DMS 2.0 FRAMEWORK W/ EVIDENCE AND INTENDED OUTCOMES - gov.ed.sites

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DMS 2.0 FRAMEWORK W/EVIDENCE AND INTENDED OUTCOMES
This Framework outlines a State system that is:
      •     100% focused on improved outcomes and results for infants, toddlers, children and youth with disabilities and their families,
      •     Comprised of defined components,
      •     Integrated across components, and
      •     Nimble enough to address emerging issues.

The Framework outlines how all programs will be monitored on their general supervision systems during Phase 1 of DMS.
General supervision encompasses the States’ responsibility to ensure that it and its subgrantees and contractors meet the requirements of IDEA which includes:
      1. Improving educational results and functional outcomes for all infants, toddlers, children, and youth with disabilities; and
      2. Ensuring that public agencies meet the program requirements under Part B and C of IDEA, with a particular emphasis on those requirements that are most closely related to improving
         educational results for infants, toddlers, children, and youth with disabilities.
     •      For each of the 8 components of a general supervisions system, OSEP provides:
      •     A definition;
      •     A series of “if/then” statements which outlines the elements OSEP thinks is necessary to achieve the intended results; and
      •     A list of examples of the types of evidence that we have found helpful in understanding a State’s system within the specific component. This list is neither exhaustive nor does it mean that a
            State is out of compliance if it does not have a specific item.

Phases
Phase 1: October–November............................. 1
Phase 1: January–February ................................ 4
Phase 1: May–June ............................................ 7
Phase 1: July–August ........................................ 10
Phase 2 ............................................................. 12
DMS 2.0 F RAMEWORK W /E VIDENCE AND I NTENDED O UTCOMES

PHASE 1: OCTOBER–NOVEMBER
    IF   A   S TATE H AS                     T HEN                             T HEN                              T HEN                             T HEN                  I NTENDED O UTCOME
An effective fiscal              The State has a thorough          The State will have                The State will be able to          The State and LEA/EIS             An effective fiscal
management system                understanding of the IDEA         internal controls in place         document oversight of the          programs will use IDEA            management system will
                                 and cross-cutting Federal         to ensure compliance with          use of IDEA funds.                 funds for their intended          contribute to improved
                                 fiscal requirements.              IDEA and cross-cutting                                                purposes in a manner that         outcomes for infants,
                                                                   Federal fiscal                                                        is reasonable, necessary,         toddlers, children and
                                                                   requirements.                                                         and allocable to the IDEA.        youth with disabilities and
                                                                                                                                                                           their families.

         D EFINITION              E XAMPLES    OF   E VIDENCE       E XAMPLES    OF   E VIDENCE        E XAMPLES    OF   E VIDENCE        E XAMPLES    OF   E VIDENCE
A system designed to ensure      • Policies and procedures         • Organizational charts            • Example of reports from          • Documentation supporting
that IDEA funds are              • (manuals, user guides for       • Documentation related to           data system for accuracy of        State’s implementation of
distributed and expended in        applicable requirements           the SEA/LA’s allocation of         billing, payments etc.             its procedures for the timely
accordance with Federal            and key Part B and Part C         funding, including IDEA Part     • Fiscal monitoring reports          disbursement/
fiscal requirements. A State's     fiscal processes), as well as     B/C funds, to its LEA/EIS                                             reimbursement of IDEA
                                                                                                      • Part B interactive
fiscal management system           description the State’s           programs and providers                                                funds
                                                                                                        spreadsheets
will include documentation of      general supervision system.                                                                           • Documentation related to
                                                                   • Risk assessment policies         • Part C budgets
required budgetary                                                                                                                         compliance with cost
                                 • Information on State              and procedures,
information, policies and                                                                             • PART C: System of payments         principles of subpart E of
                                   structure (e.g., budget           calculations of risk, rubrics
procedures reflecting IDEA,                                                                             implementation – payor             the Uniform Guidance
                                   office and program office;        related to the assignment of
EDGAR, and Uniform                                                                                      source, ability to pay, access
                                   interagency agreements;           risk categories, including                                          • Fiscal monitoring reports
Guidance requirements and                                                                               to insurance, interim
                                   examples of contracts;            LEA/EIS programs that do                                              that include findings,
evidence of implementation                                                                              payments etc.
                                   organizational charts)            not meet audit thresholds,                                            documentation supporting
of those procedures all of                                                                            • Notifications to LEA/EIS
                                 • Description of Educational        related to monitoring                                                 corrective action, and
which assist States in using                                                                            programs of upcoming fiscal
                                   Service Agencies/regional         processes, as appropriate.                                            closeout reporting
Federal funds for improving                                                                             monitoring activities
performance and outcomes           Part C structures               • Budget and expenditure                                              • Documentation
for infants, toddlers, and         roles/responsibilities for        data for a particular year for   • Description of procedures          demonstrating the
children with disabilities.        fiscal requirements               the purpose of calculating         for resolving IDEA-related         implementation of the
                                                                     MOE/MFS.                           single audit and monitoring        Method if applicable (e.g.,

