United States Department of the Interior BUREAU OF rNDIAN EDUCATION Washington, D.C. 20240 IN RErLV Rt:fER TO AUG -7 2019 Ms. Susan Benbow Office of the Secretary Risk Management Services U.S. Department of Education 400 Maryland Avenue, SW, Room 7E208 Washington, D.C. 20202 Dear Ms. Benbow: The enclosed fourth quarterly Corrective Action Plan (Plan) for the Bureau of Indian Education (BIE) reflects Section A, Title I, Part A and Section C, Special Conditions (Special Education). The report covers BIE activities from April 1, 2019 to June 30, 2019. The BIE appreciates the support and partnership that is provided by you and the U.S. Department of Education. We look forward to meeting with your team and will be contacting you to schedule a meeting to review the Plan. If you have any questions concerning this report, please contact Juanita Mendoza, Special Assistant, at (202) 208-3559. Sincerely, Tony L. Dearman Director, Bureau of Indian Education Enclosures: Cumulative Narrative Report - Fourth Quarter, SY 2018-2019 National Office Reports cc: Philip Maestri, Director, Management Development Team Office of the Secretary, U.S. Department of Education BUREAU OF INDIAN EDUCATION Corrective Action Plan for the Fourth Quarter of School Year 2018-2019 SECTION A - ESSA ITask A.I: School Supports & Interventions Subtask A.1.1: The BIE will refresh the list of Low Performing Schools using BIE's current methodology or a modified methodology [ l l l l(c)(4)(D)]. Milestone A.1.1.1: Identify low performing schools and provide list to ED. Performance Metrics: (a) Describe the methodology. (b) Provide list to ED. Completion Date: March 31, 2019 Status: Completed Justification: Comprehensive Support and Intervention (CSI) schools must include the lowestperforming 5% of the state's Title I schools and high schools that fail to graduate at least two thirds of their students. Therefore, the number of CSI schools as a percentage of all schools may be more or less than 5%. It is compulsory to affirm that all BIE-funded schools operate Title l school wide programs and are Local Education Agencies (LEAs). The BIE previously reported the collection of SY 2016-17 and SY 2017-18 state assessment data and a modified methodology to refresh the list of Low Performing Schools. The BIE considered the impacts and challenges of comparing data across 23 states' assessments with varying performance measures and moved forward using available data. The BIE also compiled graduation rate data to identify high schools that qualify for CSL The resulting lists of schools based on proficiency and graduation rate are completed. See Enclosure A. I. I . I A: School Proficiency Rankings and High School Graduation Rates. Concerning proficiency rankings, dissimilar assessment data across 23 states remains a challenge for BIE. Nonetheless, BIE anticipates that gathering valid and reliable data will be facilitated when BIE adopts a unified accountability system across the entire BIE school system. BIE would like an opportunity to discuss this and other challenges with the Department of Education. The BIE has not yet identified Targeted Support and Intervention (TSI) schools because ESSA states that these schools must have one or more subgroups of students that are consistently underperforming. Due to the Negotiated Rulemaking (NRM) process, the BIE has not yet applied their ESSA accountability system based on the results of the NRM and anticipates applying it for the first time in SY 2019-20. The BIE currently does not have enough years of comparable data to determine whether subgroups are "consistently underperfonning." The BIE will begin identifying TSI schools in SY 2020-21. Subtask A.1.2: Developing a System of Interventions Milestone A.1.2.1: Identify Svstems of Supports and Interventions to Address Federal Program Requirements. The BIE proposes to deliver a differentiated system of recognition, accountability and support for each of the three categories of schools: Comprehensive Support and Improvement; Targeted Support and lmprovement; and Additional Targeted Support and Improvement for SIG Schools. The focus of this School Improvement l003(a) grant is to provide all children significant opportunity to receive a fair, equitable, and high-quality education and to provide adequate resources in order to substantially raise the achievement of students in lowest-performing schools. The BIE will be requiring its LEAs/schools to build on the requirement that not only develop the plans but also coordinate the school improvement funds with the activities to be carried out under such plans. Requirements for Comprehensive Support and Improvement plans (under statewide accountability system the LEA/school is located) must be developed and overseen for any schools identified for improvement under the accountability system. LEAs/schools have a leading role in developing these plans for schools in comprehensive support and improvement. All school improvement plans must: • • • • Be infonned by all indicators in the statewide accountability system; Include evidence-based interventions; Be approved and monitored by the LEA/school (or in the case of comprehensive support and improvement, by the BIE); and Result in additional action for underperformance over a period ohime. LEA/school and system improvement efforts are much more likely to succeed if all available resources are coordinated, instead of having staff work in isolation from one another. The LEAs/schools must ensure that the efforts funded with school improvement dollars are well aligned with those supported under other federal education programs, work toward the achievement of a single vision for excellence, and are held to the same accountability standards. The LEAs/schools may show how school improvement funds will work in tandem with other provisions and funding available under ESSA, including: • • Title II funding, which suppo11s professional development and other efforts to improve the quality, quantity, and diversity of educators using objective measures that can be incorporated into school improvement plans; Title IV, which includes funding for the new Student Support and Academic Enrichment Grants, which provide wide flexibility for how funds are spent and could be focused on helping to support strategies identified as part of the school improvement plans; and 2 • Provisions regarding data that must be collected at the LEA/school level, particularly the use of new data elements related to teacher effectiveness and resource allocation. The BIE has developed an approach, as outlined in CAP QI and Q2, 2018-2019. In addition, The BIE will begin in the 2019-2020 school year to provide the LEAs/schools information on the newly developed: BIE's Systems of Continuous Improvement Systems, Structures, and School Improvement Process Coherent Instructional System - the major system of the complex school organization that articulates and guides the "what and how" of instruction: I. Planning for Quality Instruction - the structure of the instructional system in which Teams plan what the students should know and do, and determine how their students will show they know the content and can do a skill or performance task. 2. Delivering Quality Instruction - the structure of the instructional system that guides teachers in how they introduce content, practice its use along with the students, and then allow students to use the content on their own while providing students regular standards-based feedback to gain mastery of the content. 