Indicator 9: General supervision system identifies and corrects noncompliance as soon as possible but in no case later than one year from identification

Illinois Department of Human Services
Division of Community Health & Prevention
Bureau of Early Intervention

Revised on 02/01/07
Second Revision on 02/01/08
Third Revision on 02/02/09
Fourth Revision on 02/01/10

General supervision system (including monitoring, complaints, hearings, etc.) identifies and corrects noncompliance as soon as possible but in no case later than one year from identification.


Part C State Performance Plan (SPP) for 2005-2010

Overview of the State Performance Plan Development:

See Indicator 1 for a description of this process.

(The following items are to be completed for each monitoring priority/indicator.)

Monitoring Priority: Effective General Supervision Part C / General Supervision

Indicator 9: General supervision system (including monitoring, complaints, hearings, etc.) identifies 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:

  1. Percent of noncompliance related to monitoring priority areas and indicators corrected within one year of identification:
    1. # of findings of noncompliance made related to priority areas.
    2. # of corrections completed as soon as possible but in no case later than one year from identification.
  2. 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.

  1. Percent of noncompliance related to areas not included in the above monitoring priority areas and indicators corrected within one year of identification:
    1. # of findings of noncompliance made related to such areas.
    2. # of corrections completed as soon as possible but in no case later than one year from identification.
  2. 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.

  1. Percent of noncompliance identified through other mechanisms (complaints, due process hearings, mediations, etc.) corrected within one year of identification:
    1. # of EIS programs in which noncompliance was identified through other mechanisms.
    2. # of findings of noncompliance made.
    3. # of corrections completed as soon as possible but in no case later than one year from identification.
  2. Percent = c divided by b 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.

Overview of Issue/Description of System or Process:

  1. Components of Illinois Early Intervention Program's General Supervision System.
    • Data Systems - With the exception of two measures (i.e., reasons for delays in intake past 45 days and delays in one or more services), which are manually reported by CFCs, the Illinois EI Program uses analysis of data from its management information systems to identify noncompliance with monitoring priority areas and indicators. Modifications to these systems will be made to support the measure of new indicators. Monthly, the Department monitors and provides to CFCs data on 29 performance measures.
    • Desk Audits - The statewide data manager analyzes statistics each month. The data manager forwards questions and issues to CFC managers, the Chief of the Bureau or Early Intervention, the Bureaus' CFC liaison staff (i.e., four individuals that provide technical assistance to CFCs), and to the EI Monitoring Program. These individuals work together to identify and resolve issues of noncompliance. Data from subsequent months are used to document the correction of noncompliance.
    • Performance Contracting - For several years, the Department has used a system of performance contracting. In SFY 05, nine measures were used to establish incentive payments as part of performance contracts, with payments made to CFCs that fall in the top 12 for each measure. Basic minimum performance standards are established on four measures that may result in a penalty adjustment if basic performance is not met.
    • On-site Monitoring - In September 2004, the Department selected a vendor for compliance monitoring services to support the EI services system. After staff hiring and training and development of monitoring tools and database, the first CFC was monitored in December 2004. By the end of May 2005, all 25 CFCs participated in a monitoring visit. Corrective action plans were requested, received, reviewed, and approved on all areas of noncompliance found. Verification that corrective action plans have been successful in correcting noncompliance will occur at the next annual visits to the CFCs, which begin in January 2006.
    • Complaints, Mediations, and Hearings - If a parent/guardian disagrees with the Illinois Early Intervention Services System on the 1) identification, 2) evaluation, 3) placement of his/her child, or 4) provision of appropriate early intervention services to his/her child or family, he/she has the right to a timely administrative resolution of his/her concerns. There are 3 options for raising issues. The parent/guardian may 1) request mediation; 2) request an impartial administrative proceeding; or 3) submit a complaint to the lead agency. During the resolution of an impartial proceeding or mediation the child will continue receiving appropriate early intervention services currently being provided or, if the family is applying for initial services, the child will receive the services which are not in dispute, unless there is agreement otherwise.
  2. General Supervision System Function
    • Bureau Oversight - The Bureau of Early Intervention, with support of a data manager from the Division or Community Health and Prevention's Performance Support Services unit, coordinates and directs the general supervision system and provides technical assistance. Data have been an integral part of this system for several years, based upon the data systems referenced above. The Chief and staff of the Bureau of Early Intervention oversee the work of the contract entities that are responsible for credentialing and training of providers, maintenance of MIS systems, central billing office operation, and monitoring functions. In addition, Bureau staff are assigned to specific CFCs to provide technical assistance and follow-up on issues identified though the general supervision system.
    • Data Reports - Performance data, described above, is shared within the general supervision system and with the public through several reports. Monthly reports are shared with the CFCs, with follow-up by the data manager or Bureau staff. Quarterly, a report is made to the Illinois General Assembly in which a number of performance measures and system updates are shared and explained. The General Assembly reports are made available to the general public on the Early Intervention web site.
    • CFC Managers' Quarterly Meetings - Every three months, the 25 CFC managers come together for a meeting with Bureau staff. At these meetings, data reports are reviewed and updates are provided by contract entities. New or revised policies and procedures are reviewed and learning opportunities are provided. Work groups are formed to address specific issues and disband when resolution steps are identified.
    • Illinois Interagency Council on Early Intervention (IICEI) Bi-monthly Meetings - The IICEI meets on a bimonthly basis to advise and assist the Bureau in the performance of its responsibilities. During these meetings, the Council and the general public in attendance are provided an update of general supervision activities. The Lead Agency Report, which is distributed at each meeting, provides a defined set of performance data that is reviewed and discussed. Work groups are formed to address specific issues and disband when recommendations are reviewed and approved by the Council.
  3. Correction of Noncompliance and Improved Performance.
    • Technical Assistance - Bureau staff provide ongoing technical assistance. Four staff members are each assigned specific CFCs and are available to answer questions, provide information, and follow-up on issues identified through general supervision functions. These and other Bureau staff are also assigned responsibilities associated with monitoring and oversight of contract entities that support supervision functions.
    • Required Corrective Action - The EI Monitoring Program requires the submission of a corrective action plan to address any area of noncompliance identified during monitoring visits. These plans are reviewed and approved. Full compliance with the plans will be determined at the next annual monitoring visit. Bureau staff also request, review, approve, and monitor corrective plans that are submitted in response to issues identified through functions which include data review and complaints, mediations and hearings.
    • Performance Contracting - The system of performance contracting described in #1, above, has been most successful in moving the Illinois Early Intervention System toward full compliance with federal requirements. Data elements for incentive funding or penalty adjustments are reviewed and revised on an annual basis to direct improvements in areas of need.
    • Data Reporting - In recent years, the Illinois Early Intervention Program has made excellent use of its data systems. Sharing data analyses with CFCs have resulted in positive system changes. Data sharing with the Council, the General Assembly, and the public through various reports have also influenced policy and performance.

