Overview of the Annual Performance Report Development:

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:

Percent of noncompliance corrected within one year of identification:

  1. of findings of noncompliance.
  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: 2008
7/1/08-6/30/09

Measurable and Rigorous Target:

100 percent of noncompliance will be corrected within one year of identification

Actual Target Data for FFY08/SFY09:

Indicator 9: Percent of noncompliance corrected within one year of identification = (Indicator 9 Worksheet column (b) sum / column (a) sum) X 100
FFY08/SFY09 Result: 107/109 X 100 = 98.2%
FFY08/SFY09 Target = 100%

For findings identified in FFY07/SFY08, 98.2% of the findings were corrected within one year.

One hundred percent [13/13 X100 = 100%] of noncompliance reported in FFY06 APR as not corrected within one year from identification has been corrected. FFY07/SFY08 APR should have noted correction of noncompliance for the 13 findings identified in FFY2005. With the full implementation of the data sharing agreement between the EI Program and the Illinois State Board of Education (ISBE) and the subsequent data sharing reports, described below, no areas of noncompliance remain. No uncorrected findings of noncompliance were identified in the Illinois FFY07/SFY08 APR.

Findings of Noncompliance Identified Through Monitoring

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 a priority indicator and are listed below. Correction of noncompliance reflected by these elements is included in the Indicator C-9 Worksheet.

Verification of Correction (either timely or subsequent): For Indicator 8A findings identified through monitoring, which the State has reported correction, the following steps were taken to verify that the EIS program:

  1. is correctly implementing the specific regulatory requirements: If the on-site monitoring visit file review shows that a CFC office has one or more files that indicate noncompliance, a finding is identified. Following the monitoring visit, the CFC office submits a corrective action plan for approval and areas of noncompliance are reviewed at the CFC office's next monitoring visit.
  2. has corrected all instances of noncompliance consistent with OSEP Memorandum 09-02. In addition, electronic files were reviewed for each child has identified in the seven findings for Indicator 8(A) in the FFY2007/SFY2008 APR to ensure that correction taken place to ensure correction of each individual case of noncompliance. All the files indicated that transition steps and services had been accomplished (i.e., the child was either determined eligible (2), not eligible for Special Education (1), Special Education eligibility was not determined for family reasons (5), or the family declined referral to Special Education (1)).

Indicator

Indicator 8a: IFSP with transition steps and services.*

On Site Visit - Monitoring Tool Item

#32(a): There is evidence that six months prior to the child's third birthday communication began with the family about transition.

#32(b): With informed parental consent, service coordinator notified the child's local educational agency that the child will shortly reach the age of eligibility for preschool services under Part B.

#32(c): Early Intervention to Early Childhood Tracking Form was completed (PA34)

#32(d): Transition Efforts are documented in case notes (CMO4).

* The seven findings identified for 8(a) were noted in FFY07/SFY08 APR.

Dispute Resolution: Complaints, Hearings

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

Findings/Correction of Noncompliance Using Data System

In FFY07/SFY08, Illinois established a formal system of notification of findings and correction of noncompliance using its data system. Based upon data for April 2007, notification of findings was sent to each CFC office in February 2008. CFC offices submitted corrective action steps as part of a written plan to improve performance. All CFC offices were required to submit written plans, which were received by April 1, 2008. For CFC offices with findings, reports that demonstrate implementation of  corrective action plans and outcomes to those strategies were due by November 1, 2008. All the reports were received and reviewed and it was determined that all findings of noncompliance were corrected.

In December 2008, CFC offices were notified of findings based upon June 2008 data. After technical assistance calls with OSEP staff in January 2009, this process was revised to consider 12-month data ending June 2008. Notifications of findings were resent in March 2009. CFC offices submitted corrective action steps as part of a written plan to improve performance. All CFC offices were required to submit written plans, which were received by April 17, 2009. For CFC offices with findings, reports that demonstrate implementation of corrective action plans and outcomes to those strategies were due by August 3, 2009. All the reports were received and reviewed and it was determined that all findings of noncompliance were corrected.

Verification of Correction (either timely or subsequent): For Indicators 1, 7 and 8C findings identified using the data system, which the State has reported correction, the following steps were taken to verify that the EIS program:

