and related services in order for the child to access and progress in the general curriculum?

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Initial Evaluation: Two-Prong Process Does the child have a disability AND

by reason thereof, Does the child need special education and

related services?

To answer these questions, the team must: must determine present levels of academic

achievement and functional performance focus on child’s needs in general education

curriculum

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Consent to evaluate Consent must be informed

Parent is told what he/she is giving consent for What additional information/in what areas is being

requested

Consent must come after the evaluation planning team determines what additional information is needed

Consent is not a “blanket” consent, but is consent to gather the information the team has determined is NEEDED/NECESSARY in order to determine eligibility

Timeline ALL information requested by the team

MUST BE gathered within 60 calendar days of receipt of the PPT

Develop a system to ensure you’re following up with all people involved in gathering the additional information

OT PT SLT School psychologist Nurse Parent Teachers ……..

Reevaluations

Questions to be answered by a reevaluation

1. Does the student continue to have a disability or to have an additional disability?

2. Does the student continue to need sp ed?

3. What are the student’s present levels of education need?

4. Do any changes need to be made to the IEP?

Reevaluation team reviews

existing information The IEP team schedules a reeval meeting

Same requirements as for any other meeting (Excent Notice, contacts, …)

The IEP team reviews existing information and determines what, if any, additional data are needed to determine continued eligibility and answer the other 3 reeval questions What do we already know about the student? Where is he currently functioning? What services is he currently receiving? Has anything significant changed since the last

evaluation/reevaluation?

No additional data needed to answer all 4 reeval questions

PWN to propose evaluation, to notify parents that no additional information is needed to determine eligibility, and to give reasons for that decision given to the parent BEFORE these things can be done

PWN also notifies parents of their right to request

an assessment

Additional data ARE needed PWN to propose reevaluation, to

describe what additional information is needed to answer all 4 reeval questions, when it will be collected (completed by…), and who will collect it given to the parent BEFORE these things can be done

Parent consent to reevaluate obtained

Once the info is gathered, the team meets to review the info and answer the 4 reeval questions

If the student is determined to continue to be eligible and to need sp ed services, the team reviews and revises, if necessary the existing IEP based on the data collected

PWN is given to the parent BEFORE the changes are initiated

Reevaluations Must be completed by the due date

(whether it’s the triennial date or the date set by the team for an “out of cycle” reeval)

Completed means Existing info reviewed Any additional info collected Additional info reviewed Continued eligibility determination made

Initial Evaluations and Reevaluations

The school-level special education coordinator is responsible for coordinating all initial evaluations and reevaluations and ensuring that the evaluations and reevaluations are completed within time lines This means coordinating any outside assessments

the team has requested (OT, speech, doctor’s documentation for OHI)

Staff assigned to gather additional information as part of initial evaluations and reevaluations are responsible for notifying you as soon as he/she has gathered his/her assigned information

Develop a system to ensure you’re following

up with all people involved in gathering the

additional information

Letters of Notification

Letter of Notification IEP meeting notifications must include

the purpose, time, and location of the meeting and who will be in attendance. This is why an email asking the parent to attend a meeting doesn’t suffice (even if they attend).

Letter of Notification So there has to be documentation that a formal invite that

included all of the above was provided.

Which one shows that proper notification was provided: “Email” “Email with invitation attached?”

Does this make sense? One notification method that says “phone.” What if the parent does not attend and one of the two

notifications were “phone?”

Even if the parent attends, the meeting could be determined null and void if proper notification wasn’t provided.

The IEP Process

The following slides were adapted from a presentation conducted by the SC Department of Education, Office of Exceptional Children.

Four Goals for Meeting the Needs of Students with Disabilities

1. Provide access to the general education curriculum

2. Provide involvement and participation in the general education environment

3. Implement individualized interventions4. Show progress in the educational standards

of the general education curriculum to the greatest extent possible

IEP Section IStudent Information

The percent of time the student spends in the regular education environment auto populates from Placement History.

