Ensuring that students and children with disabilities are prepared to live independent and productive lives is the ultimate goal of all activities monitored by the Michigan Department of Education (MDE), Offices of Special Education and Early Intervention Services (OSE) and Early Childhood Education and Family Services (ECE&FS).

The Continuous Improvement and Monitoring System (CIMS-2) is a revised system used by the OSE and ECE&FS to help locals (a comprehensive term used in CIMS-2 to describe local educational agencies, public school academies, service areas, and state agencies) and the state monitor, analyze, and interpret data and ensure compliance with the Individuals with Disabilities Education Act (IDEA) of 2004 and the Michigan Administrative Rules for Special Education. The IDEA governs how states and agencies provide early intervention services, special education programs and services, and related services to children with disabilities.

This FOCUS on Results article explains Michigan’s monitoring system, how the CIMS-2 process and tools work, and provides information about the CIMS-2 electronic workbook. This article also shares how CIMS-2 is helping schools make improvements that lead to positive outcomes for all students.

Federal Requirements

The reauthorization of IDEA in 2004 required each state to develop a State Performance Plan (SPP) to evaluate its efforts to implement the requirements and purposes of the IDEA. In addition, states are required to indicate how they continuously improve upon this implementation. The federal Office of Special Education Programs (OSEP) established 20 SPP indicators for Part B and 14 SPP indicators for Part C that provide a benchmark for compliance with the IDEA and are used to measure the state’s progress.

Part B of the IDEA refers to special education programs and services for school-aged students ages 3 through 21. Part C of the IDEA refers to early intervention services for infants and toddlers birth through age 2. In Michigan, special education programs and services extend from birth through age 25—beyond the federal requirement of age 21.

Indicators for both Part B and Part C can be divided into results indicators—with targets set by the state—and compliance indicators—with targets set by the OSEP at 100 percent or 0 percent. By focusing on both results and compliance, the OSEP and the state can monitor how well the state is implementing the statute and its intent. Doing so also ensures that states focus on specific activities that will make a significant difference in the lives of children with disabilities. See Figure 1 and Figure 2 to view results and compliance indicator targets for Part B and Part C.

Michigan collects data from its locals and reports each locals progress toward meeting the targets in the SPP through submission of an Annual Performance Report (APR) to the OSEP each February. The OSEP, in turn, issues the state a determination—similar to a report card—on meeting the requirements of the IDEA. This typically occurs in late spring. Michigan also makes determinations for each of its locals, using a scale similar to that used by the OSEP. In May of each year, Michigan publicly reports on the performance of its locals.

To learn more about Michigan’s SPP, APR, determinations, and public reporting, visit www.michigan.gov/ose-eis or read the FOCUS on Results article Understanding Michigan’s State Performance Plan (SPP), Annual Performance Report (APR), and Public Reporting from September 2008.

Michigan’s Monitoring System

In order to meet the requirements of the IDEA, the state must continually review and analyze the performance of its locals. This review and analysis process and subsequent enforcement actions (if required) is what constitutes CIMS-2—or Michigan’s integrated monitoring system. CIMS-2 is part of a coordinated, integrated, system—known as Michigan’s Integrated Improvement Initiatives (MI3)—that promotes increased system efficiencies and effectiveness as well as improved student performance. To learn more about MI3, visit http://cenmi.org/About.aspx.

In assessing the performance of its locals, the MDE monitors data collected through:

• Focused monitoring activities (on site, desk audit, or self review).
• Complaints process.
• Local self assessments.
• Data review.
• Due process hearings.
• Local performance plans.
• Annual Performance Reports.
• Other activities.

Michigan evaluates the performance of each local against the SPP indicators. If areas of noncompliance with the IDEA or state or federal regulations are identified, the state must issue a finding of noncompliance to the local. A finding is a written notification explaining the area of noncompliance. It includes the citation of the statute, rule, or regulation and a description of the data supporting the state’s conclusion. The noncompliance must be corrected as soon as possible, but no later than one year, and verified by the state within that time period.

Redesign of the System

As knowledge about the efficacy of various programs and services has evolved, so have the criteria for monitoring the implementation and delivery of these services. While the original CIMS design focused on improving educational results for students with disabilities, it outlined 12 key performance indicators (KPIs) to reach this goal. These KPIs, which pre-dated IDEA 2004, were not aligned with the SPP indicators as articulated in the August 2006 regulations issued by the OSEP; therefore, a redesign of CIMS was needed. With the subsequent redesign and release of CIMS-2, in 2009, monitoring areas now directly align with all Part B and Part C SPP indicators. The MDE provided flexible, statewide trainings for locals in various formats (regional trainings, Webinars, online modules through Michigan Virtual University, and face-to-face workshops) throughout February and March of 2009. The new CIMS-2 electronic workbooks were launched on April 15, 2009, and locals began using their workbooks immediately.

