Part C State Annual Performance Report (APR) for FFY 06/SFY 07

Overview of the Annual Performance Report Development:

The Illinois' State Performance Plan and APR response to Indicator 9 have been updated to reflect changes in its general supervision system. Illinois has been among the states that defined noncompliance by individual instances, rather than grouping those individual instances as a single finding under an EI services program (i.e., by CFC). In addition, past SPP/APR Indicator 9 documentation had emphasized a broader look at noncompliance in areas other than the monitoring priorities of Indicators 1, 2, 7, 8a, 8b, and 8c.

Illinois' system of data collection, analysis, and reporting has been described under the preceding indicators. This system involves monthly reporting to CFC offices on 32 data elements and the use of selected elements for incentive payments or penalty adjustments as part of a performance contracting system. Currently, Illinois has quarterly penalty adjustments related to noncompliance with indicators 2 (natural settings) and 7 (45-days). System data are also used in setting determinations as required in Section 616 of IDEA. In preparation for full implementation, determination methodology, scores, and designations (i.e., meets requirements, needs assistance, needs intervention, or needs substantial intervention) for FFY 06/SFY 07 have been shared with CFC offices. The EI specialist assigned to each office with noncompliance has met with the CFC office to discuss issues related to noncompliance, as well as help develop strategies to ensure compliance within one year. In FFY 07/SFY 08, Illinois will establish a formal system of written notification, tracking and documentation of correction of noncompliance, and enforcement actions, when indicated.

System data are supplemented by on site monitoring activity. As part of a contractual agreement with the lead agency, the Illinois EI Monitoring Program conducts on-site monitoring visits to the 25 CFC offices. Several elements of the monitoring tool can be tied to priority indicators. Correction of noncompliance reflected by these elements is included in the Indicator C-9 Worksheet, below. Following monitoring visits, CFC offices submit a corrective action plan for approval and areas of noncompliance are reviewed for full compliance at the CFC office's next monitoring visit. In FFY 06/SFY 07, all but one CFC scored favorably on the following item. "There is evidence that the previous fiscal year Corrective Action Plan has been implemented and continues to address areas of violation."

If a CFC is identified in noncompliance under both onsite monitoring and data criteria, both indicators of noncompliance must be corrected. Correction of noncompliance occurs in the following circumstances.

  • On-site monitoring shows that a CFC with one or more files that indicate noncompliance during the FFY 05/SFY 06 site visit that has no files that indicate noncompliance during the FFY 06/SFY 07 site visit ; or
  • Data improves from below 95 percent (85 percent for Indicator 2) in FFY 05/SFY 06 to above 95 percent (85 percent for Indicator 2) in FFY 06/SFY 07.

Indicators

  • Indicator 1: Percent of infants and toddlers with IFSPs who receive the early intervention services on their IFSPs in a timely manner.
  • Indicator 2: Percent of infants and toddlers with IFSPs who primarily receive early intervention services in the home or community-based settings
  • Indicator 8a: IFSP with transition steps and services.
  • Indicator 8c: Transition conference, if child potentially eligible for Part B.

On Site Visit - Monitoring Tools

  • Item #28: Children's services that have been delayed are accurately reported on monthly manager's report.
  • Item #22: The IFSP contains a statement of natural environments in which early intervention services shall be provides: a justification of the extent, if any, to which the service(s) are provided in non-natural setting.
  • Item #32.03: Transition plan is updated in Cornerstone.
  • Item #33: There is evidence that at least 90 days prior to the child's third birthday a transition conference was held with at least the service coordinator, family and LEA.

There were no complaints or hearing requests that resulted in a finding of noncompliance for these indicators.

Monitoring Priority: Effective General Supervision Part C/ General Supervision

Indicator 9: General Supervision system (including monitoring, complaints, hearing, etc) identified and corrects noncompliance as soon as possible but in no case later than one year from identification.

(20 U.S.C. 1416(a)(3)(B) and 1442)

Measurement:

Percent of non compliance corrected within one year of identification:

  1. # of findings of non compliance
  2. # of corrections completed as soon as possible but in no case later than one year from identification.

Percent = [(b) divided by (a)] times 100.

For any noncompliance not corrected within one year of identification, describe what actions, including technical assistance and/or enforcement that the State has taken.

FFY: 2006 (2006-2007)
Measurable and Rigorous Target: 100 percent of noncompliance will be corrected within one year of identification.

Actual Target Data for FFY 06/SFY 07:

Indicator 1: Percent of infants and toddlers with IFSPs who receive the early intervention services on their IFSPs in a timely manner.

