States have a responsibility, under federal law, to have a system of general supervision that monitors the implementation of the Individuals with Disabilities Education Act (IDEA) by local educational agencies (LEAs). An effective system is accountable for enforcing the requirements and for ensuring continuous improvement.

This issue of FOCUS on Results presents the components of Michigan’s general supervision system, including a brief narrative describing each component, followed by evidences of how the state or an LEA demonstrates compliance with the required system of general supervision.

The evidences highlight some of the key federal requirements. Requirements for general supervision continue to evolve over time as states use self-evaluation and examination activities to develop descriptions of effective systems of general supervision. Although the components of general supervision are presented as separate pieces of a puzzle (see Figure 1 below), each component must inform and interact with the other components for an effective system to exist.

Components of a System of General Supervision

According to the National Center for Special Education Accountability Monitoring (NCSEAM), an effective system of general supervision must include, at a minimum, each of the following components that inform and interact with each other:

1. State Performance Plan (SPP).
2. Policies, Procedures, and Effective Implementation.
3. Data on Processes and Results.
4. Targeted Technical Assistance and Professional Development.
5. Effective Dispute Resolution.
6. Integrated Monitoring Activities.
7. Improvement, Correction, Incentives, and Sanctions.
8. Fiscal Management.

The following component descriptions and evidences have been adapted from NCSEAM’s document titled Developing and Implementing an Effective System of General Supervision: Part B, January 2007, at www.accountabilitydata.org.

State Performance Plan (SPP)

The State Performance Plan (SPP) serves as an accountability mechanism for states and LEAs. The SPP consists of 20 indicators for IDEA Part B (ages 3 through 21) and 14 indicators for IDEA Part C (birth through age 2). Each of the SPP indicators has been purposely written to provide a measurable indication of a state’s performance in specific legal priority areas under Part B—Free Appropriate Public Education (FAPE) in the Least Restrictive Environment (LRE), Disproportionality, and Effective General Supervision, including Child Find and Effective Transitions.

Compliance indicators have targets set by the federal government’s Office of Special Education Programs (OSEP) and require absolute targets of 0 or 100 percent. Results indicators have targets set by each state with approval from the OSEP. Measurable and rigorous targets are established to set expectations for achieving high standards in state and local performance.

The IDEA regulations require that each state establish and maintain an advisory panel for the purpose of providing guidance with respect to special education and related services for children with disabilities in the state. The Special Education Advisory Committee (SEAC) is Michigan’s state advisory panel to the State Board of Education and the Michigan Department of Education (MDE). Stakeholders— including SEAC members; school administrators; parents; and the MDE, Office of Special Education (OSE) staff members—are actively and routinely involved in all aspects of the SPP. It is required that stakeholders are involved in establishing and revising targets.

Annual reporting of performance on the SPP indicators from the state to the OSEP occurs through a federally mandated Annual Performance Report (APR). The APR is an essential component of the accountability system. The APR must be publicly accessible by posting on a state’s Web site. The state must also report annually to the public on the performance of LEAs compared to the state targets. Michigan’s SPP, APR, and public reporting information can be obtained at www.michigan.gov/mde.

Evidence that the State Performance Plan component is part of a state’s or an LEA’s system of general supervision includes:

• The SPP is a living document that is revised as needed and used as a roadmap to guide improvement efforts at the state and local level.
• The state follows a strategic work plan for developing and implementing the SPP/APR.
• Stakeholders are actively involved in all aspects of the SPP, including establishing and revising targets.
• A statewide system is in place to evaluate the implementation and effectiveness of the SPP improvement activities.
• The state summarizes its progress toward state- and federally-established goals in an APR to the U.S. Secretary of Education.
• Information about the SPP is communicated in language understandable to the general public.
• The state publicly reports on LEA performance against state targets of the SPP.
• The SPP is integrated within the state’s accountability systems.

For more information, see FOCUS on Results, September 2008, Volume 6, Issue 3, Packet 12, Article 1: Understanding Michigan’s State Performance Plan (SPP), Annual Performance Report (APR), and Public Reporting at www.cenmi.org.

Policies, Procedures, and Effective Implementation

States have policies, procedures, and implementation strategies that align with and support the implementation of the IDEA. The policies and procedures are enforceable under state law and/or policies through the imposition of sanctions when necessary. The policies and procedures must include descriptions of methods the state will use to detect noncompliance of LEAs and to ensure correction of noncompliance when found.