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IF   A   S TATE H AS               T HEN                             T HEN                              T HEN                            T HEN                 I NTENDED O UTCOME
                       • Data systems used by the        • PART C: Example(s) of              findings for LEA/EIS              documentation/State forms
                         State, with specific              agreement(s) with EIS              programs                          related to the use of funds
                         reference to data sources         programs/providers/              • List and documentation of         to support staff/activities
                         relevant to fiscal processes      vendors/agencies providing         IDEA-related single audit         described in the State’s
                         and oversight                     Part C EIS                         findings/corrective actions       Method and SOP
                                                                                              and fiscal monitoring             procedures)
                       • Description of fiscal TA        • List of SEA’s single audit
                         accessed by the State             findings for the past 3 years,     findings/corrective actions     • Information memos,
                                                           with status report on any          for LEA/EIS programs              guidance documents, and
                       • Yearly timeline for
                                                           unresolved findings              • Fiscal monitoring protocols       training/professional
                         reviewing data sources,
                                                                                                                                development agendas to
                         calculating, and issuing IDEA   • Oversight Agency Reports         • PART B: List of charter
                                                                                                                                LEA/EIS programs on topics
                         allocations, release of           (ex: Legislative review, OIG,      school LEAs that opened/
                                                                                                                                related to IDEA, EDGAR, and
                         funds, and reallocation           policy groups, State task        • closed/significantly              Uniform Guidance fiscal
                         considerations                    force) of SEA/LA internal          expanded/changed status           requirements, annual
                                                           processes
                                                                                            • Policies and procedures           applications/plans, budgets,
                                                                                              reflecting the SEA/LA’s           fiscal monitoring and
                                                                                              standards for correcting          enforcement, reallocation
                                                                                              fiscal noncompliance              of funds and other topics as
                                                                                            • PART C: The State’s Method        identified
                                                                                              to ensure the provision of,
                                                                                              and financial responsibility,
                                                                                              Part C Services (Draft or
                                                                                              Final), if applicable
                                                                                            • Policies and procedures
                                                                                              related to parental
                                                                                              notification/consent
                                                                                              provisions for
                                                                                              (Public/Private) Insurance
                                                                                            • Sample State consent forms
                                                                                              related to access to
                                                                                              (Public/Private) Insurance

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IF   A   S TATE H AS   T HEN                 T HEN                    T HEN                T HEN   I NTENDED O UTCOME
                                                           • Fiscal data system
                                                             procedures/screenshots,
                                                             demonstrating the system’s
                                                             capacity for oversight of
                                                             funds for the Part B/Part C
                                                             programs
                                                           • PART B: Sample calculations
                                                             and budget documents for
                                                             determining the maximum
                                                             amount of funds available
                                                             for voluntary CEIS

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PHASE 1: JANUARY–FEBRUARY
       IF   A   S TATE H AS                        T HEN                                   T HEN                                  T HEN                     I NTENDED O UTCOME
An effective Integrated             The State continuously                   The State identifies          The State requires the LEA/EIS                An effective integrated
monitoring system                   examines and analyzes data               noncompliance with procedural programs to correct identified                monitoring system will
                                    across multiple sources to               and programmatic requirements noncompliance.                                contribute to improved
                                    evaluate its performance, and            and makes recommendations                                                   outcomes for infants, toddlers,
                                    that of its LEA/EIS programs for         for performance improvements.                                               children and youth with
                                    improved results and                                                                                                 disabilities and their families.
                                    compliance.

