Indicator 8C: Early Childhood Transition

Instructions and Measurement

Monitoring Priority: Effective General Supervision Part C / Effective Transition

Compliance indicator: The percentage of toddlers with disabilities exiting Part C with timely transition planning for whom the Lead Agency has:

Developed an IFSP with transition steps and services at least 90 days, and at the discretion of all parties, not more than nine months, prior to the toddler's third birthday;
Notified (consistent with any opt-out policy adopted by the State) the State educational agency (SEA) and the local educational agency (LEA) where the toddler resides at least 90 days prior to the toddler's third birthday for toddlers potentially eligible for Part B preschool services; and
Conducted the transition conference held with the approval of the family at least 90 days, and at the discretion of all parties, not more than nine months, prior to the toddler's third birthday for toddlers potentially eligible for Part B preschool services.
(20 U.S.C. 1416(a)(3)(B) and 1442)

Data Source

Data to be taken from monitoring or State data system.

Measurement

Percent = [(# of toddlers with disabilities exiting Part C who have an IFSP with transition steps and services at least 90 days, and at the discretion of all parties not more than nine months, prior to their third birthday) divided by the (# of toddlers with disabilities exiting Part C)] times 100.
Percent = [(# of toddlers with disabilities exiting Part C where notification (consistent with any opt-out policy adopted by the State) to the SEA and LEA occurred at least 90 days prior to their third birthday for toddlers potentially eligible for Part B preschool services) divided by the (# of toddlers with disabilities exiting Part C who were potentially eligible for Part B)] times 100.
Percent = [(# of toddlers with disabilities exiting Part C where the transition conference occurred at least 90 days, and at the discretion of all parties not more than nine months, prior to the toddler's third birthday for toddlers potentially eligible for Part B) divided by the (# of toddlers with disabilities exiting Part C who were potentially eligible for Part B)] times 100.

Account for untimely transition planning under 8A, 8B, and 8C, including the reasons for delays.

Instructions

Indicators 8A, 8B, and 8C: Targets must be 100%.

Describe the results of the calculations and compare the results to the target. Describe the method used to collect these data. Provide the actual numbers used in the calculation.
Indicators 8A and 8C: If data are from the State's monitoring, describe the procedures used to collect these data. If data are from State monitoring, also describe the method used to select EIS programs for monitoring. If data are from a State database, describe the time period in which the data were collected (e.g., September through December, fourth quarter, selection from the full reporting period) and how the data accurately reflect data for infants and toddlers with IFSPs for the full reporting period.

Indicators 8A and 8C: States are not required to report in their calculation the number of children for whom the State has identified the cause for the delay as exceptional family circumstances, as defined in 34 CFR §303.310(b), documented in the child's record. If a State chooses to report in its calculation children for whom the State has identified the cause for the delay as exceptional family circumstances documented in the child's record, the numbers of these children are to be included in the numerator and denominator. Include in the discussion of the data, the numbers the State used to determine its calculation under this indicator and report separately the number of documented delays attributable to exceptional family circumstances.

Indicator 8B: Under 34 CFR §303.401(e), the State may adopt a written policy that requires the lead agency to provide notice to the parent of an eligible child with an IFSP of the impending notification to the SEA and LEA under IDEA section 637(a)(9)(A)(ii)(I) and 34 CFR §303.209(b)(1) and (2) and permits the parent within a specified time period to "opt-out" of the referral. Under the State's opt-out policy, the State is not required to include in the calculation under 8B (in either the numerator or denominator) the number of children for whom the parents have opted out. However, the State must include in the discussion of data, the number of parents who opted out. In addition, any written opt-out policy must be on file with the Department of Education as part of the State's Part C application under IDEA section 637(a)(9)(A)(ii)(I) and 34 CFR §§303.209(b) and 303.401(d).

Indicator 8C: The measurement is intended to capture those children for whom a transition conference must be held within the required timeline and, as such, only children between 2 years 3 months and age 3 should be included in the denominator.

Indicator 8C: Do not include in the calculation, but provide a separate number for those toddlers for whom the parent did not provide approval for the transition conference.

Indicators 8A, 8B, and 8C: Provide detailed information about the timely correction of noncompliance as noted in OSEP's response table for the previous SPP/APR. If the State did not ensure timely correction of the previous noncompliance, provide information on the extent to which noncompliance was subsequently corrected (more than one year after identification). In addition, provide information regarding the nature of any continuing noncompliance, methods to ensure correction, and any enforcement actions that were taken.

