Patterns, Trends, & Tips: IDC TA Providers Share SPP/APR Insights, Part Two

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### Episode Transcript ###

00:00:01.52  >> You're listening to "A Date with Data" with your host, Amy Bitterman.

00:00:07.34  >> Hey, it's Amy, and I'm so excited to be hosting "A Date with Data." I'll be chatting with state and district special education staff who, just like you, are dealing with IDEA data every day.

00:00:19.50  >> "A Date with Data" is brought to you by the IDEA Data Center.

00:00:24.73  >> Hello, welcome to an episode of "A Date with Data." Now that states have submitted their federal fiscal year '22 SPP/APRs and hopefully have taken a much needed break, it is time to start thinking about the next SPP/APR cycle, especially because there are changes coming. On this episode we have two of IDC's TA providers, Rachel Wilkinson and Nancy Johnson, who are going to talk to us about what those changes are, what are some implications that states might want to be thinking about and some ways that states can get ready for those changes. Hello, Rachel and Nancy. Thanks for joining. So a lot of states might be somewhat familiar with what these changes are, but some folks listening may not be really be aware, so maybe start off, if that's okay, Rachel, talking about what these changes are to the FFY 2023 submission that will be due in February 2025.

00:01:23.20  >> Sure, so the approved changes that are going to take effect in the FFY 2023 submission, there's really ... I think of it as three buckets of changes, so the first is a change to the introduction, and this will also be a change to the instructions for this upcoming submission for 2023. So OSEP has added language for the introduction instructions to include eight elements, and they provide them in detail, but they're part of the state's general supervision system. Some of this information might already be something that states are including in their introduction currently. Some of the items look similar to the additional language that was added to the template and the instructions for the FFY 2022 submission. But there are some key differences that we did want to highlight so people ... It's good to get this kind of percolating in the mind to think about now because these are things you'll want to be able to easily address when you do get ready to start the submission process for 2023, which is not as far off as we always want it to be. Yeah, so the things that stood out to Nancy and I when we were looking at the changes, particularly to the introduction, were the requirement to include a description of how student files are selected for monitoring for indicators and for the verification of correction of noncompliance. Nancy and I review lots and lots and lots of drafts of the SPP/APR and kind of eat, drink, sleep, dream all things SPP/APR for a good chunk of the year. And we do notice that this is something we're not seeing often in the SPP/APRs we're reviewing, so it's something states are probably going to have to start adding in, particularly that verification of collection of noncompliance section. So sometimes there may just be comments that people have that say something to the effect of, "We verified through additional records that the noncompliance identified for X indicator has been corrected," but this is really asking for more detail of how those files are selected. And so being thoughtful and mindful of how you're going to respond to this as a state so that you have kind of clear processes in place, I think would be a really helpful thing to prepare for now rather than later right before the deadline is caving in. And then the other item was a description of how the state makes LEA determinations, and then that includes the criteria the state uses and the schedule for communicating the determinations to LEAs. I don't know that every state has that information in an accessible, quick way to write down. A lot of us use our institutional knowledge or people who maybe have notes documented here and there but maybe not in a cohesive description. So that's something to also be thinking about and keeping in mind as you prepare for the revisions to the introduction and these new components. So that really gets at the introduction piece, so that's sort of bucket one for the changes, so the second changes, the bucket that we're looking at, so to speak, is for Indicator 4. And these aren't massive changes, so these aren't things that may rock people's world, so to speak, or be super challenging, but they still are things that we're not seeing in our reviews called out consistently. So for Indicator 4, the requirement is going to be to now actually provide the numbers used in calculations, and that's based on LEAs that met n-n cell size requirements. So the state is going to have to define what those n-n cell size minimum requirements are as well as the rationale used for those minimum n-n cell sizes. That's explicitly called out in the new instructions. And then for option one, so if a state is conducting analyses of long-term suspension and expulsion data based on the state rates or the comparison of LEAs to each other across the state. Then the state would be expected to provide the actual state long-term suspension and expulsion rate. And then if they use option two, which is comparing students with and without disabilities within the same LEA who are experiencing those long-term suspensions and expulsions, if states are using a rate-difference methodology, like the difference in suspension and expulsion rate for students with disabilities compared to those without disabilities, then the expectation from OSEP is that the state will provide the actual ratio used, that difference, or their rate ratio used if that's how the state is conducting the analysis. So that information now explicitly needs to be called out and spelled out rather than maybe a more general description of what a methodology is without those nuances. And I think Nancy is going to tackle the big and third and final change that is on everyone's mind.