The IDEA supports the implementation of research and evidence-based practices as important to ensuring positive results for students with disabilities. This also includes LEAs providing professional development to their personnel that includes information on evidence-based practices and enhances their skills. In addition, local programs are required to recruit and retain “highly qualified” personnel.

To ensure the implementation of the IDEA, it is necessary to coordinate efforts across state and local agencies. Interagency agreements or memoranda of understandings are sometimes necessary. As part of their efforts, collaborating bodies should discuss financial-related, service-related, and evaluation-related issues.

States are allowed to establish their own method for ensuring that LEAs follow state policies, procedures, and implement effective practices. One of the most common methods is to have LEAs submit assurance statements with their local application of funds.

Evidence that the Policies, Procedures, and Effective Implementation component is part of a state’s or an LEA’s system of general supervision includes:

• State policies and procedures align with IDEA 2004.
• State policies and procedures include descriptions of activities to identify noncompliance, methods of requiring correction of noncompliance, and the range of sanctions the state can use to enforce correction.
• The LEAs have policies and procedures in place to ensure that all personnel necessary to carry out the requirements of IDEA are appropriately and adequately prepared.
• States establish and maintain specifications for “highly qualified” personnel.
• State and local entities have policies and procedures in writing to guarantee a free, appropriate public education (FAPE) in the least restrictive environment (LRE).
• Required memoranda of understandings or interagency agreements ensure implementation of the IDEA, as well as the establishment of methods to determine their effectiveness.

Data on Processes and Results

As a part of a state’s general supervision responsibilities, a chain of events should occur when data are used for decision making about program management and improvement. These events include: (1) collection and verification, (2) examination and analysis, (3) reporting of data, (4), status determination, and (5) improvement.

1. Collection and Verification—The IDEA requires that data are collected from LEAs through a state-reported data collection and reported in the APR. To effectively use these data, LEAs must regularly update the data, and the state must routinely examine the collected data. States use the data (as well as information from other sources, such as other state-collected data, patterns, and trends in dispute resolution data and previous findings) to evaluate the performance of the state and the LEAs on the SPP indicators. These data are also useful in identifying the LEAs in need of monitoring (especially when these data can be compared across indicators). It is important for states to ensure that the data collected from the LEAs are accurate, as well as submitted in a timely manner. Accuracy has multiple levels, including that the data follow rules of entry or submission and that they reflect actual practice. States must develop multiple methods of verifying data accuracy. Data should be compared over time and disaggregated to levels that identify possible problems in validity and reliability.
2. Examination and Analyses—Data must be examined in a variety of ways to identify and determine patterns and trends. States should cluster related indicators to see whether relationships exist. Cross-indicator examinations are critical in determining “connections” among indicators and should always be considered while planning improvement activities (e.g., Part B graduation with test performance, dropout rates).
3. Reporting of Data—The federal government requires that each state’s collected data are reported to the public annually. The state’s performance on the SPP indicator targets must be included in this report. The state must also annually report on the performance of each LEA on the SPP indicators compared to the state targets. The LEA performance must be publicly accessible through such means as posting on the state’s Web site.
4. Status Determinations—Performance data on the SPP indicators for each LEA, as well as from other sources (e.g., fiscal audits, previous monitoring data) are used by states to make determinations of the status of each LEA. Based on the state’s specific criteria, LEA performance is evaluated and categorized as “meets requirements,” “needs assistance,” “needs intervention,” or “needs substantial intervention.”
5. Improvement—Data from the examination of LEA performance and ongoing state activities are used for program improvement and progress measurement. States also coordinate No Child Left Behind (NCLB) Act school improvement activities with SPP improvement activities. Technical assistance activities, designed to address the needs of each individual LEA, are based on data that are collected.

Evidence that the Data on Processes and Results component is part of a state’s or an LEA’s system of general supervision includes:

• Data are collected as required under the IDEA and by the U.S. Secretary of Education.
• Data are routinely collected throughout the year.
• The LEAs submit data in a timely and accurate manner.
• Data are available from multiple sources and used to examine performance of the LEAs. States make determinations on the status of the LEAs addressing the minimum requirements specified by the OSEP.
• Verification of data is achieved through multiple methods and activities.
• Routine examination of data at the state and local level is current and compared to previous years.
• Data collected through monitoring activities are summarized to examine cross years’ patterns and trends.
• State reports are accurate and timely.
• States include multiple measures of status in their determination decisions.
• Data are used to determine appropriate activities to assist LEAs and the state in meeting targets.
• Data are used to target and maximize technical assistance and professional development, as well as state resources.