IEP Section IStudent Information

“Date of IEP Meeting” reflects: Date of Initial IEP meeting or; Date of Annual Review

“Date of Special Review” changes whenever additional meetings are held throughout the school year

Remember that the IEP Initiation Date is either the first day of the following school year (If Not Birthday IEP) or reflects a change during the school term and you MUST provide PWN to explain the reason for the change

IEP Section IParent/Guardian Information

This section of the IEP is updated through Power School

Check frequently to ensure that Parent/Guardian Information is current and accurate

IEP Section ITransition

Check Yes for any student that: will reach the age of thirteen during the active dates of the

IEP; or is age 13 to 21 during the active dates of the IEP

The student must be invited to the first transition meeting as well as to all subsequent IEP meetings and “to discuss transition services” must be checked on the

Letter of Notification

IEP Section IStudent Interests and Preferences

Global statement describing the “student’s” interests and preferences

Interests and Preferences can be derived from: Formal and informal (documented) interviews Formal and informal interest inventories NOT just a copy/paste from the previous IEP

IEP Section IStudent Interests and Preferences

Example

IEP Section IPost Secondary Goal(s)

A Post Secondary Goal is: Articulation of what the student would like to achieve after

high school phrased in the form of a measurable goal Based on age-appropriate transition assessment Based on student’s strengths, preferences and interests Written for both education or training and employment When appropriate, written for independent living Education or Training must be separate from

Employment

IEP Section IPost Secondary Goal(s)

Post Secondary Goals are:

“Measurable”

Based on an outcome and not an activity or process Do not use action verbs like “seeks”, “pursues”,

“continues”, “learns” and “applies” as these terms are processes and not outcomes

IEP Section IPost Secondary Goal(s)“Helpful Formula”

IEP Section IPost Secondary Goal(s)

Example

Non-Example

IEP Section ISC Career Cluster

School can use up to sixteen clusters for reporting purposes but may modify these clusters (for example, Arts and Humanities in place of Arts, Audio-Video Technology, and Communications).

ONLY put a cluster (cluster combination) that your school offers)

The sixteen state clusters are the same as the sixteen federal clusters

Defined Program Grades 9-12 Regulation No.: R43-234 http://www.careertech.org/career-clusters/glance/careerclusters.ht

ml

IEP Section ICourse of Study

For any student who is, or who will reach the age of transition, the Course of Study provides a description that is:

Driven by the student’s interest and;

Linked to the selected SC Career Cluster

The only options in our District: Standard Course of Study towards a HS diploma Modified/Functional Course of Study towards a district attendance credential Standard Middle School Focus Modified/Functional Middle School Focus

IEP Section ICourse of Study

Example

Non Example

IEP Section ITransition Services

If any Transition Service is selected there must be a corresponding goal.

It is possible for one goal or goal and objectives to support multiple Transition Services

At a minimum, “Instruction” is checked. Let’s talk about “development of Employment and Post School Objectives when we talk about transition assessment.

IEP Section IDiploma/Certificate

If District Attendance Credential, the IEP team must ensure that the parent(s) and the student understands that this is not a State High School Diploma

When Regular State High School Diploma is selected, the Anticipated Date of Graduation can be updated by the IEP team as appropriate

We do not offer: Occupational credential, State Certificate, or N/A for GED Program

IEP Section IAge of Majority

Be sure to inform any student that will, or has reached age of majority, of his or her rights under IDEA.

This must be completed not later than one year before the child reaches the age of majority under the state law. This notification form is on SharePoint

IEP Section II“The Foundation”

This is the basis from which all other Individualized Education Program (IEP) components are developed

IEP Section IIAcademic and Functional Strengths and Needs

Describing Academic and Functional Strengths and Needs provides an overview of factors that impact performance and the development of services and programs designed to meet the student’s unique learning needs

IEP Section IIAcademic and Functional Strengths and Needs

Example

Questions

What is Josephina’s area of weakness? What is Josephina’s area of strength? What type of Present Levels of Academic Achievement and

Functional Performance might be developed? Might Josephina require any instructional accommodations?

IEP Section IIAcademic and Functional Behavior

If a Functional Behavioral Assessment is warranted, this must take place as part of an evaluation or reevaluation of the student unless it is the practice of the district to conduct a Functional Behavioral Assessment for any student to include students without disabilities.

