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 2021 SPP/APR, the data for FFY 2020), 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: 2005
Baseline Data: 77.80%
| FFY |
2016 |
2017 |
2018 |
2019 |
2020 |
| Target |
100% |
100% |
100% |
100% |
100% |
| Data |
83.76% |
82.51% |
82.26% |
88.32% |
82.94% |
Targets
| FFY |
2021 |
2022 |
2023 |
2024 |
2025 |
| Target |
100% |
100% |
100% |
100% |
100% |
FFY 2021 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: FFY 2021 2022 2023 2024 2025 Target 100% 100% 100% 100% 100%
Number of toddlers with disabilities exiting Part C who were potentially eligible for Part B: 942
FFY 2020 Data: 82.94%
FFY 2021 Target: 100%
FFY 2021 Data: 84.39%
Status: Did not meet target
Slippage: No Slippage
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.
58
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.
35
Provide reasons for delay, if applicable.
Exceptional Family Circumstances- COVID (3) and Parent Delay (32). Other reasons for delayed transition planning conferences included eligibility determination less than 90 days before third birthday, school district delay, and 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 2021
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. Using October's data also aligns the data collection and reporting across all Compliance Indicators.
Provide additional information about this indicator (optional).
Correction of Findings of Noncompliance Identified in FFY 2020
| Findings of Noncompliance Identified |
Findings of Noncompliance Verified as Corrected Within One Year |
Findings of Noncompliance Subsequently Corrected |
Findings Not Yet Verified as Corrected |
| 2 |
0 |
0 |
2 |
FFY 2020 Findings of Noncompliance Not Yet Verified as Corrected
Actions taken if noncompliance not corrected
The single program that continues to demonstrate noncompliance may be selected as part of the pilot for our new process for addressing longstanding noncompliance. Even if not selected for this initiative, they will receive general information about the regulatory requirements for this indicator and may have to develop an improvement plan to address performance. Bureau staff continue to work closely with all programs to identify additional resources and technical assistance opportunities to support timely transition planning conferences. This program also receives performance data and feedback on a frequent basis. The Bureau is reviewing its correction of noncompliance procedures to incorporate engagement activities between the Bureau and program. In addition, improvement activities (e.g., root cause analysis, improvement plan, data collection, data analysis) to correct noncompliance and ensure correct implementation of requlatory requirements will be revised, as needed.
Correction of Findings of Noncompliance Identified Prior to FFY 2020
| Year Findings of Noncompliance Were Identified |
Findings of Noncompliance Not Yet Verified as Corrected as of FFY 2020 APR |
Findings of Noncompliance Verified as Corrected |
Findings Not Yet Verified as Corrected |
| FFY 2019 |
1 |
1 |
0 |
| FFY 2018 |
2 |
0 |
2 |
| FFY 2017 |
2 |
0 |
2 |
Findings of Noncompliance Verified as Corrected
Describe how the State verified that the source of noncompliance is correctly implementing the regulatory requirements.
The state reviewed subsequent data comprised of a sample of all children exiting Part C for one month (December) in the state's data system for the program demonstrating noncompliance. Based on this review, the State was able to verify that the program is 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 determine through a subsequent review of data that seven of the individual cases of noncompliance were corrected as the children had transition planning conferences, even though they were delayed. Unfortunately two individual cases of noncompliance were not able to be corrected prior to the children exiting the program. These cases, however, are resolved as the children are no longer under the jurisdiction of the program.
FFY 2018
Findings of Noncompliance Not Yet Verified as Corrected
Actions taken if noncompliance not corrected
The Bureau is continuing to access technical assistance to develop a process for addressing noncompliance. We anticipate beginning work with the CFCs to develop improvement plans that address performance. This process will include identifying barriers and receiving 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). We anticipate that Bureau and Training Program staff will work closely with these programs to identify additional resources and technical assistance opportunities to support timely transition planning conferences. The programs will continue to receive performance data and feedback on a frequent basis and will be supported in their understanding of this data. It is hoped that the additional support planned that includes examining root causes and attempting to resolve barriers to timely transition planning conferences will not be delayed again due to the pandemic.
FFY 2017
Findings of Noncompliance Not Yet Verified as Corrected
Actions taken if noncompliance not corrected
The Bureau is continuing to access technical assistance to develop a process for addressing noncompliance. We anticipate beginning work with the CFCs to develop improvement plans that address performance. This process will include identifying barriers and receiving 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). We anticipate that Bureau and Training Program staff will work closely with these programs to identify additional resources and technical assistance opportunities to support timely transition planning conferences. The programs will continue to receive performance data and feedback on a frequent basis and will be supported in their understanding of this data. It is hoped that the additional support planned that includes examining root causes and attempting to resolve 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 2020, the State must report on the status of correction of noncompliance identified in FFY 2020 for this indicator. In addition, the State must demonstrate, in the FFY 2021 SPP/APR, that the remaining one (1) uncorrected finding of noncompliance identified in FFY 2019, two (2) uncorrected findings of noncompliance identified in FFY 2018, two (2) uncorrected findings of noncompliance identified in FFY 2017, and one (1) uncorrected finding of noncompliance identified in FFY 2015 were corrected. When reporting on the correction of noncompliance, the State must report, in the FFY 2021 SPP/APR, that it has verified that each EIS program or provider with findings of noncompliance identified in FFY 2020 and each EIS program or provider with remaining noncompliance identified in FFY 2019, FFY 2018, FFY 2017, and FFY 2015: (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 2021 SPP/APR, the State must describe the specific actions that were taken to verify the correction. In addition, the State must clarify its reference to three programs with remaining noncompliance from FFY 2012.
If the State did not identify any findings of noncompliance in FFY 2020, although its FFY 2020 data reflect less than 100% compliance, provide an explanation of why the State did not identify any findings of noncompliance in FFY 2020.