00:07:13.59  >> This is the one that I refer to as the biggie bucket, Indicator 18, and it is on everyone's mind. We get a lot of questions about that. People want to talk about Indicator 18 so they ... Most states, I believe, are aware of this change, and it focuses on the state's exercise of its general supervision responsibilities to monitor LEAs, and it must include findings from data collected through all components of the state's general-supervision system that are used to identify noncompliance. So I'm going to kind of go through these in short spurts here for a second. It can include information from the state-monitoring system or from the state's data system, dispute resolution, fiscal monitoring, for example, so really looking at all your different systems, your general-supervision systems, you would be pulling data about findings of noncompliance and then the verification of the correction of those findings ...

00:08:18.93  >> And, Nancy, that goes ...

00:08:19.64  >> ... for ...

00:08:19.79  >> That goes beyond the SPP/APR Indicators. Right? So it's not just ...

00:08:23.90  >> Yes.

00:08:24.13  >> ... thinking about ...

00:08:24.47  >> It is not just the indicators. It's looking at the indicators, findings within the indicators, but also findings in the other places related to the indicators. Now for FFY 2023, this will just pertain to the compliance indicators. However, if, for example, you have findings for, let's say, Indicator 11, then you would also need to look at findings related to the evaluation of students to determine eligibility that you might have found in some other system within your state. Maybe through complaints, you had findings of noncompliance related to that same thing. There is also the related-requirements document that states would want to look at and ensure that they're addressing any of those things related to Indicator 11, as an example. So while it pertains just to the compliance indicators, it is more broadly looking at all components of your general supervision where you might have identified a finding of noncompliance. So along with this, the baseline for FFY 2023 is expected to be FFY 2023, and states will have to provide rationale if they use a different baseline year for this indicator. And because this is a compliance indicator, targets are expected or required to be 100 percent. Again, you're going to use your related-requirements document to ensure that all of the IDEA regulations or citations associated with each of the compliance indicators for this FFY 2023 year are being reported, anything related to that, any findings you make. And it is based on, and this ... Sometimes states get confused about dates, but it is based on findings that were made in FFY 2022 and the status of the verification of the correction of the individual and systemic compliance within 1 year of when those findings were made or when LEAs were notified of those findings. So it is data that states are looking at right now in terms of the verification of correction of findings that they're making currently in this reporting year that were based on findings from the FFY 2022 year.

00:11:06.22  >> Okay, so it's noncompliance from the previous year that currently or already states should have issued findings already but should get districts in the process of verifying and correcting.

00:11:22.07  >> Correcting, and the state ...

00:11:22.93  >> And the state verifying.

00:11:23.70  >> ... and I'm going to emphasize, again, that word verification because it's not just the districts correcting the noncompliance. It's that the state has verified, used some methodology to verify that those corrections were actually completed and are acceptable corrections, that they actually corrected that individual findings and any systemic compliance. So it's important that they understand that they have to do that verification process within that year's timeline.

00:12:01.26  >> All right. So now that we've talked through the changes, what are some recommendations for how states can really prepare for these changes? Nancy, do you want to mention a few?

