Overview of the Annual Performance Report Development: See Indicator 1
Percent of noncompliance corrected within one year of identification:
Percent = [(b) divided by (a)] times 100.
States are required to use the "Indicator C 9 Worksheet" to report data for this indicator (see Attachment A).
This Indicator documents the correction of noncompliance within one year for findings identified in FFY08/SFY09 (i.e., those sent to CFC offices on December 18, 2008, and then revised on March 5, 2009) and on site monitoring visits conducted in FFY08/SFY09. There were no complaints or hearing requests that resulted in a finding of noncompliance. Of the findings identified in FFY08/SFY09, 59.2% were corrected within one year. The target for this indicator is 100%. For finding identified in FFY07/SFY08, 98.2% were corrected within one year. The two remaining uncorrected findings (under 8C) identified in FFY07/SFY08 have been corrected.
The drop in this measure from 98.2% in FFY08/SFY09 to 59.2% can be attributed to the addition of "prong 2" to findings identified for Indicators 1, 7 and 8, ensuring that CFC offices have correctly implemented the specific regulatory requirement, as defined in OSEP Timely Correction Memo 09-02. When a finding has been identified, the CFC office develops a corrective action plan and implementation is documented. Child-specific data are accessed through the data systems (i.e., the Service Delay Reporting and Cornerstone systems) and file reviews to ensure that correction for that child has occurred. Prong 2 involves the documentation that a CFC office has implemented the regulatory requirement using monthly statistical reports that show three consecutive months during which the CFC office shows (100%) compliance.
In FFY09/SFY10, the greatest challenge for correction of noncompliance was for Indicator 1, service delays, in which 20 of the 21 identified findings remain uncorrected. Challenges for timely services are discussed under Indicator 1. Several factors related to compliance with this indicator, including provider payment delays, are not under the control of the CFC office or the Bureau. For other indicators (7 and 8C) the issue involves documenting three consecutive months with 100% compliance. Several CFC offices fall in and out of 100% compliance with one or two consecutive months of compliance, but not 3 consecutive months. Non-compliance usually involves a very small number of children, as demonstrated by CFC-specific date for these indicators. Lack of correction of two findings for 8A involved noncompliance with1file in each of two CFC offices with an uncorrected finding.
Improvement Activities Completed: Illinois has a process in place to document the identification and correction of noncompliance as soon as possible but in no case later than one year from identification, which builds on Illinois' extensive use of its data system. The process of notifying CFC offices of findings has been combined with the determination process, allowing CFC offices to fully address areas of concern into a comprehensive correction action plan. As part of efforts to address noncompliance, all new service coordinators complete on-line training modules. The Illinois Early Intervention Training Program continues to update and modify the modules as needed and upon the request and approval of the Department.
For Indicator 1, 7 and 8C, correction within 12 months of the notification of a finding is now identified when data demonstrate that a CFC office has 100 percent compliance during three consecutive months.
For Indicator 8A, correction will be documented when no files at the subsequent annual monitoring review indicate a finding, based upon identified transition elements in the monitoring review tool.
Actions Taken if Noncompliance Not Corrected: Corrective action plans to address noncompliance policies, procedures, and practices are required to be written and implemented for any finding of non-compliance. Compliance is considered in setting determination scorecards if an agency fails to submit a credible corrective action plan, fails to make adequate progress, or fails to implement major features of the plan. Determination scores are negatively impacted by poor performance in performance measures.
Verification of Correction of FFY 2008 findings (either timely or subsequent): See steps outlined below.
Describe the specific actions that the State took to verify the correction in FFY 2009 of findings of noncompliance identified in FFY 2008: When a finding has been identified, the CFC office develops a corrective action plan and implementation is documented. In addition, the following steps are taken.
There are several elements of the CFC monitoring file review tool that relate to documentation of the transition process. Transition elements from the CFC monitoring file review tool that reflect compliance with Indicator 8(a) include the following:
Correction of Remaining FFY 2007 Findings of Noncompliance (if applicable)
If the State reported less than 100% for this indicator in its FFY 2007 APR and did not report that the remaining FFY 2007 findings were subsequently corrected, provide the information below:
Correction of Any Remaining Findings of Noncompliance from FFY 2006 or Earlier - not applicable
Additional Information required by the OSEP APR Response Table for this Indicator (if applicable):).
Illinois Part C is implementing a coordinated system of finding notification and correction.
On a quarterly basis, data will be reviewed to ensure that implementation of corrective action plans have been documented, child specific correction has taken place, and CFC offices demonstrate three consecutive months with 100 percent compliance. When compliance with OSEP Timely Correction Memo 09-02 is
present, CFC offices will be notified that correction of a finding has taken place. The program will also communicate with the EI Monitoring Program to track and document correction of noncompliance for 8A that has been identified through file reviews as part of the on-site CFC office review process. The system will also track correction of noncompliance identified based upon dispute resolution, complaints and hearings.
This will be implemented in FFY10/SFY11 as part of the finding notification process and will continue as an ongoing strategy.
Resources include the Bureaus of Early Intervention and Performance Support Services and the EI Monitoring Program.
Resources include the Bureaus of Early Intervention and Performance Support Services.
Beginning in July 2011and on an ongoing basis, "mini APR tables" will be provided to CFC offices on a quarterly basis, so that they can monitor performance on Indicators 1, 7, and 8C.