IEP Section IIPresent Levels of Academic Achievement and Functional Performance (PLAAFP)

The (PLAAFP) Identifies Educational Need Serves as a baseline or starting point Is directly connected to goals and services

IEP Section IIPresent Levels of Academic Achievement and Functional Performance (PLAAFP) Example

Recalling Josephina’s description of Academic and Functional Strengths and Needs, does the PLAAFP address all areas identified?

IEP Section III Accommodations to the General Curriculum

Accommodations : Do not reduce learning expectations Provide access by enabling the student to participate more

fully in instruction and assessment Permit the student to better demonstrate skills Must be part of daily instruction Should never be introduced for the first time when a student

is participating in state-wide or district assessments

IEP Section III Modifications in the General Curriculum

Modifications: Change learning expectations Must be clearly described

IEP Section III Supplementary Services

Supplementary Services: Aids services and supports that can be provided in general

education, education-related settings and in extracurricular and nonacademic settings

Supplementary Services: Might include parent training, providing the student with a

one-on-one assistant, or providing staff with professional development to assist in meeting the unique needs of the student

IEP Section IVIEP Goals and Objectives

Annual Goals must: Directly link to the Academic and Functional Strengths and Needs,

PLAAFP and when applicable, the Transition needs of the student

Annual Goals tell us: What we expect the student to learn or be able to do in 1 year; and How we will know when the student has learned or demonstrated

that he can do it

IEP Section IVIEP Goals and Objectives

The essential characteristics of IEP Goals are that they must be measurable and be measured

If an IEP Goal is not measurable it violates the IDEA and may result in the denial of a Free Appropriate Public Education (FAPE)

If a Goal is not measured that violates the IDEA and may result in the denial of FAPE

Bateman & Herr, 2006

IEP Section IVIEP Goals and Objectives

Every Measurable Goal Must: Allow a clear yes or no determination of whether or

not it has been achieved Pass the “stranger test” (IEP Team Members can

agree if the goal has been achieved)

IEP Section IVIEP Goals and Objectives

Objectives/Benchmarks “Spell out” what the student will need to do

to complete the annual goal. Are the same skill in each benchmark with

degree of proficiency to which the student performs the skill changing from benchmark to benchmark

Measurable Annual GoalsCritical Components

Behavior – clearly identifies the performance being monitored; “Jeremy will read aloud”

Condition – describes what must be present for the student to demonstrate the skill or behavior at the expected level of performance; “when presented with a passage from the 2nd grade curriculum”

Level of Proficiency – how many, how often, to what standards the behavior must occur; “48 words per minute with less than 2 errors”

Measurement – as measured by; “as measured by weekly one minute oral reading fluency probes”

Timeframe –may be included; “In 36 weeks”; “by the end of the 2012-2013 school year”

IEP Section IVIEP Goal Example

In 36 weeks, when presented with a passage from the 2nd grade reading text, Jeremy will read aloud from 38 to 48 words per minute with less than 2 errors as measured by weekly one minute oral reading fluency probes.

Location of ServicesSpecial Education ClassroomVirtual Special Education Classroom

Not “virtual classroom”

IEP Section IVIEP Goal and Objectives

Remember, for any student that participates in the SC-Alt (Alternate Assessment), the IEP team must develop goals AND objectives for any area of need identified in the PLAAFP.

IEP Section VTime

Special Education and Related Services must be denoted in MINUTES

Subtract the total MINUTES in special education and related services from the total amount of minutes in the school week

IEP Section VRelated Services

Related Services are: Supportive services provided to students with disabilities to

assist them in benefiting from Special Education Like the need for special education, determined on an individual

basis as part of the IEP process Connected to other parts of the IEP to include, Functional

Strengths and Needs and the PLAAFP Accompanied by measurable annual goals that are denoted in

section IV IEP Goals and Objectives

IEP Section VRelated Services

The IDEA regulations contain a list of related services IEP teams can consider and they include: Audiology, Counseling Services (including rehabilitation

counseling), Early Identification and Assessment of disabilities in children, Interpreting Services, Medical Services, Occupational Therapy, Orientation and Mobility Services, Parent Counseling and Training, Physical Therapy, Psychological Services, Recreation, School Health Services and School Nurse Services, Social Work Services in Schools, Speech-language pathology services and Transportation