3. Monitoring Student Progress - the structure of the instructional system that methodically discovers if the students are getting the content and what to do about it when they are getting it or are not getting it. 4. Refining the Instructional System - the structure of the instructional system that examines how to improve the planning for quality instruction, delivering quality instruction, and monitoring student progress. Professional Capacity - a major system of the complex school organization that develops a quality staff to reduce the variance of quality in instruction throughout the school. I. Attracting Staff- the structure of the professional capacity system that is intentional in locating the teachers and leaders that are the best fit for the school to achieve its mission. 2. Developing Staff- the structure of the professional capacity system that ensures the increasing quality of the staffs knowledge and skills. 3. Retaining Staff- the structure of the professional capacity system that ensures that quality staff is working in the context/position that is most beneficial to student achievement. 4. Ensuring Staff Collaboration - the structure of the professional capacity system that reinforces the effective practice of constant collaboration to improve instructional quality in all classrooms. Supportive Learning Environment - a major system of the complex school organization that ensures students' school participation and willingness to expend major effort on classroom learning: 3 l. Maintaining Order and Safety - the structure of the supportive learning environment system that ensures that the basic needs of orderliness and safety are met. 2. Developing and Monitoring a Multi-Tiered System of Supports - the structure of the supportive learning environment system that provides comprehensive services to students to meet their unique, whole-child needs. 3. Ensuring a Student Leaming Community - the structure of the supp011ive learning environment system that ensures compliance with positive and healthy behavioral and academic norms BIE's Systems of Continuous improvement Systems, Structures, and School Improvement Process. Family and Community Engagement - a major system of the complex school organization that develops quality links between local school professionals and the parents and community the school is intended to serve: I. Welcoming All Families and the Community - the structure of the family and community engagement system that ensures families and the community are active participants in the life of the school, and feel welcomed, valued, and connected to each other, to school staff: and to what students are learning and doing in school. 2. Communicating Effectively with Families and the Community- the structure of the family and community engagement system that ensures families/community and school staff engage in regular, two-way, meaningful communication about student learning. 3. Supportin!! Student Success - the structure of the family and community engagement system that ensures families and school staff continuously collaborate to support students' learning and healthy development both at home and at school, and have regular opportunities to strengthen their knowledge and skills to do so effectively. 4. Empowering Families - the structure of the family and community engagement system that ensures families are empowered to be advocates for their own and other children, to ensure that students are treated fairly and have access to learning opportunities that will support their success. 5. Sharing Leadership with Families and the Community - the structure of the family and community engagement system that ensures families/the community and school staff are equal partners in decisions that affect children and families and together inform, influence, and create policies, practices, and programs. 6. Collaborating with Families and the Community - the structure of the family and community engagement system that ensures families and school staff collaborate with community members to connect students, families, and staff to expanded learning opportunities, community services, and civic participation. Effective Leadership - a major system of the complex school organization that sets the direction for the LENschool, ensures that the school's staff is capable of meeting that direction, and makes sure the organization functions according to its mission. I. Creating and Maintaining a School Climate and Culture Conducive to Leaming - the structure of the leadership system that ensures that the school allows both adults and children to put learning at the center of their daily activities. 4 2. Cultivating and Distributing Leadership - the structure of the leadership system that develops others to accomplish the group's purpose and encourages the development of leadership across the organization. 3. Ensuring High Quality Instruction in All Classrooms - the structure of the leadership system that reduces the variability in the quality of instruction across all classrooms 4. Managing the School and Its Resources - the structure of the leadership system that ensures leaders effectively use all the resources at hand so that the school functions according to its vison and mission. 5. Driving School Improvement Efforts - the structure of the leadership systems that methodically, intentionally, and effectively improves the school's major systems, structures, and processes BIE's Systems of Continuous Improvement Systems, Structures, and School Improvement Process. School Improvement Process Steps: l. Identify Needs - consult many sources to determine what in the LENschool needs improvement 2. Select Interventions - research many sources to determine the solutions that have a good chance of meeting the identified school needs 3. Plan Implementation - develop a team and plan to implement the solutions that are most promising and can be carried out at the school 4. Implement Plan - cany out the plan to implement the promising solutions, making realtime adjustments where/when needed 5. Examine Progress - detennine whether the implementation of the promising solutions is meeting the originally identified needs of the school 2) BIE SUPPORT STRUCTURES (Developing a System of Interventions) BIE DPA Education Program Specialists DPA Education Program Specialists serve as liaisons to School Improvement Grant (SIG) schools. They are effective change agents and build solid connections between the schools and BIE. The DPA Education Program Specialists are expected to review the SIG grant applications and provide technical assistance to those schools eligible to receive a SIG grant. The DPA Education Program Specialists are expected to emphasize improvement by working with the schools to assist in the designing an improvement plan specific to each individual school. The DPA Education Program Specialists also support the school through monitoring. For example, the following team members from the BIE were recently involved in the development of a needs assessment resource manual for BIE school use: • • • • DPA Education Program Specialists both in SEP and IDEA DP A Supervisory Education Program Specialists in SEP and IDEA ADD/ERC Education Program Specialists ADDs/ERCs Associate Deputy Directors from Navajo Region (tribally-controlled and bureau operated schools) 5 • Education Program Administrators (EPAs) from tribally controlled and bureau operated schools These team members met with staff from the State Support Network to develop a Bureau of /11dia11 Education (Bl£) Needs Assessment Guidebook: Supporting Effective School Needs Assessment. The Guidebook was released in January 2019 for schools to use as a resource tool for the development of any required needs assessment. The DPA-SEP office provided several webinars to schools and BIE staff on the use of this tool for development in the SY20 l 9-2020 School wide/School Improvement Plan required for any ESSA program allocations schools received for this school year. 1 In addition, DPA-SEP staff presented a workshop entitled, Ro/lout of the BIE Needs Assessment Manual (ESSA) at six BIE 2019 Summer Regional Trainings. 2 BIE ADD/ERC Education Program Specialists An additional layer of support, for the School Improvement Grant (SIG) schools, is the ADD/ERC Education Program Specialists. These staff members are also effective change agents and strengthen connections between the school and the BIE. The ADD/ ERC Education Program Specialists are expected to work with principals, the school leadership team, and communicate clearly and effectively with all stakeholders. The primary work of the ADD/ERC Education Program Specialist is to build the capacity of the school and its staff so that school improvement is an ongoing process that can be sustained over time. The ADD/ERC Education Program Specialists support the school's improvement process through the effective use of data, shared leadership development, communication, embedded professional development, effective instructional and organizational processes and evaluation. When a school is ready to exit the lowest-perfonning school status the school is immersed in the improvement process and will be able to sustain the work of continuous improvement without the recurrent assistance of the BIE. School Leadership Team Principals cannot lead schools in the school improvement process without the support of the teachers and other school leaders such as, paraprofessionals, business managers, and counselors. Those individuals who comprise the leadership team must constantly reinforce the core beliefs and vision of the school. BIE schools utilize Native Star, which is the BIE's application method in which schools submit required federal education documents. As part of the Native Star process the school is required to list the names and positions of school staff who are members of the School Leadership Team. The school leadership team is accountable for creating focused and coherent school wide strategies to enhance student learning. The school leadership team is responsible for performing the following tasks, which are vital to the improvement process: 1 Webinars offered: April 5, 2019; April 22, 2019; May I, 2019; May 14, 2019; and, May 21, 2019. BIE Summer Regional Trainings: June 10-14, 2019 at Shemmn Indian High School (CA); June 17-21 2019 at Wingate High School (AZ); June 24-28, 2019 at Haskell Indian Nations University (KS), July 8-12, 2019 at College of Menominee Nation (WI); July 15-19, 2019 at United Tribes Technical College (ND); and July 22-26, 2019 at San Felipe Pueblo Elementary School (NM). 2 6 • • • • • • • • • • Develop an improvement plan; Implement the plan; Evaluate the implementation to inform future practice; Analyze school wide data; Provide a forum for communication among all staff; Promote a clear, consistent and compelling vision by cultivating trust through effective collaboration; Establish and support implementation of focused priorities for improving school and classroom effectiveness; and Monitor the effectiveness of the School Improvement Plan (SIG) based on input and data. By using a strong needs assessment to develop a plan for instructional and academic interventions, a school will be better able to analyze the possible reasons the school is not being able to meet the students ' academic or behavioral needs. The BIE will be recommending that schools utilize a strong problem-solving process to assist them in meeting students' needs. This problem-solving approach should assist the teacher in exploring, defining and prioritizing teachers concerns which will result in the school leadership team being able to select the correct intervention(s) for an individual student. When a strong problem-solving process includes ongoing progress monitoring to assess the success of instruction across all levels, more students will have the opportunity to be academically, socially/emotionally and behaviorally successful. The problem solving process involves the following steps: 1. 2. 3. 4. Identify and Define needs - What do we want students to know and be able to do? Analyze the Problem - Why is this problem occurring? Develop a Plan - What are we going to do about it? Implement and Monitor the Plan - Are we delivering the instructional supports for both academic and behavioral components. 5. Evaluate and Adjust the Plan - is what we are doing working? 7 Fi~re I: Problem-Solving Process Identify and Define Needs / I .. Evaluate & Adjust the Plan Analyze the Problem Implement & Monitor the Plan Develop a Plan This problem-solving process should include, at a minimum, the following team members: • • • • • • • Principal(s) General Education Teachers, including cultural and native language teachers Special Education Teachers Specialists Counselors Supp011 Staff Parents Throughout the continuum of instruction and intervention, planning/problem solving is used to match instructional resources to educational need. Teams continue to engage in instructional planning and problem solving to ensure that student success is achieved and maintained. The goal is to prevent problems and intervene early so that students can be successful. Coordination Between and Among Statewide System of Support Structures Research by Dwyer (2005), Lane, Seager, and Frankel (2005), Lusi ( 1997), and Massell ( 1998) suggests that regular communication, sharing of infom1ation across units potentially unaccustomed to collaborating and regular reporting of data are central to creating an effective system of support. 