            D EFINITION                  E XAMPLES    OF   E VIDENCE             E XAMPLES    OF   E VIDENCE            E XAMPLES    OF   E VIDENCE
A multifaceted process or system    • Monitoring policies/procedures         • Monitoring reports with findings     • Root cause analysis to identify
which is designed to examine and       o Self-assessments (State-level       • Description of processes in manual     what is behind the performance
evaluate States with a particular         or LEA/EIS programs)                                                        data
                                                                             • Tools to conduct monitoring
emphasis on educational results,                                                                                    • Evidence of TA provided and
                                    •   Timeline for monitoring              • Training of LEA/EIS programs
functional outcomes and                                                                                               outcomes as a result of the TA
compliance with IDEA procedural     • Criteria for identifying LEA/EIS       • Examples of improvement plans          provided
and programmatic requirements.        programs for monitoring
                                                                             • Description of Stakeholder           • Documentation of what corrective
                                    • Description of how the State             engagement and activities related      actions were required and/or
                                      analyzes data for CWD and all            to compliance and performance          improvement plans
                                      students                                 improvement
                                    • Additional data sources they are
                                      using (IDEA/ESEA)
                                    • Documentation of Stakeholder
                                      engagement activities and work
                                    • Evidence of State cross analysis of
                                      different factors and data points
                                      that contribute to identified issues

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       IF   A   S TATE H AS                          T HEN                                  T HEN                                T HEN                       I NTENDED O UTCOME
A system designed to                  The State uses a system of             LEA/EIS programs develop and         The State verifies that LEA/EIS         A system designed to sustain
Sustain Compliance and                incentives and sanctions to            implement improvement                programs have implemented               compliance and improvement
                                      ensure continued improvement           activities and corrective actions    improvement activities and              will contribute to improved
Improvement
                                      and IDEA compliance.                   to address areas in need of          corrected noncompliance.                outcomes for infants, toddlers,
                                                                             improvement and                                                              children and youth with
                                                                             noncompliance.                                                               disabilities and their families.

            D EFINITION :                  E XAMPLES    OF   E VIDENCE            E XAMPLES    OF   E VIDENCE          E XAMPLES    OF   E VIDENCE
A system for recognizing, and         • Evidence of a general supervision    • LEA and EIS procedural manuals     • Verification of the correction of
improving compliance and                system which includes a defined        including at a minimum; methods      systemic and individual
performance including use of            system of incentives and sanctions     for determining non-compliance,      noncompliance
improvement activities, incentives,     for compliance with IDEA               steps-to-correct, timelines,       • Records of enforcement actions
and sanctions.                        • Documentation of enforcement           sanctions and incentives             taken against LEA/EIS programs
                                        policies that explain the            • Evidence of the implementation     • Records of technical assistance
                                        consequences of violating              and evaluation of improvement        provided to LEA/EIS programs
                                        regulations, policies, and             activities, and how stakeholders     related to noncompliance and
                                        procedures.                            are involved                         program improvement
                                      • Policies related to Incentives for   • Verification of correction of      • Tracking noncompliance (statistics,
                                        improved performance and               systemic and individual              frequency, areas of need)
                                        compliance                             noncompliance
                                                                                                                  • Samples of LEA/EIS program
                                      • Written State monitoring             • Evidence State collects and          documents or compliance reports
                                        procedures                             reviews LEA/EIS program tracking
                                                                                                                  • Close out reports, evidence of
                                      • Sample of corrective action            mechanisms for noncompliance
                                                                                                                    correction
                                        (reports and timelines)              • Audit reports
                                                                                                                  • Revised policies and procedures, if
                                      • Valid and reliable data on State     • Sample of Corrective Actions         applicable
                                        monitoring of LEA/EIS programs         (reports and timelines)
                                                                                                                  • Evidence of the Implementation of
                                                                                                                    the revised policies and
                                                                                                                    procedures

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IF   A   S TATE H AS   T HEN                    T HEN                        T HEN                 I NTENDED O UTCOME
                                                               • Evidence of change in practices
                                                                 from attendees of trainings
                                                               • Updated data showing
                                                                 improvement

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PHASE 1: MAY–JUNE
       IF   A   S TATE H AS                      T HEN                                   T HEN                                   T HEN                     I NTENDED O UTCOME
An effective dispute               Parents and other stakeholders         The State timely resolves               LEA/EIS programs provide FAPE         An effective dispute resolution
resolution system                  will be informed of their rights       disputes about IDEA procedures          in the LRE/EIS to eligible infants,   system will contribute to
                                   under the law.                         and the provision of FAPE in the        toddlers, children and youth          improved outcomes for infants,
                                                                          LRE or EIS.                             with disabilities.                    toddlers, children and youth with
                                                                                                                                                        disabilities and their families.

