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

A Date with Data

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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.

00:00:24.56 >> Hi. Welcome to "A Date With Data." In early February, states submitted their federal fiscal year 2020-2022 SPP/APRs. IDC reviewed and provided feedback for many states' SPP/APRs, so we have a really unique perspective on overall patterns and trends, areas where states maybe are really doing well, others that seem to be more challenging, and maybe there is some room for improvement. So on this episode, I am joined by the two IDC TA providers who led the SPP/APR review effort, Rachel Wilkinson and Nancy Johnson. Thank you both so much for joining me. So let's start off by hearing about, what are some things that states are doing really well in their SPP/APRs? Rachel, do you want to go first?

00:01:14.98 >> Sure. So we were lucky enough this year ... I think we saw about 34 states, some version of their SPP/APR drafts, so it was great to really get a feel for how different states are tackling the SPP/APR, and for a lot of them, we saw improvements in the development of slippage statements. We know that that's been a challenging area because it really requires that digging into the data, and so it's less, "We need to fix this problem, and we're going to fix it in this way," but more in saying, "These are the reasons that the slippage occurred," so we've seen a lot of effort being made to really do that deep dive into the data, so that was really encouraging. Yeah, and then let's see here. I think some states were really good in describing their general supervision systems, so they provided more details about what those systems entailed. That might include things like their monitoring processes. That was a new example of different items to include in the general-supervision field in the instructions and then in the template this go-round, so we saw a lot more rich discussion about what states' general supervisions are. And then I think one thing with all the states we reviewed drafts for ... One thing that we were encouraged by is that they were getting them in really early, so people were submitting things in early December and some even earlier than that, which was great because that meant that they could take the feedback and really apply it and make sure that their drafts were high quality and compliant, and that was really encouraging to see, and I think the SPP/APR Summit has helped sort of spotlight the importance of working on this sooner rather than later.

00:03:15.54 >> Yeah, definitely. It's nice to have that summit occur when it does to kind of kick off in some ways. States probably have been working and should be on their SPPRs well before that, but the time where it really comes to putting pen to paper and really getting down into it and reminding states, of course, at that point too that we're available to review their SPP/APRs, and hearing that so many states took us up on that is ... It's really exciting.

00:03:41.89 >> Yeah, it was wonderful. We were thrilled.

00:03:44.03 >> Great. It's really promising to hear about all the ways that states are improving and doing well, and we know there are still some areas where states could use some improvement, and I'm wondering, Nancy, if you want to talk a little bit about what some of those are.

00:03:59.82 >> Sure, I'd be happy too, Amy. There is always room for improvement no matter how well we do things, and there are some ... a couple of areas that jump out at us that could use some improvement. One in particular was in the area of Indicator 4. OSEP had some very specific comments from states to address some requirements related to reasonable methodology with Indicator 4, and the state ... Some states really did not address those requirements with the comments from OSEP. They may be waiting for more directive from OSEP with regard to Indicator 4, and also, some states have let us know they had already issued their requirements regarding Indicator 4 earlier before they ever got their clarification or the OSEP letter in June, so they just kind of waited until maybe this year to take a look at it. We would suggest though that it would be beneficial for states to be thinking about their existing processes alongside stakeholders, including their stakeholders to ensure that children with disabilities are not being subjected to inappropriate removals that could prevent them from accessing instruction and which then would impact long-term outcomes for children to their adult lives, so that Indicator 4 area is a real ... not a concern to us but ... And we're waiting to also see how OSEP is going to respond to those requirements. Another area is in the area of stakeholder engagement. Some states did a nice job in that area, but many states provided more generic information regarding stakeholder engagement or referenced work they had done prior years, particularly prior to with that first submission of FFY2020, which is 4 years removed from that now, but it's worthwhile for states to be connecting with stakeholders regularly on an ongoing basis, and they should be addressing more than just setting new targets but also looking at their data analysis, their progress toward their targets, their improvement activities and their evaluations, and it was sometimes challenging for us to find information in there about what currently occurred this past reporting year related to stakeholder engagement. And then a third area that ... And this is one that's been kind of ongoing ... is in the area of corrections of noncompliance. Corrections in noncompliance is really about the state verifying [Indistinct] LEAs corrected any findings of noncompliance, and that verification of correction should be consistent with the OSEP QA 23-01 that came out last July and the requirements within. In particular related to correction of noncompliance, we saw and continued to see challenges with the correction of systemic noncompliance where it is unclear whether or not states really looking at additional records in addition to the findings of noncompliance that they initially made and then looking at then additional records that they were reviewing and when those reviews took place. We also saw that states sometimes still combine their individual child-specific noncompliance and their systemic noncompliance all together and just repeat it in both prompts when they really are two separate prompts for that information. And in some instances, we just saw some general boilerplate-type language about their monitoring and review process rather than specific language about what the state actually did to verify the correction of noncompliance, which is the OSEP requirement. So those are three kind of main areas that come to mind when we think about ways states can continue to improve their SPP/APR.