3 3 Cited in Redding, S., and Walberg, H.J., Editors (2008). Handbook on Statewide Systems of Support, Charlotte, NC: lnfonnation Age Publishing, 2008. 8 In recent years, the BIE has concentrated its efforts to build its internal capacity to provide schools with continuous school improvement support through a shared understanding approach. Findings from a study by Lane, et al., (2005) of New York State's strategy for school improvement support the idea that internal coherence defined as aligrunent and shared understanding of school improvement processes/approaches within and across levels of the multi-tiered educational system, will lead to a more effective school support system. 4 The BIE recognizes the importance of aligrunent and collaboration among various levels of staff in the BIE school system, based on a shared understanding of school improvement. Effort will continue to extend shared understandings across the BIE schools system. School Improvement Team Structure The BIE strongly supports a collaborative effort in the school to enhance school-based decisionmaking using a distributed leadership model that promotes local ownership of the structures, processes and practices that bring about school improvement. Schools must learn to use the power of collective action as well as the talents and commitments of skilled educators within the schools, to drive improvement efforts and to promote a culture of continuous learning for all. Peter Senge, author of Schools That Learn: A Fifth Discipline Fie/dhookfor Educato1:\·, Parents and Everyone Who Cares Abolll Education. believes: ... we are at a point in time where teams are recognized as a critical component of every enterprise-the predominant unit for decision making and getting things done.... Working in teams is the nonn in a learning organization.5 Professional development is offered to school leadership teams to familiarize them with the teaming process and to learn how the school can use the process to d1ive improvement efforts. The following graphic represents a suggested structure the BIE school leadership team could use for organization. 4 Lane, B., Seager, A. and Frankel. S. (2005). Leaming into a Statewide System of Support: New York State's Regional Network Strategy for School Improvement (2005). Providence, RI: The Education Alliance al Brown University. 5 Senge, P., et al. (1994). The Fifth Discipline Field Book Strategies and Tools for Building a Leaming Organization. Currency Doubleday, New York, pp. 354-355. 9 Figure 2: Example ofBIE Team Structure for School Improvement Support ,.... Jfflooltall~.... (SIUCWII fotu1) --- - -,...... .... ISdtoait lmptOWfflnit , .....1 Each team would have multiple functions. The following team structure would be used to advance continuous school improvement: Administrative Team - School Administration • This team would provide conditions that support and assist teachers in the effort of continually improving their collective capacity to ensure all students to acquire knowledge, skills and dispositions essential to their success • Develops the capacity of people throughout the school to assume leadership roles and to promote the role of leader of leaders • Establishes a coherent sense of purpose, direction and goals essential to improving the school • Provides time, structures and resources to suppo11 school improvement efforts School Leadership Team • This team would create focused and coherent school wide strategies to enhance student learning • Gathers and analyzes school wide data, including achievement, climate and satisfaction data. • Identifies gaps in performance or processes and plans for their improvement. • Assists the principal in making decisions to govern the school through shared decision making. • Ensures a focus on leaming and continuous school improvement. • Provides a forum for communication among all School Improvement Teams. • Promotes a clear, consistent and compelling vision by cultivating trust through effective collaboration. • Establishes and supports implementation of focused priorities for improving school and classroom effectiveness. • Monitors the effectiveness of the continuous school improvement plan based on input and data. 10 • Consists of school administrators, one member from each teacher collaborative team and others at the principal' s discretion Collaborative Teams • These teams are to assist in the improvement of the instruction and assessment of classroom cuniculum with a focus on student learning and practice • All teachers are participants in a collaborative team. • Collaborative teams are organized by grade or content. • The leaders of each collaborative team are also members of the school leadership team (recommended). • Collaborative teams work and learn together to adjust instruction to improve student learning. • Collaborative teams provide input to the school leadership team on school-wide actions to improve learning. Comprehensive Needs Assessment, Root Cause Analysis and Integrated Action Plan Support The ADD/ ERC School Improvement Specialists will support LEAs/schools to review and analyze the CAN, look deeper at the root causes for the primary concerns and detennining what evidence-based interventions might be the most successful to implement to effect marked improvement. School improvement action plans will be written by the CSI school and tracked, supported and provided technical assistance by the ADDIERC School Improvement Specialist. The goal is to ensure that the 2019-2020 School Improvement Plan will be specific, intentional and evidence-based removing the root causes, leading to dramatic student achievement increases. The cha11 below is an organic document and may be adjusted once the CSI school begins its analysis: Planning Strategy: Convene Administrative & School Leadership Team Members When Action Steps Responsibility Deep Root Cause Analysis Principal, Assistant Principal(s ), Committee Members March 2019 Research possible evidence-based Assistant Principal(s), April 2019 11 Objective: Determine best evidencebased course of action Resources Success Estimat Needed Criteria ed Budget Amount s Worksheets Root cause 4 hours identified that X8 when teachers extinguished X will result in $25.00 = $800 desired outcome Evidence Recommendati Total 20 and source hours x ons to full documentati Committee programs/interventi ons school SubTeams Select best fit intervention(s) for the school's context Assistant Principal(s ), Full Committee April 2019 Acquire/Plan intervention Principal./Assist ant Principal(s), Administrative & Leadership Team Members Administrative & Leadership Team May 2019 Staff Development Plan Professional Development Vendor/ staff Implement Plan for FY2019-2020 Administrative & Leadership