            D EFINITION :              E XAMPLES    OF   E VIDENCE            E XAMPLES    OF   E VIDENCE             E XAMPLES    OF   E VIDENCE
A system designed as part of a     • Procedural safeguards notice         • Section 618 data                      • Timely Correction of
State’s general supervisory          (dispute resolution components)      • Evidence of hearing officer’s           noncompliance (individual and
responsibility to ensure           • Evidence of receipt of Procedural      decisions, state complaint actions,     systemic)
implementation of IDEA’s dispute     Safeguards (signature page, file       mediation agreements                  • Evidence of implementation of
resolution procedures consistent     review during monitoring)                                                      remedies ordered by hearing
                                                                          • Evidence of training provided to
with IDEA requirements.                                                                                             officer or State (compensatory
                                   • Model forms for State complaints       hearing officers and mediators
                                     and due process                                                                services, monetary
                                                                          • Description of how the Due
                                                                                                                    reimbursement, IEP/IFSP Team
                                   • Review of communication to MSIP        Process System is established in
                                                                                                                    meetings)
                                     Customer service                       the State
                                                                                                                  • Evidence of technical assistance
                                   • News articles or pending lawsuits    • Part C programs – policies and
                                                                            procedures for Part C due process     • Review any Memorandums of
                                   • State websites for access to forms
                                                                            hearing procedures or adoption of       agreements or contracts with the
                                     and safeguards
                                                                            Part B hearing procedures               entity responsible for conducting
                                   • LEA/EIS program examples of                                                    the hearings
                                     model forms                          • Documentation that appeal rights
                                                                            are included in hearing decisions     • Any supplemental guides or Q & A
                                   • Policies and procedures regarding                                              Documents the States have
                                     timing of safeguards, use of model   • Tracking documents for Dispute
                                                                                                                    developed to provide guidance to
                                     forms, and information required in     resolution systems (State
                                                                                                                    their Stakeholders related to
                                     State complaints and hearing           Complaint, Due Process and
                                                                                                                    Dispute Resolution activities
                                     notices                                mediation)
                                                                          • Policies around timelines

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       IF   A   S TATE H AS                            T HEN                                   T HEN                                 T HEN                    I NTENDED O UTCOME
                                        • Information on requesting
                                          mediation (info in notice, website,
                                          etc.)
                                        • Evidence of availability of hearing
                                          decisions to SAP/ICC and/or public

An effective system for                 The States uses all available           The State identifies TA/PD             The State prioritizes the delivery An effective system for targeted
targeted technical                      data/information to prioritize          offerings that are aligned to          of TA/PD in those areas in need technical assistance and
                                        which areas need improvement.           those areas in need of                 of improvement.                    professional development will
assistance and professional
                                                                                improvement.                                                              contribute to improved
development                                                                                                                                               outcomes for infants, toddlers,
                                                                                                                                                          children and youth with
                                                                                                                                                          disabilities and their families.

            D EFINITION :                    E XAMPLES    OF   E VIDENCE             E XAMPLES    OF   E VIDENCE           E XAMPLES    OF   E VIDENCE
A system of technical assistance and    • Tools/ mechanisms to collect data     • Evidence of dissemination and        • State level or LEA/EIS program
professional development that uses        that would inform targeted TA or        communication of available TA/PD       best practices for implementing
data-informed root cause analysis         identified area(s) for improvement    • Description of State’s analysis of     IDEA.
areas to address State priorities and   • Evidence of how the State is            data to inform TA/PD activities      • Description of the delivery method
areas in need of improvement.             triangulating or analyzing their                                               of the TA/PD activities the State
                                          data.                                                                          are developing and implementing
                                        • Monitoring reports                                                           • Review the State’s description of
                                        • 616/618 Data Reports                                                           TA/PD in the SPP/APR introduction
                                        • Description of State TA/PD                                                   • Evidence of alignment with other
                                          activities within the State                                                    programs/initiatives (e.g. SPDG)
                                                                                                                         (e.g., meeting notes, agendas,
                                        • Description of how the State
                                                                                                                         etc.)
                                          identifies the types of TA/PD
                                          activities they provide                                                      • Evidence of stakeholder
                                                                                                                         involvement in identifying needs
                                                                                                                         on TA/PD activities