IEP Section VIParticipation in Statewide Testing

Consideration for the use of Accommodations and/or Modifications for Statewide Testing should: Be based on individual

student need and; When selected, must

be clearly reflected in IEP Section III – Accommodations to the General Curriculum

IEP Section VIIISpecial Factors The Team Must Consider In The Development of the IEP

IEP Section IXLeast Restrictive Environment (LRE)

LRE Considerations The team must

document the extent, if any, that the student WILL NOT participate with non-exceptional students in the general education classroom

IEP Section IXReporting to Parents

The IDEA requires every IEP to include a description of how the child’s progress toward annual goals will be measured and when periodic reports will be provided.

If your district chooses to send reports home, determine how often they will be sent and be sure to adhere to this timeline

Many districts report on progress for students with disabilities at the same time they report progress for general education students (quarterly).

IEP Section XTeam Members

Summary and PWN

Meeting Summary Required per District Policy

Not meant to be a transcription Purpose is to capture the gist/flow of an IEP meeting Purpose is to discuss requests/disagreements Every parental request needs to have closure

Parent asked for a in-home teaching assistance. The team discussed and determined that based on present level data, the child is able to receive FAPE through the proposed services of virtual services.

Common mistakes noted: Wrong date of the meeting Not noting proper meeting membership

Tips for Taking Notes – See Handout

PWNs Top 5 things found on PWNs:

We considered sending the kid back to his home school.

We considered nothing. We considered discontinuing services. We prosed to conduct an annual review. Meeting letter says “invite to special review,” but

PWN says conducted annual review.” We made changes to the present levels (nothing in

section C checked). Considered but rejected requiring the child to take

medication.

PWNs Let’s talk about what these questions mean:

As a result of the IEP/Staffing meeting, the IEP/Staffing Team proposes or refuses to.

Explanation of why the school district/agency proposes or refuses to take this action.

Description of each evaluation procedure, assessment, record, or report the school district used in deciding to propose or refuse the action.

Description of any other choices that the IEP team considered and the reasons why those choices were rejected.

Description of any other reasons why the school district proposed or refused the action.

PWNs The parent MUST have a copy of the PWN prior to implementing the

IEP.

If the parents attends the meeting and does not leave with a copy of the PWN, the IEP cannot be implemented until after the PWN has been sent.

If parents did not attend, the IEP cannot be implemented until after the PWN has been sent to the parents.

What does this mean? Give the PWN at the meeting (along with the IEP) Wait 5 – 7 days after the meeting to initiate the proposed FAPE

Initiation date must reflect this on the cover page of the IEP) Cannot extend past the expiration date of the IEP to “wait” to give the PWN.

Progress Monitoring

Progress Monitoring Using the PM report in Excent Documenting progress towards each

annual goal Provided to parents on the schedule

dictated in IEP At least as often as gen ed, but not less

than every 9 weeks

Purpose“When the cook tastes the soup, that formative; when the guests taste the soup,

that’s summative.”Robert Stake

“As the cook, or teacher, we need to stop and taste the soup before we move forward with instruction. We need to design instruction so students can press the reset button and go back to learn what they missed the first time. We can use many techniques to assess student achievement and understanding.”

If you wait until the end of the year to monitor progress, you have run out of time to change instruction.

Collecting progress monitoring data drives/guides instruction.

Examples Updates of baseline data from PLPs

CBMs Data sheets for time on task, assignments

completed Discipline referrals

Description of progress (more than “progressing”)

Answer the question “Where is Robbie now?”

Special Review vs Annual Review

Special Review vs. Annual Review

Special Review Can be done with an

agreement to amend an IEP

Only update certain areas of present levels

Something needs to be changed (updated) for EVERY special review (most likely in the PLOP)

Annual Review Updated 100% of

the present levels with CURRENT present level data

ExitingServices & Students

Exiting = ReevaluationUnless the student is graduating with a regular high school diploma or aging out at age 21, he/she can only be exited through a reevaluation.