Team with all staff input on for ESSA, Attendance research, etc. Copies of support documentati on Intervention Details May 2019 School calendar, Scope of Professional Developme nt June 2019 TBD July/Aug ust 2019 TBD 25 = $500.00 Decision Made Purchaseldesig n plan Written PD Plan 3 hours x8 teachers X 25 =$600.00 TBD TBD . Successful completion by all staff School CSI Plan completed TBD FY19 CS! Grant On-Site Support, Planning and Progress Visits The BIE Svstem of Technical Assistance Support is designed as follows: • Comprehensive Support and Improvement Schools (CSI) will be supported by the ADD/ERC School Improvement Specialists • Support continuous school improvement in all BlE schools • Assist identified lowest performing schools as well as other BIE schools as requested • Focus on leadership at the school level • Build LEA/school capacity to support lowest performing schools to guide continuous school improvement • Support the development of a network of schools within the BIE to guide continuous improvement • CSI schools will be tracked, supported, and provided technical assistance for the next three years by the ADD/ERC School Improvement Specialist to ensure continued improvement • CSJ schools must Exit this CSI status within four years. If not, the CSI School will be placed in a more rigorous intervention process. 12 CSI SUPPORT AND INTERVENTIONS BY THE BIE-ADD/ERC • CSI TRACKING, SUPPORT AND TECHNICAL ASSISTANCE BY THE BIEADD/ERC • On-site support visits based on needs Evidence-based Decision Making Support Analyzing Comprehensive Needs Assessment (CAN) data Root Cause Analysis Support in the planning process Support developing and implementing the schools Theory of Action/Logic Model plan Support with grant applications (see Enclosure A.1.2.1 A) and funding process Support with implementation of required LEA/school systems and structures Evidence-based Interventions Quarterly progress checks lnte1:,'l'ated support Desktop support as needed Leadership Development Professional Development • • • • • • • • • • • • • • • • • On-site technical assistance, support and tracking visits based on needs Comprehensive Needs Assessment Review Stralebry!Needs and Action Steps observed for completion from the schools Theory of Action/Logic Model Quarterly data reflection summaries Grant Review (Funded) - Budget Review - Ensuring LEA/School is spending down grant monies - Review of grant revisions (plan and budget) . Review of Benchmark Reports Submissions General Guidelines for on-site support, planning and progress tracking visits by the ADDIERC School Improvement Specialists: Prior to the visit, the LENschool site staff will establish an agenda for day(s) in collaboration with the ADD/ERC School Improvement Specialist. Each school is in a different place in the Comprehensive Needs Assessment (CNA), root cause analysis, and planning process. Site visits during the planning year will be very specific to the needs of individual schools. Keeping in mind the focus on reviewing and analyzing the CAN, looking deeper at the root causes for the primary concerns and detennining what evidence-based interventions might be the most successful, all visit will include: • • • ADD/ERC School Improvement Specialist and Principal conversation at the beginning of the visit for school status update, to review CNA, root cause analysis, current CSI School Improvement Plan and planning needs ADD/ERC School Improvement Specialist meets with Administrative and Leadership Team to review CAN, root cause analysis, current CSI School Improvement Plan and planning needs as well as current data Exit Interviews o Principal and Assistant Principal(s) o Administrative Team o Leadership T earn o School Collaboration Teams: Student Focus, Faculty Focus, School Improvement Focus and Stakeholder Focus 13 On-Site Visits may include: • • • Walkthrough classroom observations ( I 0-15 minutes each) using a pre-developed walkthrough protocol. o Observe in all Math and English/Language Arts classrooms o Observe in other classrooms as time pe1TI1its o Share the classroom observation data and provide feedback to Principal and/or Administrative and Leadership Teams Focus Group Interviews {approximately 30 minutes each) o Teachers (4-6) depending on school size o Students (4-6) grade 5 and above Follow-Up Meeting(s) o On-site or online to continue the discussion(s), tracking planning action steps, discuss evidence-based intervention possibilities, etc. The BIE's Strategic Direction that is currently being developed will support the foundation of continuous school improvement efforts. The BIE's Strategic Direction has six Missions that will outline clear expectations for excellence, provide rubrics for school reflection and drive continuous school improvement for all schools in the BIE. Those six Missions are: High-Quality, Early Childhood Education; Wellness Behavioral Health, and Safety; K-12 Instruction and High Academic Standards; Postsecondary and Career Readiness; Self-DetelTilination; and PerfolTilance Management. Each of the six Missions have Milestones, Actions, Goals and Strategies in which Year One is currently being implemented. Community stakeholder members will be encouraged to be invited by schools to take an active role in the cycle of Continuous School Improvement. Parents, guardians, and community tribal members may be asked to take part in the school's activities as a stakeholder and provide sf.the school feedback, as a stakeholder, and input into the School Improvement Planning process. Including the BIE's Strategic Perfonnance Plan initiatives as a part of the cycle of continuous school improvement is an intentional way that provides LEAs/schools with an understanding of the importance around using relevant, evidence-based interventions. The use of the relevant, evidenced-based interventions will be used to bring about rapid change to identified lowest perfom1ing schools. The continuous school improvement framework will support LEAs/schools in building capacity to work with their identified CSI and TSI schools to select and implement interventions that have the highest probability of improving student achievement. The LEA/school should focus on student learning as part of the continuous school improvement plan. The ADD/ERCs will assist the schools in detelTilining what issues the school has with student learning and will be able to assist in helping the school to make decisions in the following areas. ics Area of Concern for the School to Focus Activities/Tasks for the School to Focus 14 • Instructional Excellence and Alignment Teaching and Learning • • Instructional Excellence and Alignment Support for Student Achievement • • • • • • • Leadership Capacity Professional Capacity • • Planning and Operational Effectiveness • • Families and Communities • Note: Adapted from NCDPI. School to communicate high expectations to staff and students Cuniculum and Instructional Vertical and Horizontal