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IF   A   S TATE H AS                T HEN                    T HEN                    T HEN   I NTENDED O UTCOME
                       • Outline of stakeholder’s
                         involvement in development of
                         TA/PD activities

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PHASE 1: JULY–AUGUST
    IF   A   S TATE H AS                          T HEN                                  T HEN                                     T HEN                           I NTENDED O UTCOME
An effective system to            The State collects and reports          The State analyzes data for             The State uses data to support               An effective system to collect and
collect and report                valid and reliable data that are        strategic planning and equitable        implementation of strategies that            report timely and accurate data
                                  timely submitted to the Secretary       allocation of resources.                are most closely aligned to                  will contribute to improved
timely and accurate
                                  and the public.                                                                 improved outcomes.                           outcomes for infants, toddlers,
data                                                                                                                                                           children and youth with
                                                                                                                                                               disabilities and their families.

         D EFINITION :                 E XAMPLES    OF   E VIDENCE             E XAMPLES    OF   E VIDENCE              E XAMPLES     OF   E VIDENCE
A data system designed to         • Description of data collection        • Schedule/Timeline for examining       • Timeline of data pulls for
ensure that the data                system(s)                               LEA/EIS program data                    implementation of strategies
collected and reported are        • Reports/Screen Shots of data          • Guidelines for using data to inform   • Documentation of analysis of data
valid and reliable and that         systems                                 monitoring/TA                           trends
information is reported to
                                  • Walk through demonstration of data • Evidence that the State uses its data    • Evidence that the State supports a
the Department and the
                                    system                               systems to plan for new initiatives        data driven culture at the LEA/EIS
public in a timely manner.
                                  • Documentation of Data governance      • Evidence that the State compiles        program level to ensure LEA/EIS
The data system will inform
                                    requirements                            and integrates data across systems      programs carry out evidence-based
and focus a State’s
                                                                            and uses the data to inform and         practices with fidelity (e.g. trainings,
improvement activities as         • Manuals or evidence reflecting the
                                                                            focus its improvement activities        user manuals, guidance etc.)
well as verifying that that the     Edit Checks/Business Rules within
data collected and reported         their data system                     • Models for root cause analysis        • Identification of high and low
reflect actual practice and                                                                                         performing LEA/EIS programs based
                                  • Data manuals                          • Evidence of how root cause analysis
performance.                                                                                                        on data
                                  • Description of data process/oversight   is used
                                                                                                                  • Evidence of identification of best
                                  • Organizational Chart related to data • Process for making data informed         practices through the use of data
                                    and roles and responsibilities          decisions at the State level
                                                                                                                  • Additional sources of data beyond
                                  • TA/PD trainings for data users        • Guidance and/or training to LEA/EIS
                                                                                                                    616 and 618 data at both State and
                                                                            programs to use data to inform
                                  • EDFacts Data Quality Reports                                                    LEA/EIS program level
                                                                            decision making
                                  • APR Data Matrix

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    IF   A   S TATE H AS                       T HEN                                     T HEN                                   T HEN                         I NTENDED O UTCOME
                                • Data sharing agreements                • Training and guidance for LEA/EIS     • Evidence that the State uses its data
                                                                           programs on how to analyze data.        systems (e.g., monitoring, self-
                                • Public Reporting
                                                                                                                   assessment, database, due process,
                                • Evidence of meaningful stakeholder     • Evidence such as a data sharing
                                                                                                                   and State complaints) to improve
                                  involvement                              agreement, MOU, or information
                                                                                                                   program and systems operations
                                                                           attained during OSEP interviews
                                • Evidence that the State has a system                                           • Evidence that outcomes data within
                                                                           that State level Part C and Part B
                                  to ensure protection of personally                                               longitudinal data systems are
                                                                           619 staff regularly communicate
                                  identifiable data                                                                analyzed and used for improving the
                                                                           about outcomes data issues
                                                                                                                   programs

