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Gold ND Community CallFebruary 3, 2015

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Agenda

• “That Time of Year”: CSPR Data Submission• Peer-to-Peer Discussion: Questions from

Community Members• A Closer Look: Federal Monitoring• Review of Recent TA Requests • What’s New: NDTAC Products

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“That Time of Year”

CSPR Data Submission

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“That Time of Year”: CSPR Data Submission

Where are you in the CSPR data reporting process?• I’m having difficulty getting the last of the data

from some subgrantees• I’ve collected data from all subgrantees• I’m in the process of compiling the data and

checking for data quality • I’ve already submitted the data via EDFacts and

CSPR• I’m not entirely sure, the data people at my SEA

are taking care of the CSPR data

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“That Time of Year”: CSPR Data Submission

Are there any portions of the CSPR data reporting process that improved this year?• TA provided to subgrantees to

prepare them for the CSPR collection

• Subgrantee’s collection of data• Collection of data from your

subgrantees• Checking for data quality• Compiling the data from

subgrantees• Submission of data through

EDFacts and CSPR

Are there any portions where you would like to improve the CSPR data reporting process?• TA provided to subgrantees to

prepare them for the CSPR collection

• Subgrantee’s collection of data• Collection of data from your

subgrantees• Checking for data quality• Compiling the data from

subgrantees• Submission of data through

EDFacts and CSPR

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Peer-to-Peer Discussion

Questions from Community Members

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Peer-to-Peer Discussion: Questions from Community Members

• What changes are other SEAs making in light of the new OMB circular?

• What guidance do coordinators provide to subgrantees in order to ensure transition doesn’t start at the end?

• Have other SEAs drafted their own policies and procedures (not the Federal guidance) for administering Title I, Part D programs (i.e. funding, application review, etc.)?

• Any other questions?

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A Closer LookFederal Monitoring

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Monitoring Plan

• Office of Safe and Healthy Students (OSHS) Monitoring Plan for Homeless and Neglected or Delinquent Education Programs

• Revised December 2014• Reflects reorganization that moved the

Title I, Part D programs to OSHS

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Definition and Purpose

• Monitoring formalizes the integral relationship between ED and the States– Emphasizes accountability for using resources wisely in educating

and preparing our nation’s students

– Regular and systematic examination of a State’s administration and implementation of a Title I, Part D grant

– Necessary to ensure that all children have a fair, equal, and significant opportunity to obtain a high-quality education

– Assesses the extent to which States provide leadership and guidance for subgrantees in implementing policies and procedures that comply with the statutes and regulations of Title I, Part D

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Monitoring Process

• Preparation for Monitoring– OSHS staff will request that the SEA submit specific

documentation about eight weeks prior to scheduled onsite review

• Onsite or Remote Monitoring– OSHS staff will review additional documentation and will

interview SEA and LEA staff with program responsibilities

• Exit Conference– Monitoring team meets with the SEA to discuss potential

findings and recommendations that the team will likely cite in the monitoring report

– Responds to questions posed by the SEA

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NDTAC’s Role

• Prepare pre-monitoring reports for ED– Coordinator tenure

– NDTAC event participation (e.g., webinars, conference, topical calls) Provide TA in response to findings (past 3 years)

– TA requests (past 7 years)

– CSPR data (FY 13-14)

• Raise awareness about monitoring indicators• Direct States to Federal and NDTAC resources to

help Coordinators and subgrantees self-assess preparedness for monitoring visits

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NDTAC’s Role

• Observe monitoring visits to inform TA activities and future product development (with coordinator’s approval)

• NDTAC does NOT monitor States or provide guidance on the likelihood of findings

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Monitoring Indicators

• Used by ED to determine the degree of implementation of Federal

programs and activities administered by SEAs in three areas:

– Standards, Assessment and Accountability

– Instructional Support

– Fiduciary

• Criteria ensures a consistent application of these standards across

monitoring teams and across States

• Provide guidance for all States regarding the purpose and intended

outcomes of monitoring by describing what is being monitored and

providing the criteria for judging the quality of implementation

(acceptable evidence)

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Monitoring Indicators

Standards, Assessment and Accountability

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Monitoring Indicators

Standards, Assessment and Accountability

To what extent are your subgrantees meeting Subpart 3 program evaluation requirements?