Transfers into the District

Written, school-level procedures

How to you identify newly-enrolled students who have IEPs?

How/who requests records? What happens if you don’t get records

within 5 days? Once you get records, what happens?

1. Comparable services meeting 2. Comparable services form and transfer

IEP uploaded into Excent3. Communication with general and

special education teachers about comparable services

4. IEP meeting w/i 30 days to either Adopt the transfer IEP (on our forms) Write your own IEP based on new data

collected

“Comparable” services

Not going from 1950 minutes of special education services to 60

Not dropping the behavior/counseling goal because “we don’t do that here”

Not dropping the fine motor goal because “we don’t have an OT”

30-day IEP meeting

Team can only make changes if there are new

data to support making changes

30-day IEP meeting Treat as a special review (typically) Update PLPs Make any changes, BASED ON NEW

DATA, that are needed in the goals, accommodations, services,…

The IEP Folder

The IEP Folder Simply put, EVERY CHILD who has/had an

IEP at your school needs to have an IEP folder.

These files need to be kept for 5 years after the child exits.

Things that are embarrassing: 2 years in and the only file in the folder is a

meeting notification from 18 months ago. The only files are non-signed IEPs.

IEP Folder

What happens with the “signed IEP” (hand written one with markups)?

What happens to your signature page?

Moving Forward

Citations IEP Compliance:

Top Areas of Noncompliance Are children with disabilities achieving at high levels?

Q55: Severity of Disability Statement in PLOP (N=9) Q60: PLAAP (N=8) Q62: Annual Goals Relating to Disability (N=14) Q63: Other Annual Goals (N=11) Q65: Progress Measured (N=8) Q66: When Progress Reported (N=8) Q69: Nonparticipation with Nondisabled (N=13)

Are youth with disabilities prepared for life, work and postsecondary education? Q34: Strengths Considered (N=7)* Q77: Meeting Notice (Transition) (N=8)*

Does the District implement IDEA to improve services and results for children with disabilities? Q6: Parent Right to Assessment (N=7)* Q23: PWN Completion (N=19)

District Corrective Action Plan District creates and implements a district-wide monitoring

plan that includes a formal compliance process and sanctions (8/15/2013).

Provide staff training on the evaluation process/IEP Compliance.

Require schools to submit monthly updates to District regarding evaluations in process

Provide tailored and specific technical assistance to individual charter schools through the creation and assignment of a regional coordinator.

Create an IEP compliance checklist that is used at the school level for peer review.

Individual Student Corrections (10/15/2013). Develop a process to verify certification/qualifications of all

service providers.

Denial of FAPE Meetings

Denial of FAPE For anytime a potential denial of FAPE took

place (i.e. services didn’t happen as they are written, procedural compliance), an IEP TEAM needs to meet to discuss what, if any, negative impact took place.

How not to decide this: The principal says we’ll provide two make up

sessions We missed 3 sessions so we’ll make up 3

sessions

Denial of FAPE cont. How this is decided?

Two questions: What is the child’s present levels (IN ALL

AREAS)? Based on data, previous progress, and

parental input, what does the IEP team think the child’s present levels would look like if the A, B, and C compliance issues never took place.

Denial of FAPE cont. What if the scales are tipped (where the child should be versus where

the team thinks the child should be)? A negative impact took place:

Develop a Compensatory Service Plan amount of services needed to make up the deficit location of services person providing services measurement of progress documentation of provision of services

Where/How this is documented? SERIOUSLY . . . . NO SHORTCUTS WITH THIS!

Sample Meeting Agenda, Summary and PWN: See Handout

Small Group Discussion As you think about your next steps at your

school (i.e. a corrective action plan): What do you do with the information you

receive? How do you share your wealth of knowledge?

How are you going to ensure compliance within your own staff (teachers)?

How are you going to ensure compliance for your related service providers (contract providers)?

Corrective Action Plans Sample Plan

School Action Plans Action Plan Components:

Area of Non-Compliance Root Cause Corrective Action Plan Personnel Responsible Date for Completion

Due Date: April 30, 2013 ALL SCHOOLS