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.

Baseline Data for FFY 2004 (2004-2005):

A. Percent of noncompliance related to monitoring priority areas and indicators corrected within one year of identification

Priority Area Non-compliance Identified & Corrected within a Year

Reporting CFCs CFCs w/
Delays
Child
Months
Corrected
w/in 1 Yr.
% Corr.
w/in 1 Yr.
  1. % of infants and toddlers with IFSPs who received their early intervention services on their IFSPs in a timely manner
Monthly
Self-Report
25 19 872 872 100.0%
  1. % of infants & toddlers with IFSPs for who an evaluation and assessment and an initial IFSP meeting were conducted within Part C's 45-day timeline
Data System 25 22 2,230 2,230 100.0%
  1. % 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
Data System
Meetings/ Potentially Eligible
25 25 1,702 - 0.0%
Total 4,804 3,102 64.6%

B. Percent of noncompliance related to areas not included in the above monitoring priority areas and indicators corrected within one year of identification

Service Coordination (case management) - 303.23
CFC Monitoring Tool Item/Legal Requirement
# CFCs With Findings # of Findings
CFC Process & Procedures #25
Every child/family eligible under part C has an assigned service coordinator responsible for serving as a single point of contact and coordinating across agency lines. (review case assignment in Cornerstone) 0 0

Explanation: No noncompliance found.