If the State reported less than 100% compliance for the previous reporting period (e.g., for the FFY 2020 SPP/APR, the data for FFY 2019), and the State did not identify any findings of noncompliance, provide an explanation of why the State did not identify any findings of noncompliance.

8C - Indicator Data

Historical Data

Baseline Year	Baseline Data
2005	77.80%

FFY	2015	2016	2017	2018	2019
Target	100%	100%	100%	100%	100%
Data	83.70%	83.76%	82.51%	82.26%	88.32%

Targets

FFY	2015	2016	2017	2018	2019
Target	100%	100%	100%	100%	100%
Data	83.70%	83.76%	82.51%	82.26%	88.32%

FFY 2020 SPP/APR Data

Data reflect only those toddlers for whom the Lead Agency has conducted the transition conference held with the approval of the family at least 90 days, and at the discretion of all parties, not more than nine months, prior to the toddler's third birthday for toddlers potentially eligible for Part B preschool services. (yes/no) YES

Number of toddlers with disabilities exiting Part C where the transition conference occurred at least 90 days, and at the discretion of all parties not more than nine months prior to the toddler's third birthday for toddlers potentially eligible for Part B	Number of toddlers with disabilities exiting Part C who were potentially eligible for Part B	FFY 2019 Data	FFY 2020 Target	FFY 2020 Data	Status	Slippage
716	1,089	88.32%	100%	82.94%	Did not meet target	Slippage

Provide reasons for slippage, if applicable

Data collection for timely Transition Planning Conferences was difficult during COVID, in general, due to CFC office and LEA office closures while transitioning to remote work and e-learning. Though every effort was made to keep families engaged, CFCs reported that many families stopped responding or did not follow through with scheduled Transition meetings. While some CFCs were able to attribute the cause of these delays to COVID using the available codes, not all were documented as such. The ability of CFCs, families and LEAs to perform the Transition Planning Conferences was just more difficult during COVID.

While many people have now become more familiar and appreciative of the opportunities that LVVs offer, it took time and practice to successfully utilize this technology. CFCs were offered support through the monthly CFC Manager calls as well as the additional CFC Supports call. This additional call was focused on supporting practice and continued compliance during the pandemic and problem-solving during the shift to virtual administration. CFCs continue to receive monthly data on the number of children exiting, who are potentially eligible for ECSE to support their continued efforts to ensure all families are offered timely Transition Planning Conferences.

Number of toddlers for whom the parent did not provide approval for the transition conference

This number will be subtracted from the "Number of toddlers with disabilities exiting Part C who were potentially eligible for Part B" field to calculate the denominator for this indicator.

Number of documented delays attributable to exceptional family circumstances

This number will be added to the "Number of toddlers with disabilities exiting Part C where the transition conference occurred at least 90 days, and at the discretion of all parties not more than nine months prior to the toddler's third birthday for toddlers potentially eligible for Part B" field to calculate the numerator for this indicator.

130

Provide reasons for delay, if applicable.

In addition to the 130 delays attributed to families (92-COVID RELATED DELAYS/38-FEC), other delays included untimely transition planning conferences caused by the LEA and/or CFC delay.

What is the source of the data provided for this indicator?

State database

Provide the time period in which the data were collected (e.g., September through December, fourth quarter, selection from the full reporting period).

October 2020

Describe how the data accurately reflect data for infants and toddlers with IFSPs for the full reporting period.

The month of October does reflect the average number of children potentially eligible who exit the program through the year. This also aligns the data collection and reporting across all Compliance Indicators as well.

Provide additional information about this indicator (optional).

Correction of Findings of Noncompliance Identified in FFY 2019

Findings of Noncompliance Identified	Findings of Noncompliance Verified as Corrected Within One Year	Findings of Noncompliance Subsequently Corrected	Findings Not Yet Verified as Corrected
5	4	0	1

FFY 2019 Findings of Noncompliance Verified as Corrected

Describe how the State verified that the source of noncompliance is correctly implementing the regulatory requirements.

Through a subsequent review of a sample of data from the state's database, the State was able to verify that four of these programs are now demonstrating full compliance with the regulatory requirements for timely transition conferences. They had timely transition conferences for 100% of the children in the sample.

Describe how the State verified that each individual case of noncompliance was corrected.