A State Performance             The State executes an approvable         The State reports annually to the       The State will work with LEA/EIS          An SPP/APR that demonstrates
Plan/Annual                     plan that evaluates the State’s          Secretary on the performance of         programs to address needed                progress on compliance and
                                efforts to implement IDEA                the State under the SPP/APR. The        improvement, in those areas that          results indicators will contribute
Performance Report
                                requirements and purposes and            SPP/APR demonstrates the State’s        are most closely related to               to improved outcomes for
(SPP/APR)                       the plan describes how the State         progress towards meeting the            improved outcomes.                        infants, toddlers, children and
                                will improve IDEA                        measurable and rigorous targets                                                   youth with disabilities and their
                                implementation.                          for each indicator that have been                                                 families.
                                                                         developed with stakeholder input.
                                                                         The State has a plan in place to
                                                                         address needed improvement.

         D EFINITION :               E XAMPLES    OF   E VIDENCE              E XAMPLES    OF   E VIDENCE             E XAMPLES    OF   E VIDENCE
A multifaceted plan that        • An approved SPP/APR                    • SPP/APR                               • Public Reporting
evaluates the State’s efforts   • Policies and procedures around the     • Improvement activities                • Training to LEA/EIS programs on
to implement the                  SPP/APR                                                                          Indicator Analysis and Evaluation
                                                                         • Cross indicator analysis
requirements and purpose of
                                • Evidence of stakeholder input in the   • Reasons for slippage                  • Policies and procedures around data
the IDEA and describes how
                                  development and the                                                              submission
the State will improve its                                               • Plans in place to address slippage
                                  implementation of the SPP/APR                                                  • Valid and reliable data
implementation.                                                          • Policies and procedures around data
                                                                           submission
                                                                         • Valid and reliable data

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PHASE 2
    IF   A   S TATE H AS                    T HEN                          T HEN                           T HEN                          T HEN                I NTENDED O UTCOME
Effective                        The State develops policies    The State effectively       The State ensures that              LEA/EIS programs               Effective implementation
implementation of                and procedures that are        implements its policies and LEA/EIS programs are                effectively implement          of policies and procedures
                                 aligned with IDEA and          procedures.                 knowledgeable about the             policies and procedures        will contribute to
policies and
                                 other Federal                                              policies and procedures.            that ensure the provision      improved outcomes for
procedures                       requirements.                                                                                  of FAPE in the LRE and EIS.    infants, toddlers, children
                                                                                                                                                               and youth with disabilities
                                                                                                                                                               and their families.

         D EFINITION :            E XAMPLES   OF   E VIDENCE     E XAMPLES   OF   E VIDENCE      E XAMPLES   OF   E VIDENCE      E XAMPLES   OF   E VIDENCE
Policies and procedures          • Annual IDEA Grant            • Evidence of LEA/EIS           • Evidence of dissemination     • Samples of LEA/EIS program
outline the goals, objectives,     Application                    program implementation of       of State policies and           policies and procedures
processes and statutory          • Evidence of systematic and     the State’s policies and        procedures                    • Sample documents (largest
requirements of a Part B and       periodic review of             procedures                    • Evidence of State TA/PD         LEA/EIS programs, Redacted
Part C Program, that are           implementation of specific   • LEA/EIS program websites        related to implementation       documents such as
implemented with fidelity.         policies and procedures        demonstrating consistency       of policies and procedures      IEP/IFSPs, to verify
                                 • Evidence of policies and       with State policies and         to its LEA/EIS programs         implementation/
                                   procedures being publicly      procedures related to IDEA    • Documentation of the State      compliance)
                                   available                    • The State monitoring            process for identifying       • Evidence of LEA/EIS
                                 • Evidence of accessible         reports of LEA/EIS programs     barriers to LEA/EIS program     program methods for
                                   policies and procedures on     on implementation of State      implementation through          identifying noncompliance
                                   State’s Website                policies and procedures         root cause analysis           • Examples of LEA/EIS
                                 • Review of communication      • Evidence of periodic review   • Documentation of what           program improvement
                                   to MSIP Customer service       of LEA/EIS program policies     LEA/EIS program corrective      plans
                                                                  and procedures                  actions were required
                                                                                                  and/or improvement plans,
                                                                                                  if applicable
                                                                                                • Evidence of meaningful
                                                                                                  stakeholder engagement

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                               during implementation, and
                               evaluation of LEA/EIS
                               program policies and
                               procedures

                      PAGE 13 OF 14
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