Evaluation/Assessment - 303.404 and 303.322
CFC Monitoring Tool Item/Legal Requirement
# CFCs With Findings # of Findings
CFC File Review #8
The Evaluation/Assessment
1. conducted by appropriately credentialed personnel. 6 8
2. was based on informed clinical opinion, 30% delay, or medical diagnosis. 4 6
3. included a review of pertinent record related to the child's current health status an medical history 3 4
4. included an evaluation of the child level of functioning in each of the following areas: 7 8
a. Cognitive development 5 6
b. Physical development including vision & hearing 4 5
c. Communication development 7 8
d. Social and emotional development ande. Adaptive development 6 7
5. identified the child's unique strengths and needs and the services appropriate to meet those needs. 3 4
6. identified the resources, priorities, and concerns of the family and the support services necessary to enhance the family's capacity to meet the developmental needs of the child. 3 4
7. was multidisciplinary. 6 8
CFC File Review #9
The assessment was administered in the native language of the parents and the assessment procedures were nondiscriminatory. 7 10

Explanation: A corrective action plan has been submitted and approved for all identified noncompliance. A determination of full compliance will be made following the next annual monitoring visit. A total of 755 records were reviewed statewide, with 14 to 62 files reviewed at each of the 25 CFCs, based upon a percentage of the caseload. See the Exceptions to Selected Items chart for CFC-specific data.

CFC monitoring tool elements relative to evaluation and assessment demonstrated full compliance in 13 out of the 25 CFCs. Minimal noncompliance was identified in 12 CFCs, with 9 CFCs having fewer than 6 findings and 3 having 11 or more findings (CFC #9 with 11, CFC #10 with 13, and CFC #16 with 26.) Since the number of findings is an unduplicated count, these numbers may represent just a few files with missing information per noncompliant CFC.

Procedures for IFSP Development, Review, and Evaluation - 303.342
CFC Monitoring Tool Item/Legal Requirement
# CFCs With Findings # of Findings
CFC File Review #28
A review of the IFSP has been conducted every 6 months or more frequently if conditions warranted or if the family requested such a review. 16 74
CFC File Review #29
The 6-month review documented:
1. the degree to which progress toward achieving the outcomes is being made; 13 63
2. whether modifications or revision of the outcomes or services is necessary; 13 64
3. documentation of IFSP meeting held with all providers prior to service change/increase. 14 66
CFC File Review #30
An annual meeting was conducted to evaluate the IFSP and revise as necessary. 3 4
CFC File Review #31
The results of any current evaluations and other information available from the assessment of the child and family were used to determine what services were needed. 7 8
CFC File Review #32
The annual IFSP meeting was conducted within 1 year of the initial or previous IFSP meeting. If not justification for extension is documented. 9 16
CFC File Review #33
IFSP meeting was conducted:
1. in settings and at times that were convenient to family (documentation may be found in CM04 Cornerstone. 2 2
2. in the native language of the family; and with input from the appropriate participants, including the parents, service coordinator, members of the assessment team, & current providers. 6 7
CFC File Review #35
The IFSP was in native language of parents and is understandable to parents.
13 42

Explanation: A corrective action plan has been submitted and approved for all identified noncompliance. A determination of full compliance will be made following the next annual monitoring visit. A total of 755 records were reviewed statewide, with 14 to 62 files reviewed at each of the 25 CFCs, based upon a percentage of the caseload. See the Exceptions to Selected Items chart for CFC-specific data

Procedures for IFSP Development, Review, and Evaluation indicators demonstrate full compliance in 5 CFCs with an additional 5 CFCs with 1 indicator of non-compliance. CFC File Review tool items # 28 and #29 indicate some (less than 10%) issues with 6-month review documentation, particularly in the CFCs with the largest caseloads. Noncompliance may represent the unwillingness of families to participate in the 6-month review process and CFC workload priorities in which initial and annual reviews are completed to avoid delays in services. Targeted technical assistance is given by Bureau of Early Intervention staff to direct CFCs to remain compliant the 6-month review requirement.

As indicated in CFC monitoring tool item #35, monitoring staff found that CFCs were not retaining a copy of a translated IFSP document, giving the original to the family. CFCs have been instructed to maintain a copy of the translated IFSP in the child's chart.

Content of an IFSP - 303.344
CFC Monitoring Tool Item/Legal Requirement
# CFCs With Findings # of Findings
CFC File Review #37
The IFSP includes a statement of the child's present level of physical development (including vision, hearing, and health status); cognitive, communication, social/emotional and adaptive development. 5 6
CFC File Review #38
The IFSP contains a statement of natural environments in which early interventions services shall be provided: a justification of the extent, if any, to which the service(s) are provided in non-natural settings. 12 87
CFC File Review #39
The IFSP includes a statement of major outcomes expected to be achieved for the child and family. 4 6
CFC File Review #40
The major outcomes include the strategies, activities, criteria, procedures and timelines used to determine the degree to which progress toward achieving the outcomes is being made. 4 8
CFC File Review #41
The IFSP identifies the specific early intervention services necessary to meet the unique needs of the child and family,including:
1. implementation dates and expected duration of the services 4 6
2. frequency, intensity, and method of delivering services 3 5
3. the location of the services 6 15
4. the funding source 15 76

Explanation: CFC File Review #37 The IFSP includes a statement of the child's present level of physical development (including vision, hearing, and health status); cognitive, communication, social/emotional and adaptive development.