The State was also able to verify that individual instances of noncompliance were resolved because the individual cases of noncompliance were for children no longer under the jurisdiction of the program.

FFY 2019 Findings of Noncompliance Not Yet Verified as Corrected

Actions taken if noncompliance not corrected

The program that continues to demonstrate noncompliance will have an improvement plan developed to improve performance. This program will work through a process of identifying barriers and will receive additional technical assistance from Bureau staff, Early Intervention Training Program staff, and other partners/program managers (as needed) on potential strategies for meeting the regulatory requirements and program expectations for Indicator 8c (timely transition planning conferences). Bureau staff will work closely with this program to identify additional resources and technical assistance opportunities to support timely transition planning conferences. The program will receive performance data and feedback on a frequent basis. It is hoped that the additional support planned that includes examining root causes and attempts to resolve barriers to timely transition planning conferences will not be delayed again due to the pandemic.

Correction of Findings of Noncompliance Identified Prior to FFY 2019

Year Findings of Noncompliance Were Identified	Findings of Noncompliance Not Yet Verified as Corrected as of FFY 2019 APR	Findings of Noncompliance Verified as Corrected	Findings Not Yet Verified as Corrected
FFY 2018	2	0	2
FFY 2017	3	1	2
FFY 2015	1	0	1

FFY 2018 Findings of Noncompliance Not Yet Verified as Corrected

Actions taken if noncompliance not corrected

The programs that continue to demonstrate noncompliance will have improvement plans developed to improve performance. These programs will work through a process of identifying barriers and will receive additional technical assistance from Bureau staff, Early Intervention Training Program staff, and other partners/program managers (as needed) on potential strategies for meeting the regulatory requirements and program expectations for Indicator 8c (timely transition planning conferences). Bureau staff will work closely with these programs to identify additional resources and technical assistance opportunities to support timely transition planning conferences. These programs will receive performance data and feedback on a frequent basis. It is hoped that the additional support planned that includes examining root causes and attempts to resolve barriers to timely transition planning conferences will not be delayed again due to the pandemic.

FFY 2017 Findings of Noncompliance Verified as Corrected

Describe how the State verified that the source of noncompliance is correctly implementing the regulatory requirements.

For the three remaining 2017 Findings, the State was able to verify, through a subsequent review of a sample of data from the state database that one program,is now fully implementing the requirements for compliance with Indicator 8C and all Part B potentially eligible children had timely Transition Planning Conferences and/or timely declines.

Describe how the State verified that each individual case of noncompliance was corrected.

Additionally, the individual instances of noncompliance are resolved as the state has verified that all of the individual cases of noncompliance are for children who are no longer under the jurisdiction of the program.

FFY 2017 Findings of Noncompliance Not Yet Verified as Corrected

Actions taken if noncompliance not corrected

FFY 2015 Findings of Noncompliance Not Yet Verified as Corrected

Actions taken if noncompliance not corrected

Similar to the programs with remaining noncompliance from other years, the 3 programs still demonstrating noncompliance from FFY2012 will have improvement plans developed to improve performance. These three programs will work through a process of identifying barriers and receive technical assistance from Bureau staff, Early Intervention Training Program staff, and other partners/program managers (as needed) on potential strategies for meeting the regulatory requirements and program expectations for Indicator 8c (timely transition planning conferences). Bureau staff will work closely with these programs to identify additional resources and technical assistance opportunities to support timely transition planning conferences. The programs will receive performance data and feedback on a frequent basis. As with the others, it is hoped that the additional support around examining root causes and resolving barriers to timely transition planning conferences will not be delayed again due to the pandemic.

8C - Prior FFY Required Actions

Because the State reported less than 100% compliance for FFY 2019, the State must report on the status of correction of noncompliance identified in FFY 2019 for this indicator. In addition, the State must demonstrate, in the FFY 2020 SPP/APR, that the remaining two uncorrected findings of noncompliance identified in FFY 2018, three uncorrected findings of noncompliance identified in FFY 2017, one uncorrected finding of noncompliance identified in FFY 2015, and three uncorrected findings of noncompliance identified in FFY 2012 were corrected. When reporting on the correction of noncompliance, the State must report, in the FFY 2020 SPP/APR, that it has verified that each EIS program or provider with findings of noncompliance identified in FFY 2019 and each EIS program or provider with remaining noncompliance identified in FFY 2018, FFY 2017, FFY 2015, and FFY 2012: (1) is correctly implementing the specific regulatory requirements (i.e., achieved 100% compliance) based on a review of updated data such as data subsequently collected through on-site monitoring or a State data system; and (2) has corrected each individual case of noncompliance, unless the child is no longer within the jurisdiction of the EIS program or provider, consistent with OSEP Memo 09-02. In the FFY 2020 SPP/APR, the State must describe the specific actions that were taken to verify the correction.