Alignment Data Analysis and Instructional Planning Student Support Activities Strategic Planning, Mission and vision Distributed Leadership and Collaboration Monitoring Instruction in Schools Teacher Quality and Experience Quality of Professional Development Talent Recruitment and Retention Resource Allocation Facilities Management Technolo_gy Mana_gement Parental Involvement and Family Engagement Community and Stakeholder Engagement ADD/ERC School Improvement Diagnostic Team Review The ADDs/ERCs will schedule a Diagnostic Team visit. This visit involves a scheduled, full day school review completed by an ADDtERC Diagnostic Team of approximately four to six members of their BIE staff. The visit includes a classroom observation and interviews with teachers, students, counselors and administrators. Intervic\\.' questions will revolve around assisting the Diagnostic Team to make decisions on the types of and amount of technical assistance each Comprehensive and Targeted school needs. During the Diagnostic Review the ADDs/ERCs will follow established protocols to be developed by ADO/ERC BIE start: Each ADD/ERC Diagnostic Team will appoint a liaison to serve as the Comprehensive or Targeted School Improvement Coordinator to assist in the facilitation of the Diagnostic Review visit and follow-up review technical assistance. BIE School Improvement Diagnostic Review Process I. The ADD/ERC will contact the superintendent and/or principal of the Comprehensive/Targeted School to schedule the Diagnostic/Review visit. 2. Principal and/or Superintendent holds a meeting with school staff to explain that a BIE Diagnostic Review Team of team of 4-5 members will spend a day in the school. These Diagnostic Review Team members will be observing classrooms and interviewing students, teachers, staff, and administration. Principal/Superintendent needs to emphasize that the Diagnostic Review Team will be looking at overall processes and structures, not checking for compliance. IS 3. Also at this Review, school staff members will he given a form to complete concerning the school culture survey (TBD) and leadership effectiveness {TBD). School faculty and staff should feel secure in providing honest answers since the surveys are compiled in a data base. 4. The Diagnostic Review Team will spend a full day at the school using a pre-developed BIE school improvement observation fmm and a pre-developed interview questionnaire. These two fonns will assist in guiding the Review Team's discussions and facilitate their observations. Assessing the school leadership is a critical component of the diagnostic review. The Diagnostic Review Team will provide an overview of the strengths and weaknesses of the administration, along with recommendations for improvement. 5. At the conclusion of the day, the Diagnostic Review Team will debrief with both the school and school administration. The debrief meeting will be a time to share the major concerns of the day. Concerns about the leadership will be voiced at this time to the superintendent/principal so that he/she can begin to focus on the leadership of the school and detennine a plan of action. 6. A time will be scheduled with the school administration to return to the school and share the results of the culture survey and the diagnostic visit with the administration and faculty. The report is meant to provide an overview of the team's observations and infonnation gathered. It should be seen as a discussion tool to help guide the planning for the school improvement process. 7. Upon the return visit, the diagnostic report and culture survey will be shared with the entire staff. It is at this point, that the process becomes individualized based on the needs of the school. . Table_: , S ub.~roup ntervent1ons fior Com pre 1ens1ve &Tar~eted sCh00 lS SUBGROUPS INTERVENTIONS Intervention Support for Personalized Leaming -MTSS School Climate Technology Problem-solving Process Universal Design for Leamin~ (UDL) Differentiated Instruction lnfonnative/Classroom Assessment Scaffolding Vocabulary Cognitive Strategies Instruction Students with Disabilities English Language Learners Economically Disadvantaged/ Homeless High Absenteeism/ Trauma Related Issues/Gifted & Talented X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 16 Data Collection & Assessment System Service Delivery Individualized Education Program (IEP) Limited English Proficient Plan Early Warning System Mathematics Academy Teaching & Leaming Academy Dropout Prevention Program Basic Core Strategies for Dropout Prevention ( mentoring/tutoring, service learning, alternative schooling. afterschool opportunities) Cultural & Language Pro~rams X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X The DP A staff will assist he schools in ensuring the schools are making the best use of and are in compliance with their educational monies supporting the implementation of the school's continuous school improvement plan, including any Comprehensive Support and Targeted schools improvement activities. Funding Allocations • As federal appropriations allow, the BIE for the FY 19 funding year or SY 20 l 9-2020 will award the I003(a) fund allotments below for each category of federal identified schools: Catee:orv TSI CSI - Lowest 5% or former TSI schools CSI - Graduation Rate below 67%; only identification • Minimum 1003(a) Allotment Not Currently Applicable $ 150,000 $75,000 Schools identified for CSI support that are selected for turnaround by BIE will receive an annual 1003(a) supplement of $150.000 per school. CSI schools are identified based on multiple criteria. 17 • • • • Currently, BIE is not able to identify TSI schools, because BIE currently does not have enough years of comparable data to determine whether subgroups are "consistently underperforming." The BIE will begin identifying TSI schools in SY 2020-21. An LENschool may use section 1003(a) funds for any activity that it determines will help a school identified for comprehensive support and improvement improve student outcomes within the school. For example, an LENschool may use section I 003(a) funds to implement interventions aimed at improving the school, such as professional development, tutoring opportunities to increase student achievement in the school, and family engagement activities. Activities supported with section 1003(a) funds must be consistent with a school's comprehensive support and improvement plan. Please note that the schools are required to submit a Theory of Action/Logic Model plan outlining the school's indicating the alignment of the comprehensive needs assessment and the continuous school improvement plan the school developed (Enclosure In addition: • • • • • • • The LENschool must, in its application, include evidence-based interventions. Evidence-based interventions supported with section 1003(a) school improvement funds must be based on strong, moderate, or promising evidence of a statistically significant effect on improving