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Monitoring Indicators

Standards, Assessment and Accountability

Guiding Question NDTAC Resources• How does the SEA ensure that students in Title

I, Part D programs receive instruction that is aligned with state standards and accountability?

• What is the SEA process for monitoring Subpart 1 and 2 programs from selection and notification to reporting and corrective action follow-up?

• Tip Sheet: Subgrantee Monitoring

• Title I, Part D, State Coordinator's Orientation Handbook (PDF)

• Compliance Isn't Built in a Day: The Importance of Ongoing Communication in Subgrantee Monitoring

• Subgrantee Monitoring: How do States Monitor Their SAs and LEAs?

• Innovative Approaches to Offsite Monitoring and TA Provision

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Monitoring Indicators

Standards, Assessment and Accountability

Guiding Question NDTAC Resources• What is the process for data collection that the

SEA uses to obtain demographic, academic and vocational outcome information on all Subpart 1 and 2 programs?

• How does the SEA evaluate statewide and subgrantee program performance and report the results of such evaluations?

• Title I, Part D, State Coordinator's Orientation Handbook (PDF)

• The Instructional Guide to Reporting Title I, Part D Data in the CSPR for SY 2013–14

• Resources and Tools for Title I, Part D Data Collection for SY 2013–14

• Measuring Program Success

• Making the Most of Your Data: Strategies for Evaluating Your Program

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Monitoring Indicators

Instructional Support

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Monitoring Indicators

Instructional Support

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Monitoring Indicators

Instructional Support

Guiding Question NDTAC ResourcesWhat are the SEA’s goals and objectives for the Title 1, Part D Program? Have they been reviewed and updated recently?

• Title I, Part D, State Coordinator's Orientation Handbook

• Collaboration and Developing State Plans How does the SEA inform SAs about their eligibility

and application requirements for a Title I, Part D subgrant?

• Title I, Part D, Program Administration Planning Toolkit

What technical assistance does the SEA provide the SAs on developing or revising their Subpart 1 applications?

• Title I, Part D, Program Administration Planning Toolkit

How does the SEA review and evaluate the Subpart 1 applications?

• Title I, Part D, Program Administration Planning Toolkit

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Monitoring Indicators

Instructional Support

Guiding Question (CONT’D) NDTAC Resources

Do institutionwide project plans include a comprehensive needs assessment across all education program services?

• Planning and Implementing Institutionwide Projects

• Tool: Institutionwide Project Planning Toolkit

How are the needs assessment, curriculum, plans for professional development and program evaluation aligned in institutionwide projects?

• Tool: Institutionwide Project Planning Toolkit

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Monitoring Indicators

Fiduciary

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Monitoring Indicators

Fiduciary

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• Discussion: What internal fiscal controls does your state have in place to account for the use of Title I, Part D funds in a way that meets Federal requirements?

Monitoring Indicators

Fiduciary

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Common Monitoring Findings and Recommendations

• State Plan (former Indicator 1.1)– Whether the content of the State Plan adhered to

Federal guidelines (e.g., insufficient or improper identification of State goals; insufficient descriptions of State activities and/or services)

– Extent to which States implemented their State Plan, including inappropriate allocation of Part D funds or lack of alignment between the content of the plan and how program activities were being conducted

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Common Monitoring Findings and Recommendations

• SA Application (former Indicator 1.2):– Extent to which SA Applications addressed all

statutory requirements (i.e., the 19 required elements)– Using an inappropriate application– Insufficient evidence that an application had been

approved by the SEA– Not using an application to allocate funds

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Common Monitoring Findings and Recommendations

• LEA Application (former Indicator 1.3)– Administering an application that did not meet all

statutory requirements (i.e., the 13 required elements)– Insufficient evidence that an application had been

approved by the SEA– Not using an application to allocate funds—that is, not

sufficiently identifying and inviting LEAs that serve students with the greatest needs to complete an application

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Common Monitoring Findings and Recommendations

• IWPs (former Indicator 2.1)– Insufficient monitoring of existing IWPs– SEAs not providing subgrantees an opportunity to

submit information related to IWPs on grant applications or for ensuring that each IWP submitted a plan

– Insufficient training and technical assistance to SAs

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Common Monitoring Findings and Recommendations

• Transition Reservation (former Indicator 3.1):– Insufficient evidence of reserving funds for transition– Not enforcing requirements to reserve funds or

reserving insufficient funds for transition– Questionable use of the transition reservation– Inappropriate oversight of transition reservations

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Common Monitoring Findings and Recommendations

• Subgrantee Monitoring (former Indicator 3.2):– No evidence of subgrantee monitoring– Insufficient subgrantee monitoring– Use of informal and unsystematic monitoring

protocols– Faulty data collection processes– Insufficient use of program evaluation information.