Elements of the CIMS-2 Process

CIMS-2 processes and tools include the following:

Electronic Workbooks

Electronic workbooks help locals organize information and activities related to the monitoring process. Each local is issued a CIMS-2 workbook three times a year on April 15, September 15, and December 15. Each workbook contains a series of reports—some for informational purposes and some that require action on the part of the local.

A Series of Reports Containing Local Data

Reports and other tools in the electronic workbook are designed to assist locals to work through the entire continuous improvement process. The workbook guides users by providing a list of tasks that must be completed depending on the local’s performance on the SPP indicators (modularity). The electronic workbook helps locals to organize, implement, and track the status of reports and activities, and it provides the necessary reports, forms, and resources to successfully complete this process. The following reports are contained in the electronic workbooks:

Local Strand Report—A Local Strand Report groups the SPP indicators into compliance and results indicators and provides a measure of a local’s performance against the SPP indicator targets.

Determinations Report—A Determinations Report provides an annual rating of a local’s performance in meeting the requirements of the IDEA.

Monitoring Activities Report—A Monitoring Activities Report (MAR) gives information on MDE monitoring activities which affect the local. It is provided to each local three times a year and gives information regarding performance or other issues identified by MDE monitoring activities. A MAR may require action. The local reviews the report in each workbook cycle and makes sure required actions are performed and completed by the due date.

Report of Findings—A Report of Findings is a written notification issued to a local from the MDE citing an area of noncompliance with state or federal rules or regulations.

Review and Analysis Process (RAP) Teams

Each local must form a Review and Analysis Process (RAP) team to review and analyze CIMS-2 reports. Each team provides oversight, guidance, and structure in the planning process. The RAP team is responsible for (1) reviewing and analyzing local reports and data to gain an understanding of strengths and challenges, (2) prioritizing the underlying concerns, and (3) identifying the root cause of the problem. A unique feature of the CIMS-2 electronic workbook is its ability to ask probing questions which help the RAP team identify the underlying cause of the noncompliance and identify corrective action planning activities.

Teams then write Corrective Action Plans (CAPs) or complete other required monitoring activities to respond to the need to correct or improve. The electronic workbook contains CAP forms to guide this process. Alternatively, locals may identify their own activities. The MDE recommends that research-based practices be used, and a list of scientifically-based resources can be found at the What Works Clearinghouse Web site.

RAP teams also track the implementation and effectiveness of correction and improvement activities through status reports and team updates. RAP team members play a crucial role in the review and analysis of a local’s performance. The results of the RAP team’s deliberations will contribute to the success of a local’s special education and Early On® programs and services and can highlight areas where improvement can be made. RAP teams typically convene after the April 15 and September 15 workbooks are issued. The December workbook may not require a RAP team meeting unless a local has been issued a Report of Findings with the December 15 workbook.

Improvement Planning Process

The improvement planning process begins with understanding the data. CIMS-2 provides each local with a series of reports to place data into context and to assist the local district in starting the improvement process. Improvement planning consists of the following three parts:

• Correction of Noncompliance—A correction of noncompliance is what must occur after a local receives a finding of noncompliance about a specific section of a state or federal administrative rule, regulation, or law. Locals correct findings by creating and implementing a CAP.

  Once a RAP team develops a CAP, it is submitted to and reviewed by the MDE. The MDE will confirm that CAP activities are implemented and completed by the local as stated in the original plan and that the underlying noncompliance has been corrected. Once a local completes its CAP activities, the MDE reviews the status report and the evidence of correction. The MDE establishes whether the local is correctly implementing the specific statutory or regulatory requirements, and once correction can be verified, notifies the local and closes the CAP.

• Instituting Systemic Change Within an Organization (Planning for Improvement)—In addition to correcting areas of noncompliance, locals should continuously evaluate and address areas of systemic performance relative to other state and federal monitoring priorities. This process may include reviewing SPP results indicators to identify strengths or challenges, participating in a focused monitoring activity, conducting student record reviews, or engaging in a data validation exercise.These monitoring activities, which are not associated with compliance indicators, will be listed in the local’s MAR. The RAP team reviews and acts on these activities. For example, if a local has one or more results indicators that do not meet the state target(s), the RAP team must compare their local’s performance against the state target(s) and develop a hypothesis as to why the target(s) was not met. The team must then transmit the analysis to the district’s School Improvement Team (for Part B) or the Local Interagency Coordinating Council (for Part C) through a school improvement framework transmittal form. By doing so, there is now a direct connection between monitoring and overall (school) improvement.
• Verification of Correction—The final component of the improvement planning process is verification. Verification is the process by which the MDE confirms that CAP activities have occurred and that the local data show correction of the noncompliance. Verification activities can occur at three levels—MDE, local, or intermediate school districts (ISDs)—and may include activities within the CIMS-2 workbook, on-site verification by the MDE or ISD staff, or review of newly submitted data by the local to the MDE via the various state data collection systems.