If the State did not identify any findings of noncompliance in FFY 2019, although its FFY 2019 data reflect less than 100% compliance, provide an explanation of why the State did not identify any findings of noncompliance in FFY 2019.

Response to actions required in FFY 2019 SPP/APR

In FFY19, the state issued five findings for noncompliance with Indicator 8C. Through a subsequent review of a sample of data from the state's database, the State was able to verify that four of these programs were now demonstrating full compliance with the regulatory requirements for timely transition conferences. The State was also able to verify that individual instances of noncompliance were resolved because the children were no longer under the jurisdiction of the program. For the three remaining 2017 Findings, the State was able to verify, through a subsequent review of a sample of data from the state database that one program,is now fully implementing the requirements for compliance with Indicator 8C and all Part B potentially eligible children had timely Transition Planning Conferences and/or timely declines. Additionally, the individual instances of noncompliance are resolved as the state has verified that all of these children are no longer under the jurisdiction of the program. The two FFY2018 findings and the one FFY2015 finding remain as these programs have not successfully implemented the regulatory requirements for timely transition planning. The three remaining finding from 2012 remain uncorrected. The Bureau continues to share data and strategies to help these CFCs to move toward the goal of 100% compliance.

8C - OSEP Response

The State reported that it used data from a State database to report on this indicator. The State further reported that it did not use data for the full reporting period (July 1, 2020 - June 30, 2021). The State described how the time period in which the data were collected accurately reflects data for infants and toddlers with IFSPs for the full reporting period.

Although the State provided the reasons for delay, as required by the Measurement Table, the number of delays described under "parents did not provide approval for transition conference (69), "exceptional family circumstances "(130, and "reasons for delay" (130), is not consistent with the information provided in the data table .

8C - Required Actions

Indicator 8C: Early Childhood Transition

Compliance Indicator: The percentage of toddlers with disabilities exiting Part C with timely transition planning for whom the Lead Agency has:

Conducted the transition conference held with the approval of the family at least 90 days, and at the discretion of all parties, not more than nine months, prior to the toddler's third birthday for toddlers potentially eligible for Part B preschool services.

CFC #	Potentially Eligible for Part B (OCT. 2020)	Family did not provide consent to Transition	Exceptional Family Circumstances/COVID	Timely Transition Conferences (conducted at least 90 days before 3rd birthday)	% of Timely Transition Conference
1	35	3	6	22	87.50%
**2	45	0	3	41	97.78%
3	24	3	3	12	71.43%
**4	39	3	3	33	100.00%
**5	62	4	0	57	98.28%
*6	87	5	3	70	89.02%
*7	70	24	5	41	100.00%
*8	55	0	36	17	96.36%
*9	51	4	1	37	80.85%
*10	61	1	23	23	76.67%
*11	124	3	18	27	37.19%
*12	81	4	15	47	80.52%
13	15	5	0	10	100.00%
14	29	2	2	17	70.37%
**15	86	1	1	62	74.12%
16	37	2	2	30	91.43%
17	16	0	0	16	100.00%
18	28	1	2	25	100.00%
19	24	1	1	22	100.00%
20	25	0	0	25	100.00%
21	41	0	0	41	100.00%
22	15	0	0	15	100.00%
23	7	1	2	2	66.67%
24	9	0	1	8	100.00%
**25	23	2	3	16	90.48%
Statewide	1,089	69	130	716	82.94%
*Chicago - Cook County	291	8	78	104	64.31%
*Suburban - Cook County	238	33	23	158	88.29%
** Collar Counties (2, 4, 5, 15, * 25)	255	10	10	209	89.39%
Downstate (All Others)	305	18	19	245	91.99%

*Cook County Offices:

CFC 6 - North Suburban
CFC 7 - West Suburban
CFC 8 - Southwest Chicago
CFC 9 - Central Chicago
CFC 10 - Southeast Chicago
CFC 11 - North Chicago
CFC 12 - South Suburban