Indicator #9 - Correction of Noncompliance within One Year

Correction of Noncompliance within One Year

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Part C State Annual Performance Report (APR) for FFY 07/SFY 08

Overview of the Annual Performance Report Development:

The Illinois APR documents performance data on State targets for each Child and Family Connections (CFC) office and documents CFC and state progress or slippage toward measurable and rigorous targets. The Illinois Early Intervention (EI) Program makes the Illinois APR and State Performance Plan (SPP) available on its web site and through links from the other EI web sites (the Illinois Early Intervention Training Program; Provider Connections, the Early Intervention credentialing office; and the Early Childhood Intervention Clearinghouse). The APR and SPP documents are also available to the public at each of the 25 CFC offices.

The APR is part an ongoing process of performance measurement and strategic planning for the Illinois Early Intervention Program. For a number of years, Illinois has been reporting performance data to key stakeholders including the Illinois Interagency Council on Early Intervention (IICEI), the Child and Family Connections (CFC) offices, and the general public through various reporting mechanisms. Work groups of the IICEI have been formed to address specific indicators (Service Delay Work Group and Transition Work Group) and overall operation issues (Finance Work Group). These work groups have helped analyze data and suggest improvement strategies.

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 next annual monitoring visit, reviewers verify that corrective action plans have been implemented and continued to address areas of violation.

Illinois now 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. Initially, Illinois established the process by selecting one month to identify noncompliance. Strategies are being implemented to consider an entire 12-month period.

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: 20077/1/07-6/30/08

Measurable and Rigorous Target: 100 percent of noncompliance will be corrected within one year of identification

Actual Target Data for FFY07/SFY08: 100 percent of noncompliance was corrected within one year of identification.[(21/21)*100]=100%

Actual Target Data for FFY07/SFY08:

100 percent of noncompliance reported in FFY06 APR as not corrected within one year from identification has been corrected. [(30/30)*100]

Correction of Noncompliance for Indicator 2 from FFY06 APR:

Five of the six uncorrected findings of noncompliance for Indicator 2 noted in the FFY06 Illinois APR were identified and documented through the program's monitoring process. Documentation of correction of noncompliance was made during the subsequent annual monitoring visit in which it was identified that there is evidence that the previous fiscal year corrective action plan had been implemented and continued to address areas of violation. The final uncorrected finding of noncompliance was identified based upon system data. Subsequently, the CFC has submitted a corrective action plan regarding this indicator. This plan was reviewed and approved and implementation strategies were successfully implemented, verifying that the noncompliance had been corrected.

Correction of Noncompliance for Indicator 8 from FFY06 APR:

Indicator 8(A) - All four findings of uncorrected noncompliance noted in the FFY06 Illinois APR were identified and documented through the program's monitoring process. Documentation of correction of noncompliance was made during the subsequent annual monitoring visit in which it was identified that there is evidence that the previous fiscal year corrective action plan has been implemented and continues to address areas of violation.

Indicator 8(B) - All 13 findings of noncompliance noted in the FFY06 Illinois APR were identified based upon system data. As noted under Referral to LEA - Indicator 8.B, strategies have been implemented statewide that ensures that all children who reach 30 months of age or who start EI services after that ages are made known to the Local Education Agency as a results of full implementation of a data sharing agreement with Part B/Illinois State Board of Education. As a result, all findings of noncompliance regarding this notification have been corrected.

Indicator 8(C) - Two of the seven findings of uncorrected findings of noncompliance for Indicator 8(c) noted in the FFY06 Illinois APR were identified and documented through the program's monitoring process. Documentation of correction of noncompliance was made during the subsequent annual monitoring visit in which it was identified that there is evidence that the previous fiscal year corrective action plan has been implemented and continues to address areas of violation. The remaining five findings of noncompliance were identified based upon system data. Subsequently, the CFC offices with findings submitted a corrective action plan regarding this indicator. These plans were reviewed and approved and implementation strategies were successfully implemented, verifying that the findings of noncompliance had been corrected

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 priority indicators and are listed below. Correction of noncompliance reflected by these elements is included in the Indicator C-9 Worksheet. 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 for full compliance at the CFC office's next monitoring visit. Monitoring staff specifically note if there is evidence that the previous fiscal year corrective action plan has been implemented and continues to address areas of violation.

Indicator 1: Percent of infants and toddlers with IFSPs who receive the early intervention services on their IFSPs in a timely manner.
On Site Visit - Monitoring Tool Item: #28: Children's services that have been delayed are accurately reported on monthly manager's report.

Indicator 2: Percent of infants and toddlers with IFSPs who primarily receive early intervention services in the home or community-based settings
On Site Visit - Monitoring Tool 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.

Indicator 8a: IFSP with transition steps and services.
On Site Visit - Monitoring Tool Item: #32.03: Transition plan is updated in Cornerstone.

Indicator 8c: Transition conference, if child potentially eligible for Part B.
On Site Visit - Monitoring Tool 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.

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 has 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 CFCs 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. Since the notification of these findings occurred in FFY08/SFY09, they will be reported in FFY08 APR. This process has been revised to meet OSEP requirements. A second cycle, using data for the 12-month period ending April 2008, has been initiated with letters sent to CFC offices in December 2008.

Indicator C-9 Worksheet

Indicator/Indicator Clusters General Supervision System Components	# of EIS Programs Issued Findings in FFY 2006 (7/1/06 to 6/30/07)	(a) # of Findings of noncompliance identified in FFY 2006 (7/1/06 to 6/30/07)	(b) # of findings of noncompliance 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	1	1	1
Dispute Resolution: Complaints, Hearings	0	0	0
2. Percent of infants and toddlers with IFSPs who primarily receive early intervention services in the home or community-based settings
Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other	9	9	9
Dispute Resolution: Complaints, Hearings	0	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 C's 45-day timeline.
Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other	0	0	0
Dispute Resolution: Complaints, Hearings	0	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: D. IFSPs with transition steps and services;
Monitoring Activities: Self-Assessment/ Local APR, Data Review, Desk Audit, On-Site Visits, or Other	4	4	4
Dispute Resolution: Complaints, Hearings	0	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: E. 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	0	0	0
Dispute Resolution: Complaints, Hearings	0	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	7	7	7
Dispute Resolution: Complaints, Hearings	0	0	0
Sum the numbers down Column a and Column b		21	21

Percent of noncompliance corrected within one year of identification = (column (b) sum divided by column (a) sum) times 100 = [(21/21)*100]=100%

Discussion of Improvement Activities Completed and Explanation of Progress or Slippage that occurred for FFY07/SFY08:

Illinois has greatly improved its documentation of findings and correction of noncompliance. Illinois has been able to improve its performance from 67.8 percent correction of noncompliance within one year, reported in the FFY06/SFY07 APR, to 100 percent in FFY07/SFY08. In FFY07/SFY08, it also expanded the process to better utilize its data system. A system of identification and correction of noncompliance was developed, but not fully implemented until FFY08/SFY09, due to delays in sending notification of findings to CFC offices. Illinois is now on track to provide timely notification and to monitor and document correction of noncompliance.

The program has continued to modify its procedures, as instructions for this reporting have been more clearly defined for states. Illinois staff have participated in the APR TA conference call on Indicator 9 and studied reference material, including the frequently asked questions document. Two follow-up conference calls were held with Illinois' state contact, Jennifer Simpson, 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.

Revisions, with Justification, to Proposed Targets / Improvement Activities / Timelines / Resources for FFY07/SFY08:

New Improvement Activity:

• Annually, 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.