Noncompliance indicated in 12 CFCs to monitoring tool item #38 reflects challenges that Illinois has faced with services in natural environments, particularly in areas of the state with a strong center-based provider pool, and documentation of appropriate justification. During the last year, the Illinois Interagency Council on Early Intervention helped sponsor a training session in two locations, bringing in national speakers to address natural learning environments. The Council also held a strategic planning session to discuss ongoing efforts to support compliance with natural environments in Illinois. See discussion of indicator #2 for additional information.

In a June 30,2005 memo from the Chief of the Bureau of Early Intervention, policies for the use of the fund source column in the IFSP document were clarified. (See item 41.4.) The clarification directed service coordinators to document the payer, or the steps being taken to secure a payer, for any supports/serves that are not authorized under Part C.

Exceptions to Selected Questions - CFCs - Revised 10/5/05

Question State
wide
CFC
1
CFC
2
CFC
3
CFC
4
CFC
5
CFC
6
CFC
7
CFC
8
CFC
9
CFC
10
CFC
11
CFC
12
CFC
13
CFC
14
CFC
15
CFC
16
CFC
17
CFC
18
CFC
19
CFC
20
CFC
21
CFC
22
CFC
23
CFC
24
CFC
25
Records 755 28 40 21 35 26 44 48 51 40 36 62 32 20 19 54 23 14 16 24 22 26 22 15 15 22
Service Coordination (case management) - 303.23
025.00. 0
Evaluation/Assessment - 303.404 and 303.322
008.01. 8 1 1 2 1 1 2
008.02. 6 1 1 2 2
008.03. 4 1 1 2
008.04.a 8 1 1 1 1 1 2 1
008.04.b 6 1 1 1 2 1
008.04.c 5 1 1 1 2
008.04.d 8 1 1 1 1 1 2 1
008.04.e 7 1 1 1 1 2 1
008.05. 4 1 1 2
008.06. 4 1 1 2
008.07. 8 1 1 1 1 3 1
009.00. 10 1 1 1 2 3 1 1
Procedures for IFSP Development, Review, and Evaluation - 303.342
028.00. 74 2 1 5 2 2 7 9 17 6 7 2 4 4 2 1 3
029.01. 63 3 1 7 3 6 6 16 3 6 1 3 5 3
029.02. 64 3 1 7 3 6 7 16 3 6 1 3 5 3
029.03. 66 4 1 7 1 2 7 9 16 3 5 1 3 4 3
030.00. 4 1 1 2
031.00. 8 1 1 1 1 1 2 1
032.00. 16 1 1 2 4 3 2 1 1 1
033.01. 2 1 1
033.02. 7 1 1 1 2 1 1
035.00. 42 5 1 1 1 2 2 6 6 3 11 1 2 1
Content of an IFSP - 303.344
037.00. 6 2 1 1 1 1
038.00. 87 8 1 2 6 13 27 11 5 4 2 1 7
039.00. 6 1 2 2 1
040.00. 8 2 2 2 2
041.01. 6 2 1 2 1
041.02. 5 1 2 1 1
041.03. 15 1 2 1 9 1 1
041.04. 76 4 1 6 9 16 10 6 9 6 1 1 1 2 3 1
Summary
Total 633 0 23 7 42 6 20 60 77 126 71 56 19 0 0 22 60 1 4 2 0 2 0 1 4 30

C. Percent of noncompliance identified through other mechanisms (complaints, due process hearings, mediations, etc.) corrected within one year of identification = 100 percent

No findings of noncompliance were identified through the 6 complaints received during the period July 1, 2003 through June 30, 2004.

Discussion of Baseline Data:

A. Percent of noncompliance related to monitoring priority areas and indicators corrected within one year of identification.