student outcomes or other relevant outcomes, as defined in ESEA section 8 l OI (2 l )(A)(i). Develop a comprehensive support and improvement plan for the school identified for comprehensive support and improvement for which the LENschool receives school improvement funds. Monitor schools receiving funds under ESEA section I 003(a). Use a rigorous review process to recruit, screen, select. and evaluate any external partners. if the LENschool partners with one or more consultants to assist with the implementation of a school improvement method. Align other federal resources to carry out the activities supported with school improvement funds. As appropriate, modify practices and policies to provide flexibility that enables effective implementation of comprehensive or targeted support and improvement plans. Exit Criteria Comprehensive Support and Improvement Schools (CSI) are Title I, Part A schools in the lowest five-percent on statewide assessments. In order to exit this status schools must adhere to the following: • A school may exit CSI status if the school no longer meets the lowest 5% entrance criteria AND demonstrates an improvement in the overall state assessment score greater than or equal to 3% of the gap between the baseline state assessment score and 100. This 3° o improvement must be demonstrated from the highest of three state assessment scores used in a three-year average to the current state assessment score l8 • • implement school improvement goals and strategies and action steps in the BIE required CSI School Improvement Plan application be proficient above the BIE bottom five-percent of the Title I schools CSI schools will be tracked, supported and provided technical assistance by the ADD/ERC/ EPA and School Improvement Specialists for the next three-years to ensure continued improvement. If a previously identified CSI school Exits this status and the school falls into the bottom fivepercent again, the school will immediately be placed back into Comprehensive Support and Improvement status and subject to more rigorous interventions. CSI schools must exit within four-years of being identified. If not, these schools will also be subject to more rigorous interventions. Subtask A.1.3: SIG Planning & Implementation - l003(g) Milestone A.I.3.1: SIG Planning & Implementation - 1003(g) 3) BIE SUPPORT STRUCTURES (SIG PLANNING & IMPLEMENTATION) For those schools identified as school improvement grant (SIG) schools, the BIE will provide targeted support that promotes school wide efforts aligned to the following criterion: 1. 2. 3. 4. Establishing a Positive School Climate aligned with relevant cultural standards; Building capacity and supporting effective School Leadership; Aligning instruction with C1iterion-Focused Curriculum and Assessments; Building an infrastructure for Student Support Services and Family Engagement/Community alignment; 5. Developing and maintaining Educator Growth and Professional Development; 6. Building the infrastructure to support Efficient and Effective Management of both the Individual School Equalization Program (ISEP) monies and the federal education program monies received from the U.S. Department of Education (US ED); and 7. Building a culture of Continuous School Improvement. The BIE will support the implementation of the Turnaround Principles as outlined in the Elementary and Secondary Education Act of 1965 (ESEA) Flexibility in Priority Schools. The Turnaround Principles are as follows: • • • • • • • Provide strong leadership; Ensure that teachers are effective and able to improve instruction; Redesign the school day, week, or year; Strengthen the school's instructional program - rigorous and aligned; Use data to inform instruction; Establish a school environment that improves safety and discipline and addresses other nonacademic factors, such as, cultural relevance; and Engage families and community. l9 SIG schools will follow the same School Improvement Team Structure as Comprehensive and Targeted Schools do in A. l .2 Subtask. BIE's previous identified Priority Schools are the only schools that will be eligible to compete for the SIG l003(g) grant. The awarded schools receive SIG funds 1003(g) to implement a school intervention mode. The BIE will provide the following: • • • • • SIG 1003(g) funds to awarded to previously identified SIG Schools LENschool professional learning opportunities such as Leadership Conferences/Workshops will be provided by the ADDs/ERCs for LENschool leaders working in SIG Schools Regional professional learning opportunities that may pertain to the concerns of the SIG Schools ADD/ERC Education School Improvement Specialists will be available to support the SIG Schools in the implementation of their refonn initiatives/school improvement plan, the area(s) of concern highlighted by the school's needs assessment data, and the school's plan to use the Title I funding, if applicable. Targeted technical assistance workshops provided by the ADDs/ERCs related to the school's designation as a SIG 1003(g) school Sustainability for SIG l003(g) Cohorts Implementation and monitoring of a viable sustainability plan is a critical component as SIG l 003(g) schools approach the end of the funded grant period. The emphasis of such a plan is in identifying priority areas for program sustainability while developing goals, objectives, strategies, resources, and action steps. Each LENschool receiving SIG 1003(g) funding, is expected to develop a comprehensive Sustainability Plan, which defines elements for continuing the effective components of their grant while utilizing strategies that will ensure the school improvement work continues in subsequent years. SIG schools awarded 1003(g) monies for the SY2019-2020 for the final year of SIG awards: SIG 1003(g) Schools SY 2019-2020 (4 Schools) School Circle of Life Crow Creek High School St. Francis Indian School Theodore Roosevelt School To'haiiile Community School T,·pc of School Tribally Controlled School Tribally Controlled School Tribally Controlled School Tribally Controlled School Tribally Controlled School Fundin2 Amount $340,000 $317,544 $340,000 $340,000 $308 ,000 Milestone A.1.2.1: Identify system of supports and interventions to address federal program requirements. Performance Metrics: 20 (a) Ensure that the all elements of the Consolidated Application is collected for all schools. (b) BIE (ADDs, EPNERCs, and DPA) will provide appropriate Technical Assistance to schools (c) BIE (ADDs, EPNERCs, and DPA) will provide interventions targeted to the specific needs of each school. (d) BIE will develop a Memorandum of Agreement (MOU) that outlines the responsibilities of BIE and the LEA. (e) BIE will monitor through progress checks to ensure that MOU is on track. Completion Date: June 30, 2018 Status: In Progress. The BIE proposes to deliver a differentiated system of recognition, accountability and support for each of the three categories of schools: Comprehensive