  1. is correctly implementing the specific regulatory requirements: For CFC offices with findings, reports that demonstrate implementation of corrective action plans and outcomes to those strategies were submitted. All the reports were received and reviewed and it was determined that all findings of noncompliance were corrected.
  2. has corrected all instances of noncompliance consistent with OSEP Memorandum 09-02.
    • Indicator 1: CFC offices submit a monthly Service Delay Report. This report includes a status code and date the delay was resolved. April 2007 and April 2008 data were used to identify findings that were reported to CFC offices in FFY07/SFY08. Child-specific information was used to determine the status of all instances of noncompliance and their correction. Child specific data were accessed through the Service Delay Reporting system, the Cornerstone system, and file reviews. All instances of noncompliance were resolved for reasons that include the following: data entry error, service provided, family declined service, and child no longer in system,
    • Indicator 7: The data system continues to track a child for whom an evaluation/assessment and an initial IFSP meeting were not conducted within Part C's 45-day timeline. No cases from the findings identified in this report were left unresolved, as indicated in 75- and 90-day reports.
    • Indicator 8B: No findings of noncompliance have been identified for 8B.
    • Indicator 8C: CFC offices conducted case file reviews for all children identified in the months of April 2007 and April 2008 that did not have a transition meeting entered in the Cornerstone system. CFC offices either confirmed through case notes that a transition meeting had been held/transition appropriate completed or that the child was no longer in the jurisdiction of the Early Intervention program. Transition information from the IL State Board of Education was also reviewed to determine the child's transition outcome. All but two findings of noncompliance (representing 7 children from 2 CFC offices) remained unresolved in the sample.
Indicator/Indicator Clusters General Supervision
System Components
# of EIS Programs
Issued Findings in
FFY 2007 (7/1/07 to
6/30/08)
(a)# of Findings of
noncompliance
identified in FFY
2007 (7/1/07 to
6/30/08)
(b) # of Findings of
non-compliance from
(a) for which
correction was
verified no later than
one year from
identification
1. Percent of infants and toddlers with IFSPs who receive the early intervention services on their IFSPs in a timely manner. Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other 25 31 31
Dispute Resolution: Complaints, Hearings 25 0 0
2. Percent of infants and toddlers with IFSPs who primarily receive early intervention services in the home or communitybased settings Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other 25 9 9
Dispute Resolution: Complaints, Hearings 25 0 0
7 Percent of eligible infants and toddlers with IFSPs for whom an evaluation and assessment and an initial IFSP meeting were conducted within Part Cs 45-day timeline Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other 25 24 24
Dispute Resolution: Complaints, Hearings 25 0 0
8 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;
Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other 25 7 7
Dispute Resolution: Complaints, Hearings 25 0 0
8 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.
Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other 25 0 0
Dispute Resolution: Complaints, Hearings 25 0 0
8 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.
Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other 25 38 36
Dispute Resolution: Complaints, Hearings 25 0 0
Sum 109 107

Percent of noncompliance corrected within one year of identification = (column (b) sum divided by column (a) sum) times 100 (107/109) x 100 =98.2%

Discussion of Improvement Activities Completed and Explanation of Progress or Slippage that occurred for FFY08/SFY09:

Progress/Slippage for Indicator 9: FFY08/SFY2009 Indicator 9 data include findings of noncompliance from both the Cornerstone data and monitoring systems. Due to the timing of notification, FFY08/SFY09 data system findings of noncompliance represent data from both FFY2006/SFY07 and FFY07/SFY08. As a result the overall number of findings has increase from 21 in FFY07/SFY08 APR to 109 in FFY08/SFY09 APR. In FFY08/SFY09, 98.2% of findings were resolved compared to 100% in FFY07/SFY08. The two unresolved findings result from the requirement to look at child-specific data to indicate that resolution occurred for each child in a sample of cases.

Illinois has greatly improved its documentation of findings and correction of noncompliance. In FFY06/SFY07, it expanded the process to utilize its data system. A system of identification and correction of noncompliance was developed, but not fully implemented until FFY07/SFY08, due to delays in sending notification of findings to CFC offices. Two sets of findings were sent in FFY07/SFY08 based on April 2007 data and 12-month data ending June 2008. Illinois is now on track to provide timely notification and to monitor and document correction of noncompliance. On August 27, 2009, the Bureau sent a single letter to each CFC office that included the CFC office's determination (in accordance with 616(a)(1)(C)(i) and 300.600(a) of IDEA 2004) and the notification of findings of noncompliance, based upon 12-month data ending June 2009.

The program modified its procedures, as instructions for this reporting was more clearly defined by OSEP. Illinois staff have participated in TA conference calls and studied reference material, including the frequently asked questions document. In preparation for submitting the FFY07/SFY08 APR, two conference calls were held with Illinois' state contact and Larry Ringer to further discuss Illinois' compliance with the reporting requirements of this indicator. As a result, Illinois has taken steps to bring its process in line with OSEP guidance.

Improvement Activities:
  • The Early Intervention Monitoring Program continues to conduct annual on-site monitoring visits to all 25 CFC offices on an annual basis. The monitoring tools used for these visits can be found at http://www.eitam.org/forms.htm. CFC offices develop and implement corrective action plans, when indicated. At the subsequent monitoring visit, reviewers verify that corrective action plans have been implemented and continued to address areas of violation.
  • Illinois has a process in place to document the identification and correction of noncompliance as soon as possible but in no case later than one year from identification, which builds on Illinois' extensive use of its data system. CFC offices are notified of findings in writing. Corrective action plans are submitted, reviewed, and approved or revisions made, when necessary. Implementation of corrective action plans is monitored to ensure that correction of noncompliance can be documented within one year. Strategies have been implemented to consider data from an entire 12-month period.
  • Illinois has a process in place to document the identification and correction of noncompliance as soon as possible but in no case later than one year from identification, which builds on Illinois' extensive use of its data system and is based on an annual review of 12-month data.
  • The process of notifying CFC offices of findings has been combined with the determination process, allowing CFC offices to fully address areas of concern into a comprehensive correction action plan.
  • All new service coordinators complete on-line training modules. The Illinois Early Intervention Training Program continues to update and modify the modules as needed and upon the request and approval of the Department.
Revisions, with Justification,  to Proposed Targets / Improvement Activities / Timelines / Resources for FFY09/SFY10:

The Department will continue to use established systems to identify findings of noncompliance and correction within one year.

  • By March 31, 2010, a quarterly data reporting system will be established to provide child-specific information to CFC offices so that they can follow-up and report on correction of noncompliance for Indicators 1 and 8C.