00:08:17.06 >> All right. Thanks, Nancy. And coming up in April is what's called the clarification period, so if there are things that come to OSEP's attention when they're reviewing the SPP/APRs, it's an opportunity to come back and ask questions. I think I kind of got that right, but I might be missing pieces of it. So maybe for newer state staff, Rachel, do you want to say any more about what the clarification period is for those who might not be familiar with it?

00:08:44.89 >> Sure, so this is an opportunity that OSEP offers. It's usually about 2 weeks in length where they'll have comments, feedback, sometimes clarifying questions, thus the name of the clarifications to ask about particular indicators, components of indicators and the introduction as well as other areas that they might look at, so it's important when you get those clarification notices from OSEP to dig into the different comments they've made, and all of those will be in that SPP/APR tool in the EMAPS data system, and then states develop responses, provide those to OSEP, and then based on those final responses, OSEP will provide any comments or questions, feedback that they might have as a result of their reviews of the SPP/APR, and then they'll review states' responses because each state will need to respond to those comments or questions, and then they will issue either additional required actions based on that feedback or any other comments that they think are appropriate, and then that information is what's finalized and reported in the final SPP/APR.

00:10:05.14 >> Okay. Thank you. And IDC is able and willing to review how states are addressing and responding to anything that comes back from OSEP during that clarification period as well, so just putting that out there for states.

00:10:21.25 >> Absolutely, and we would encourage you to make sure that you have at least someone there who can take notes or be an extra set of ears, so IDC state liaisons are great to be that resource, and we really do encourage during this time frame that states take up the offer from OSEP to review the clarifications as a group and to have a call to do so because then you can ask questions and get feedback on things. Maybe you have a question about a comment that was provided that wasn't clear. These are the calls that you can get that clarification, and some states have asked for clarification and found that issues that had been flagged really weren't issues, and they didn't have to address them, so that meeting with OSEP and then having someone there to help you with taking notes or listening in could be really valuable.

00:11:16.80 >> Great, so that's, I think, a helpful tip for states when it comes to addressing OSEP's questions and feedback. Are there other tips that you all have to share that might be helpful for states?

00:11:28.13 >> Well, I can think of one more, but I think Nancy's got a couple as well because she's worked with a lot of states on this.

00:11:34.40 >> Yes.

00:11:35.72 >> But one of my additional thoughts was just to come up with a strategic plan of how your group as a state is going to respond to the questions and clarifications. That helps everyone understand what the expectations are and how they're responsible for certain portions, so if you have an indicator lead who needs to answer a programmatic question, they're aware of what that clarification question is so that you can be strategic in your response as a state, or if there's a data-specific question, make sure you have your data manager, whomever put the data together for the indicator available and aware of the question so that they can give feedback, so again, kind of coming up with that plan internally so that the responses you as a state provide are coherent and reflective of all the expertise that might be needed.

00:12:31.26 >> Yes, and I do also have a couple of tips, and I would like to go back to the importance of the call with OSEP because sometimes states think or interpret the information that OSEP asked for and then learn during the call as they're talking about it that OSEP really meant something different than what the state thought they meant, so those clarification calls are very important. Along with that, it's important as you're getting ready for that call that you review all of OSEP's feedback carefully before you have the call, and I want to emphasize including the comments for the introduction section. I worked with a couple of states that had overlooked the introduction section and only focused on the indicators, but there are comments also in the introduction section. And then lastly, for the required ... Think about, for those required actions that OSEP is asking you to address next year, you want to ensure that you're documenting these and beginning to develop plans on how to address those actions, and if you thought about that before your clarification period, you could perhaps consider even ... or during the clarification period running those past OSEP during the call or asking them about them during the call as you're thinking about them so that that will help you know how to address those required actions in the next SPP/APR and just documenting any of that information.

00:14:14.01 >> Yeah, while it's still kind of fresh in everyone's minds and you have that chance with OSEP, yeah, might as well use it, and that's a great, great tip.

00:14:23.47 >> And then I would also emphasize having ... inviting your IDC state liaison to be on the call with you because they can be that extra set of ears and might hear something you didn't hear or also taking notes for you so you do have things documented.

00:14:40.05 >> Yeah. Wonderful. Well, thank you both so much. I picked up some great tips. Hopefully others listening did as well and really appreciate you being on the podcast.

00:14:54.11 >> Thanks, Amy. This was a pleasure.

00:14:56.45 >> Thank you, Amy. It was our pleasure to do this.

00:15:00.32 >> 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.