  1. During SFY 04/FFY 03, 19 of Illinois CFCs experienced at least one delay in finding an able and willing provider for at least one service for a child within 30 days. Of those, three experienced no problems in SFY 05/FFY 04. These delays involved a total of 872 child months, which represented 0.6% of the total for the year. The actual number of children involved was lower because delays lasting more than one month are counted multiple times. In most cases the delays were resolved within one or two months. In no case did a delay exceed one year.
  2. During SFY 04/FFY 03, 22 of the Illinois 25 CFCs failed to complete an initial IFSP within the required 45 days. The total number of cases that took more than 45 days was 2,320. As was documented under Indicator 7, all but 30 of those cases were overdue for family reasons, although Illinois does not make that distinction in its oversight of CFCs. All but a few of CFCs completed FFY 04/FFY 03 without a single IFSP taking more than 45 days for system reasons. There were only 261 instances where a case spent over 75 days in intake and a number of those proved to be false cases caused by data errors. In almost no instance did a case go past 45 days by more than two months and none remained unresolved for more than a year.
  3. The original submission of the SPP regarding transition meetings being held is being revised in conjunction with the FFY 05 APR submission. One reason for the change is the determination that the same data was being kept in two different parts of the Cornerstone data system. In most cases information on a child was only kept in one of the two places. The revision now reflects unduplicated data from both tables. During the FFY 04/SFY 05 baseline period, documentation of transition meetings did not exist for 1,702 children deemed potentially eligible. This included children from all 25 CFCs. EI had no capacity to follow-up on these cases in a systematic way. That capacity now does exist thanks to the data sharing agreement with ISBE and its efforts to require LEAs to report back when EI reports that eligibility was not determined.

B. Percent of noncompliance related to areas not included in the above monitoring priority areas and indicators corrected within one year of identification.

The data table provided under Baseline Data for FFY 2004 (2004-2005) (B) summarizes information collected in the first round of annual, on-site monitoring visits to the 25 CFCs conducting during year one of a contractual agreement with the EI Monitoring Program. Items are grouped under the Part C requirements 1) Service Coordination, 2) Evaluation/Assessment, and 3) Procedures for IFSP Development, Review, and Evaluation, and 4) Content of an IFSP. A corrective action plan has been submitted and approved for all areas of noncompliance. Full compliance will be determined at during the second round of on-site monitoring visits to the CFCs scheduled to begin in January 2006.

C. Percent of noncompliance identified through other mechanisms (complaints, due process hearings, mediations, etc.) corrected within one year of identification

No findings of noncompliance identified.

FFY: 2005 (2005-2006)
Measurable and Rigorous Target: 100 percent of system issues identified as noncompliant will be corrected within one year of identification.

FFY: 2006 (2006-2007)
Measurable and Rigorous Target: 100 percent of system issues identified as noncompliant will be corrected within one year of identification.

FFY: 2007 (2007-2008)
Measurable and Rigorous Target: 100 percent of system issues identified as noncompliant will be corrected within one year of identification.

FFY: 2008 (2008-2009)
Measurable and Rigorous Target: 100 percent of system issues identified as noncompliant will be corrected within one year of identification.

FFY: 2009 (2009-2010)
Measurable and Rigorous Target: 100 percent of system issues identified as noncompliant will be corrected within one year of identification.

FFY: 2010 (2010-2011)
Measurable and Rigorous Target: 100 percent of system issues identified as noncompliant will be corrected within one year of identification.

Improvement Activities/Timelines/Resources:

For measurement area A, please refer to the steps outlined under Indicators 1, 7 and 8 as appropriate.

Resources Timelines
1. Enhance the EI Monitoring Program's role in following-up areas of noncompliance.
  • Include documentation of corrections completed as part of annual CFC monitoring process
01/06
  • EI Monitoring staff will assume responsibility for receiving and monitoring corrective action plans resulting from written complaints.
01/06
2. Enhance training efforts directed at CFC staff to decrease incidence of noncompliance.
  • Pilot new resources to provide on-line training opportunities.
01/06
  • 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.
06/06
3. 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.
  • ALL
4. Implement the compliance determination criteria established by OSEP (i.e., meets requirements, needs assistance, needs intervention, needs substantial intervention) with CFC offices
  • 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.
7/1/07
5. Establish a formal system of written notification, tracking and documentation of correction of noncompliance, and enforcement actions, when indicated.
  • ALL
7/1/08
6. Data for a 12-month period ending on a selected date will be used for the identification of findings of noncompliance. CFC offices will be notified of findings in writing. Corrective action plans will be submitted, reviewed, and approved or revisions made, when necessary. Implementation of corrective action plans will be monitored to ensure that correction of noncompliance can be documented within one year.
  • ALL
Annually