School Compliance Procedures

Janet Dinnen Quality Assurance & Accountability Director

Charter School Institute

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CSI Statutory Responsibilities

oApprove and deny applications as well as to revoke, renew, or non-renew charter school contractsoMonitor the operations of Institute schools to ensure compliance with state and federal regulations

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School Compliance PolicyoAdopted by CSI Board in 2011 oGuide for addressing and remedying situations of noncompliance before getting to non-renewal or revocation of a charter contractoUtilized by all CSI Departments •Data on noncompliance roll into a school’s annual evaluation and rating by CSI schools with more than three Notices of Concern in a year may have their rating lowered • Performance used to determine tier of support

ofewer notices = more autonomyomore notices = heightened monitoring 3

Frequency of Notices

• On average, schools receive 0.9 Notice of Concern per year

• Over the last 3 years, 2 Notices of Breach have been issued in total

• Over the last 3 years, 1 Charter Review has been issued

4

0 1 2 3 4+0

5

10

15

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Frequency of Notices of Concern Issued to CSI Schools by Year

2012-132013-14

# of NoCs

# of

Sch

ools

School Compliance Policy (2015)

5

Notice of Concern•Noncompliance with contract , rule, law, or policy

•Concern about academic, financial, or operational performance

Notice of Breach•Failure to meet Notice of Concern requirements

•Material breach of charter contract or applicable law

•More than 3 Notices of Concern within a year

•Situations identified under C.R.S. § 22-30.5-511 and 1 C.C.R. 302-1

Charter Review•Failure to meet Notice of Breach requirements

Revocation

Corrective Action Notice

6

CA

N v

s. N

oC

D

eci

sion

Tre

e

7

Compliance Process• Initiated when a school is identified to be out of

compliance with CSI requirements, rule, law, policy, or the charter contract

• While all situations of potential noncompliance will be investigated, the majority of situations do not result in a Notice of Concern

• The context surrounding issues of noncompliance will be reviewed and the situation will be evaluated against the following criteria

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Compliance ProcessCriteria 1. Does the issue hinder, disrupt or infringe on a student’s ability to access his/her

education?2. Does the issue impact the ability of CSI to fulfill its obligations to various stakeholders

(including other schools in the portfolio and CDE)?3. Does the issue represent a pattern of noncompliance or indicate larger systemic

issues within the school?4. Did the school fail to remedy identified issues of noncompliance from a previous

Corrective Action Notice?5. Does the issue jeopardize student and/or staff safety or represent a serious threat to

the school or community?

Is the response to any of the above questions a “Yes” ?

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A Corrective Action Notice

is issued

A Notice of Concern is

issued

NO YES

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Communicating Compliance

• CSI staff will notify the school in writing of the area of noncompliance and provide a timeline and actions necessary to remedy the situation.

• The school will submit the necessary information to the appropriate CSI contact by the deadline to remedy the situation.

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Corrective Action Notice

Notice of Concern

Notice of Breach

Issued by

CSI Department CSI Executive Director

CSI Executive Director

Sent to Department’s school level contact

School leader & Board chair

School leader & Board chair

The Process in Action• Scenario 1:• Issue:

o Schools receives an application, and the IEP box is checkedo There has been no enrollment determination

• Context: o The student’s IEP requires an OTo The student shows up on the first day of schoolo It is identified in week 3-4 that student had IEP

• Outcome:o Notice issued: Notice of Concern is issued to the school leader and

board chair, which provides the actions and timeline for remedying the situation

o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education?

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The Process in ActionScenario 2A• Issue:

o IEP meeting isn’t held by annual date

• Context: o In the 14-15 school year, the 15-16 annual IEP review date was set for

October 15, 2015o Parent isn’t able to attend on October 15th and reschedules for

later in the month

• Outcome:o No notice of noncompliance is issued since the parent was unable to

make the annual review date and reschedules

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The Process in ActionScenario 2B• Issue:

o IEP meeting isn’t held by annual date

• Context: o In the 14-15 school year, the 15-16 annual IEP review date was set for

October 15, 2015o Teacher isn’t able to attend on October 15th

• Outcome:o Notice issued: Notice of Concern is issued to the school leader and

board chair, which provides the actions and timeline for remedying the situation

o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education?