00:12:12.35  >> Sure. I'll be happy to start. First of all, I would recommend based on Indicator 18, which is the biggie bucket, to dig into the related- requirements document and make sure that all of their staff offices department and any staff responsible really understand any of those requirements and are aware of those requirements as it relates to the components, and that they need to provide this information to whoever is then completing Indicator 18 so that they need to be able to provide any information about the findings of noncompliance for FFY 2022 and then the verification of the correction of noncompliance so that whoever is developing, there will be a table in the tool that has certain requirements to complete all of this information. And it's got to be a joint effort. One person cannot do all of this, and it's different departments. Different people are working on different components that all may impact what those findings are.

00:13:24.76  >> Mm-hmm.

00:13:25.22  >> So digging into those related requirements, I would say, is the first thing I would recommend people do. And then I would also make sure that you establish with your staff a common understanding of the verification of correction of noncompliance processes. That it is not just the district correcting the noncompliance, it's the state verifying and how they verified that the district corrected the noncompliance. We're also in the process, or I would recommend that districts, if they haven't already, create some kind of a tool or process for how they track all of their information for Indicator 18 because it is a lot of data they're going to have to submit. And the sooner they start collecting that information and continue to add to it throughout the year until they're ready to submit would be helpful. And then maybe meeting with your team just to ensure that all the components for general supervision are clearly articulated and reflective of the work that is going on in a state. I know oftentimes when I meet with states, they'll be talking about work they've done with stakeholder engagement or other general-supervision requirements, but they haven't documented it or haven't included it in their SPP/APR, and they really didn't think about including it. But yet they're doing it, so they really need a way to document that and report it in their FFY 2023.

00:15:02.06  >> Yeah. You want to get credit for all that good work that you're doing.

00:15:04.87  >> Yes. You do want credit for that good work you're doing, absolutely.

00:15:09.60  >> We know states are getting into this and trying to figure out what needs they might have, as is IDC, how we can best support states with these changes, so what are some tools, resources, technical-assistant services that are out there and available or maybe things that we're working on that are going to be in place to help states related to implementing these changes?

00:15:34.44  >> When you mention this question was resources that exist currently, so the data-processes documentation is really valuable for making sure that states are capturing all the relevant information for the indicators, so thinking about the introduction as well as the changes for Indicator 4. This might be a good time for states who've done the data processes to revisit those and make sure that the information that's now required is reflected there for those data processes, and so everything is consistent. What's in their process documents matches what's in the SPP/APR because we know OSEP really wants that consistency across different reporting avenues, especially with the DMS visits that they're doing and looking at all that documentation. And for those of you who haven't done data-process documentation or have but maybe are thinking you could use some additional support, just a reminder that IDC will support these efforts and come and meet with your team, document information, facilitate conversation. So definitely reach out to your state liaison if this is something you're interested in doing, especially as you prepare for these changes or for monitoring visits or all that good stuff coming down the pike, so ... And then the last thing I can think of is that the Interactive Institutes that will be in Atlanta this year in June, so II 2024 will have some sessions that will be addressing these changes in the SPP/APR, so just a plug to take advantage of that opportunity to go to II '24 and learn about all sorts of things related to IDEA data, but in particular there will be a focus on Indicator 18 as well as some of these other changes, so ...

00:17:38.58  >> Thanks, and everyone will get a chance to meet Rachel and Nancy probably in-person and ask questions that you might have thought about during this podcast during the Interactive Institute. So definitely much more to come related to these changes, and do please reach out to your IDC state liaison with any questions or support that you might need. And thank you so much, Rachel and Nancy, for being on and giving us some insight into what's happening and what states can be thinking about, getting ready for it.

00:18:12.44  >> Thank you for having us, Amy. It was my pleasure to be a part of this, and we look forward to seeing everyone at II '24 and having the opportunity to discuss more of this with our state colleagues and each other, and thank you.

00:18:29.65  >> Thank you, everybody. This was great to talk more about this, and as Nancy said, we'll certainly be in touch with more information and hope to see you in-person at the different events that are going on across the country, including II '24.

00:18:45.63  >> To access podcast resources, submit questions related to today's episode or if you have ideas for future topics, we'd love to hear from you. The links are in the episode content, or connect with us via the podcast page on the IDC website at ideadata.org.