Response to actions required in FFY 2020 SPP/APR
In FFY20, fifteen programs were out of compliance with this Indicator when APR data was reviewed. Of these fifteen, ten still had open findings from prior years. Through a subsequent review of a sample of one month's data (December) from the state's database for the remaining five programs, the State was able to verify that three of these programs were now demonstrating full compliance (pre-finding correction) with the regulatory requirements for timely transition conferences. The State was also able to verify that individual instances of noncompliance were resolved for these three programs because the children are no longer under the jurisdiction of the program. Unfortunately, two of the programs were not able to demonstrate correction and were issued findings.
For the remaining 2019 finding, the State was able to verify, through a subsequent review of a sample of one month of data (December) from the state database, that the program is now fully implementing the regulatory requirements for compliance with Indicator 8C. They had 100% compliance for all children in the sample. The State was also able to verify that seven of the individual instances of noncompliance were corrected because the children had transition planning conferences, albeit late, and the other two instances of noncompliance were resolved because the children were no longer under the jurisdiction of the program.
For the two remaining findings from FFY2018 and the two remaining findings from FFY2017, the State has not been able to verify compliance. These programs may be selected to be part of piloting the process that we are developing with our technical assistance partners to address performance.
Due to the limited number of rows in the table for uncorrected noncompliance, we are using this narrative box to report on older remaining noncompliance.
FFY2015
The State has been unable to verify that the program with the one remaining finding from FFY2015 is now successfully implementing the regulatory requirements for timely transition planning. The Bureau continues to share data and strategies to help this CFC move toward the goal of 100% compliance.This program may be selected to be part of piloting the process that we are developing with our technical assistance partners to address correction of noncompliance.
FFY2012
The three remaining findings from 2012 remain uncorrected. The Bureau continues to share data and strategies to help these CFCs to move toward the goal of 100% compliance. These three programs may also be involved in the more intensive process we are currently developing with our technical assistance providers.
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, 2021- June 30, 2022). 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.
OSEP's response to the State's FFY 2020 SPP/APR required the State to include in the FFY 2021 SPP/APR that it has verified that each EIS program or provider with noncompliance identified in FFY 2020 for this indicator: (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 2021 SPP/APR, the State must describe the specific actions that were taken to verify the correction.
The State wrote under "Response to actions required in FFY 2020 SPP/APR" that they had 15 CFCs with less than 100% compliance in FFY 2020. The State reported that they did not issue findings to ten CFCs that were less than 100% compliance for this indicator because the State already had an open finding with those CFCs. The State further reported the following: "Through a subsequent review of a sample of one month's data (December) from the state's database for the remaining five programs, the State was able to verify that three of these programs were now demonstrating full compliance (pre-finding correction) with the regulatory requirements for timely transition conferences. The State was also able to verify that individual instances of noncompliance were resolved for these three programs because the children are no longer under the jurisdiction of the program. Unfortunately, two of the programs were not able to demonstrate correction and were issued findings." However, this information is inconsistent with what the State reported under "Correction of Findings of Noncompliance Identified in FFY 2020." The State must clarify the number of findings it made in FFY 2020, as OSEP could not determine if the State ensured, consistent with OSEP Memo 09-02, that each EIS program or provider: (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; (2) has corrected each individual case of noncompliance, unless the child is no longer within the jurisdiction of the EIS program or provider.
8C - Required Actions
TIMELY TRANSITION
| CFC # |
Potentially Eligible for Part B (OCT. 2021) |
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 |
31 |
1 |
2 |
27 |
96.7% |
| **2 |
45 |
3 |
1 |
40 |
97.6% |
| 3 |
22 |
0 |
1 |
20 |
95.5% |
| **4 |
46 |
2 |
0 |
44 |
100.0% |
| **5 |
73 |
3 |
2 |
60 |
88.6% |
| *6 |
79 |
2 |
3 |
74 |
100.0% |
| *7 |
45 |
5 |
3 |
30 |
82.5% |
| *8 |
39 |
0 |
0 |
31 |
79.5% |
| *9 |
34 |
4 |
2 |
12 |
46.7% |
| *10 |
49 |
3 |
3 |
26 |
63.0% |
| *11 |
113 |
11 |
6 |
54 |
58.8% |
| *12 |
67 |
13 |
5 |
43 |
88.9% |
| 13 |
15 |
4 |
1 |
9 |
90.9% |
| 14 |
35 |
1 |
1 |
24 |
73.5% |
| **15 |
72 |
1 |
2 |
53 |
77.5% |
| 16 |
46 |
3 |
1 |
39 |
93.0% |
| 17 |
10 |
0 |
0 |
10 |
100.0% |
| 18 |
13 |
0 |
0 |
13 |
100.0% |
| 19 |
22 |
1 |
0 |
21 |
100.0% |
| 20 |
13 |
0 |
0 |
13 |
100.0% |
| 21 |
34 |
0 |
0 |
34 |
100.0% |
| 22 |
12 |
0 |
0 |
12 |
100.0% |
| 23 |
3 |
0 |
0 |
3 |
100.0% |
| 24 |
10 |
0 |
2 |
7 |
90.0% |
| **25 |
14 |
1 |
0 |
12 |
92.3% |
| Statewide |
942 |
58 |
35 |
711 |
84.4% |
| *Chicago - Cook County |
235 |
18 |
11 |
123 |
61.8% |
| *Suburban - Cook County |
191 |
20 |
11 |
147 |
92.4% |
| ** Collar Counties (2, 4, 5, 15, * 25) |
250 |
10 |
5 |
209 |
89.2% |
| Downstate (All Others) |
266 |
10 |
8 |
232 |
93.8% |
*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