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The Process in ActionScenario 2C• Issue:

o IEP meeting isn’t held by annual date

• Context: o In the 14-15 school year, the 15-16 annual IEP review date was set for

October 15, 2015o School forgot to schedule meeting

• Outcome:o Notice issued: Notice of Concern is issued to the school leader and

board chair, which provides the actions and timeline for remedying the situation

o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education?

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The Process in ActionScenario 3A• Issue:

o Qualified SPED staff is not hired by the start of the school or the position becomes vacant

• Context: o School completes the Vacant Personnel Action Plan and

submits to CSI

• Outcome:o Notice issued: Corrective Action Notice of issued to school SPED

contact, which provides the actions and timeline for remedying the situation

o Rationale: “No” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education? because they provided an adequate plan for serving students in the interim

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The Process in ActionScenario 3B• Issue:

o Qualified SPED staff is not hired by the start of the school or the position becomes vacant

• Context: o School does not complete the Vacant Personnel Action Plan for

CSI

• Outcome:o Notice issued: Notice of Concern is issued to the school leader and

board chair, which provides the actions and timeline for remedying the situation

o Rationale: “Yes” response to following criteria: Does the issue hinder, disrupt or infringe on a student’s ability to access his/her education?

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For More InformationCSI Quality Assurance Webpage

[www.csi.state.co.us/school_resources/quality_assurance]

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SPED Submissions

Janet Dinnen Quality Assurance & Accountability Director

Charter School Institute

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Submissions Process

CDE/Data Pipeline provides reports to CSI on errors and validations

CDEImplements timelines for reports

CSI• Creates and

Communicates timelines for schools to ensure deadline is met

• Provides Training CSI

• Provides errors reports to schools

• Troubleshoots errors with school

CSISubmits data files to CDE’s Data Pipeline

School• Obtains error

reports and fixes information

• Provides files to CSI

School• Attends CSI

training• Maintains student

and staff level data• Provides data files

to CSI to submit per CSI’s timelines

School’s Role• Under CSI, you have more autonomy Schools

are responsible for completing all data submissions

• School’s Submissions Contact Responsibilities:o Data Integrityo Clearing Errorso Meeting CSI-Imposed Deadlineso Confirming accuracy of reports

• School’s SPED Contact Responsibilities:o Ensure data is up to date in your school’s plan management systemo Work with school’s Submissions Contact to ensure data integrity /

accuracy of reports

SPED Submissions • The Special Education IEP Interchange is a set of two files which contain

Special Education data for the school year: 1. Special Education Child file: contains data related to the student’s demographic and

contact information. 2. Special Education Participation file: contains data related to the student’s participation

in special education. 3. For SPED HR files:

• 2015-2016 File Layout and Definitions for Staff Assignment (PDF) • 2015-2016 File Layout and Definitions for Staff Profile (PDF)

• This information is used to make up the following snapshots: o Special Education December Count

• Coordinate with your HR Submissions contact to ensure all necessary data is collected for staff providing direct services to students with disabilities

o Special Education End-of-Year o Special Education Discipline

• Coordinate with staff responsible for addressing student discipline to discuss the process for reporting info regarding disciplinary incidents and actions for students with disabilities

See more at: https://www.cde.state.co.us/datapipeline/inter_sped-iep

SPED Submissions – Collaborating with School

Staff• Special Education December Count

o Coordinate with your HR Submissions contact to ensure all necessary data is collected for staff providing direct services to students with disabilities

• Special Education Disciplineo Coordinate with staff responsible for addressing student discipline to

discuss the process for reporting info regarding disciplinary incidents and actions for students with disabilities

Plan Management System• Schools are using one of the following plan management

systems to house student plans:o Alpine (see Alpine for training resources)

• Guide to Data Entry in Student Plans  • State Reporting utilities

o Infinite Campus (see Campus Community for Training Resources)• Special Education (Colorado)• State Reporting (Colorado) – for Dec Count, SPED EOY, SPED

Discipline reports

• Schools are responsible for:o ensuring they have collected all required information

• Ex: There are additional fields required for the December Count that are not required in the IEP (ex: EDID number for service providers)

o extracting the appropriate files from their plan management system and submitting them to CSI