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Review of Recent TA Requests

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Review of Recent TA Requests: Eligibility of Mental Health Facilities

I have a local facility providing mental health services to youth who have been voluntarily placed there that would like to apply for Title I, Part D funds, would it be considered a neglect facility?

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Review of Recent TA Requests: Eligibility of Mental Health Facilities

• Facilities are counted as “neglected” or “delinquent” in

accordance with the definitions set forth Section 1432 of the Part

D statute. Annual Count Toolkit also walks through this.

• This facility does not seem to fall neatly within the types of

facilities defined, potentially because they use different

terminology.

• To confirm facility eligibility consider requesting that subgrantees

and facilities submit (to the SEA) relevant facility information:

1. Charter or mission statement

2. Information about the type of children and youth typically served

3. Whether the facility’s regular program of instruction is funded with

State, local, or private funding

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Review of Recent TA Requests: Subgrantee Monitoring Frequency

Is it a requirement in the statute for the SEA to monitor their subgrantees once every three years?

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Review of Recent TA Requests: Subgrantee Monitoring Frequency

This request has gone to OGC for clarification, but here are some other considerations:• There should be some form of regular desk

monitoring or review that can be tied into the application review, as well as review of annual performance and fiscal data.

• Remote interviews and written reports that may require corrective actions, there are no Federal requirements that specify a minimum.

• Recommendation that all grantees have this kind of review at least once every 3-5 years depending on how they fare in an annual risk assessment.

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Review of Recent TA Requests: Data Storage

What is the expected policy for storing CSPR/EDFacts data (e.g.,

how long must it be maintained)?  

• One source at the state indicated they should keep data for 3

years—however this couldn’t be substantiated by any known law.

• They want to ensure they have sufficient records in case of a

lawsuit, which would require them to store records up to 6 years.

• They would like to make it a state policy to store records up to 7

years, a practice their CSPR coordinator already follows. The

CSPR coordinator then archives the data for backup.

• The state is interested to know if there are existing Federal

regulations for data storage and want to align their policies with

Federal recommendations.

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Review of Recent TA Requests: Data Storage

This request has gone to OGC for clarification, but here are some other considerations:• OESE manually closes out formula grants to States about

four years after they are awarded. For example, they close out FY 2011 grants by September 2015.

• Should not have to save documents for more than 3 – 5 years after closeout

• Hopefully SEAs are maintaining longitudinal databases or summary trend reports of performances

• Actual physical or electronic copies of individual grantee performance don’t have to be stored, nor multiple copies or earlier draft copies of data

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What’s NewNDTAC Products

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NDTAC Updates: New Resources

Youth with Special Education Needs in Justice Settings• NDTAC Fact Sheet: Youth with Special Education Needs in J

ustice Settings (PDF)

• N&D Infocus: Supporting Youth with Special Education Needs in Justice Settings (webinar)

Federal guidance• Correctional education in juvenile justice facilities:

http://www2.ed.gov/policy/gen/guid/correctional-education/index.html

• English learner students’ access to education: http://www.ed.gov/news/press-releases/us-departments-education-and-justice-release-joint-guidance-ensure-english-learn

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NDTAC Updates: Forthcoming Resources

NDTAC tip sheets:

• Beginning With the End in Mind: State Title I, Part D Logic Model Development Guide for Youth Who Are Delinquent and Neglected

• Determining the Title I, Part D Eligibility of Students Who Have Earned a High School Diploma or GED 

• Transition Services That Support Positive Educational and Vocational Outcomes for Justice-Involved Youth: Overview and Funding Sources

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NDTAC Updates: Upcoming Calls and Events

NDTAC national conference• 19-21 May 2015

Topical calls• Improving Data Quality and Use• Subgrantee Monitoring Tools• NDTAC Resources to Support TA Needs

Community calls• 2 June 2015