General Supervision System Components

  • Monitoring: Data and On-Site Visit (Item #28)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 6
    • b. # Findings from a. for which correction was verified no later than one year from identification: 6
  • Dispute Resolution (Complaints, due process hearings)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0

Indicator 2: Percent of infants and toddlers with IFSPs who primarily receive early intervention services in the home or community-based settingsGeneral Supervision System Components

  • Monitoring: Data and On-Site Visit (Item #22)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 19
    • b. # Findings from a. for which correction was verified no later than one year from identification: 13
  • Dispute Resolution (Complaints, due process hearings)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0

Indicator 7: Percent of eligible infants and toddlers with IFSPs for whom an evaluation and assessment and an initial IFSP meeting were conducted within Part C's 45-day timeline.

General Supervision System Components

  • Monitoring: Data
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0
  • Dispute Resolution (Complaints, hearings)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0

Indicator 8A: Percent of all children exiting Part C who received timely transition planning to support the child's transition to preschool and other appropriate community services by their third birthday including:
A. IFSPs with transition steps and services;

General Supervision System Components

  • Monitoring: Data and On-site Visit (#32.03)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 24
    • b. # Findings from a. for which correction was verified no later than one year from identification: 20
  • Dispute Resolution (Complaints, hearings)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0

Indicator 8B: Percent of all children exiting Part C who received timely transition planning to support the child's transition to preschool and other appropriate community services by their third birthday including:
B. Notification to LEA, if child potentially eligible for Part B

General Supervision System Components

  • Monitoring: Data
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 23
    • b. # Findings from a. for which correction was verified no later than one year from identification: 10
  • Dispute Resolution (Complaints, hearings)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0

Indicator 8C: Percent of all children exiting Part C who received timely transition planning to support the child's transition to preschool and other appropriate community services by their third birthday including:
C. Transition conference, if child potentially eligible for Part B.

General Supervision System Components

  • Monitoring: Data and On-Site Visit (#33)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 21
    • b. # Findings from a. for which correction was verified no later than one year from identification: 14
  • Dispute Resolution (Complaints, hearings)
    • # of Programs Monitored in FFY 2005: 25
    • a. # of Findings of non-compliance identified in FFY 2005 (7/1/05-6/30/06): 0
    • b. # Findings from a. for which correction was verified no later than one year from identification: 0

Percent of noncompliance corrected within one year of identification = (column b sum divided by column a sum) times 100

(63/93) x 100 = 67.8 percent

Discussion of Improvement Activities Completed and Explanation of Progress or Slippage that occurred for FFY 06/SFY 07:

In the FFY 2005 APR, Illinois did not report a specific percentage for Indicator 9, although OSEP calculated that percentage to be 52 percent. As stated above, individual instances of noncompliance had been reported rather than findings of noncompliance by CFC. The data, above, use the correct definition for a finding and indicate a percentage of noncompliance corrected within one year of identification of 67.8 percent.

In FFY 07/SFY 08, Illinois will establish a formal system of written notification, tracking and documentation of correction of noncompliance, and enforcement actions, when indicated.

Revisions, with Justification, to Proposed Targets / Improvement Activities / Timelines / Resources for FFY 06/SFY 07:

The following chart in the Illinois SPP would be updated, as follows.

Enhance the EI Monitoring Program's role in following-up areas of noncompliance.

  • Timelines 01/06 - Include documentation of corrections completed as part of annual CFC monitoring process. Completed
  • Timelines 01/06 - EI Monitoring staff will assume responsibility for receiving and monitoring corrective action plans resulting from written complaints. Completed

Enhance training efforts directed at CFC staff to decrease incidence of noncompliance.

  • Timelines 01/06 - Pilot new resources to provide on-line training opportunities. Completed
  • Timelines 06/06 - Develop and a series of training modules for service coordinators. The modules will be a combination of on-line learning opportunities followed by one-day, face-to-face interactive sessions to address the four Early Intervention core knowledge areas. The modules will be piloted beginning 7/06 and then modified to include policy, procedure, and MIS system training for new service coordinators. Completed

Increase compliance with 6-month review requirement

  • Timelines 01/06 - Add a new required date field to the Cornerstone system that documents date of 6-month review.
  • Timelines 07/06 - Add compliance with 6-month review requirement to monthly CFC performance reports.

Maintain correction of compliance through components of the General Supervision System, as defined above, including data systems, desk audits, performance contracting, on-site monitoring, and the compliant, mediation and hearing processes.

  • Timelines Ongoing

Implement the compliance determination criteria established by OSEP (i.e., meets requirements, needs assistance, needs intervention, needs substantial intervention) with CFC offices

  • Timelines 7/1/07 - The Bureau will use established criteria to make a compliance determination for each CFC office. These criteria will be measured using a CFC office's average performance over 4 quarters on the nine areas for which the program grants incentives and upon documentation of correction of noncompliance, as identified by the CFC monitoring tool.

Establish a formal system of written notification, tracking and documentation of correction of noncompliance, and enforcement actions, when indicated.

  • Timelines 7/1/08