Support and Improvement; Targeted Support and Improvement; and Additional Targeted Support and Improvement for SIG Schools. The School Supports and Interventions document (see Table 3, below) outlines the strategic plan and federal program plan requirements, technical assistance responsibilities and expected interventions, as well as accountability, progress review and rewards/consequences for each of the school categories. The differentiated nature of the proposed system is demonstrated in the progressive nature of each element of the chart as the intensity of service, support and accountability increases. Ta bl e 3 SClOO I IS upports and Interventlons SCHOOL SUPPORTS& INTERVENTIONS Plan Requirements Fcderal Program Requirements TA Responsibilities COMPREHENSIVE SUPPORT & IMPROVEMENT SCHOOLS TARGETED SUPPORT AND IMPROVEMENT SCHOOLS School Strategic Plan to include data analysis to determine root causes & develop a targeted goal(s) for meeting applicable BIE accountability criteria School Strategic Plan to include data analysis to determine root causes & develop a targeted goal(s) for meeting applicable BIE accountability criteria Consolidated IDEA &ESEA applications must include objectives for supporting nonprogressing schools TA from SEA/BIE, including DPA, ADDs, ERCs& approved Consolidated IDEA & ESEA applications must include objectives for supporting non· progressing schools TA from SEA/BIE, including DPA, AD Os, ERCs & approved external providers to 21 ADDITIONAL TARGETED SUPPORT& IMPROVEMENT SIG SCHOOLS School Strategic Plan to include data analysis to determine root causes & develop a targeted goal(s) for meeting applicable BIE accountability criteria Consolidated IDEA &ESEA applications must include objectives for supporting nonprogressing schools TA from SEA/BIE, including DPA, ADDs, ERCs & approved SUCCESS/REWARDS SCHOOLS School Strategic Plan to include data analysis to detennine root causes & develop a targeted goal(s) for meeting applicable BIE accountability criteria Consolidated IDEA & ESEA Applications - TA from SEA/BIE, including DPA, ADDs, ERCs & approved support planning & implementation processes Expected Interventions Operational Accountability Progress Review Reward & Consequences School determined interventions facilitated by the BIEs DPNADD/ERC and articulated in the School Strategic Plan and Consolidated Application for IDEA & ESEA applications MOU articulating the responsibilities & expectations of each supporting agency & the school leadership team Annual progress review by local board of education, and BIE's DPA, ADD and ERC. Specific School Strategic Plan requirements • Required implementation of approved interventions with alibrnment of ESENIDEA funding • MOU accountability • School pro1:rress review& redirection as warranted external providers to support planning & implementation processes School determined interventions facilitated by the BIEs DPNADDtERC and articulated in the School Strategic Plan and Consolidated Application for IDEA& ESEA applications MOU articulating the responsibilities & expectations of each supporting agency & the school leadership team Annual progress review by local board of education, and BIE's DPA, ADDandERC. Specific School Strategic Plan requirements • Required implementation of approved interventions with alignment of ESENIDEA funding •MOU accountability • School progress review& redirection as warranted external providers to support planning & implementation processes Turnaround Principles aligned to the BIE School Improvement Framework external providers to support planning & implementation processes School determined inter.ventions :1 MOU articulating the responsibilities & expectations of each supporting agency & the school leadership team Annual progress review by local board of education, and BIE's DPA, ADD and ERC. Specific School Strategic Plan Requirements: • Required implementation of turnaround principles & consequences with alignment of ESENIDEA funding •MOU accountability • School progress review & redirection as warranted School operating procedures Annual progress review by local board of education, and BlE's DPA, ADD and ERC. Recognition for Reward- High Performance • Showcase best practices School Supports and Interventions Plan Requirements will be met through the BIE's recently developed strategic plan, which consists of the following components: Vision, Mission, Core and Beliefs, prioritized issues based 22 on data analysis, goals and objectives. The basic strategic plan will be required of Success Schools. The targeted strategic plan will include all components of the basic plan along with action steps to address how applicable subgroups will meet proficiency rates. This will be required of all BIE schools. The extended strategic plan requires a more comprehensive analysis of data to identify root causes and detailed action steps to improve student achievement. This will be required of all Comprehensive, Targeted, and Additional Targeted Support Schools to SIG Schools. BIE's • • • • DPNSEP Accountability Index Components: Proficiency Rates, including subgroups Participation Attendance Rates Graduation Rates Schools will be required to provide objectives to address how IDEA and ESEA funds will be utilized in identified schools through the Consolidated IDEA and ESEA School wide Plan application. Comprehensive Support & Improvement Schools; Targeted Support and Improvement School and Additional Targeted Support and Improvement for SIG Schools will also complete the simply complete the application. Technical Assistance Responsibilities will be distributed among vmious providers including the various divisions of BIE which will include the Division of Performance and Accountability (DPA) whose two units are ESSA and IDEA; Associated Deputy Directors (ADDs); Education Resource Centers (ERCs) and approved external providers. The school designation will dete1mine the support provided. Expected Interventions will be provided according to the school's designation. Interventions for comprehensive support and targeted schools will be aligned to the ESSA and IDEA requirements. Additional Targeted Support and Improvement for SIG Schools will be aligned with SIG requirements. Schools will identify interventions from the approved menu based on needs identified in the diagnostic review. Operational Accountability will be managed both at the ADDIERC and DPA level for comprehensive support and targeted schools. Schools will be required to sign a memorandum of understanding (MOU) detailing role definition and accountability at each level. Progress Reviews will be conducted annually by the SENBIE based on school's designation and submitted to the local and/or tribal boards of education for appropriate action. Rewards and Consequences range from monitoring exemptions and showcase opportunities to extended strategic plan requirements and MOU describing accountability at vmious levels. The process the BIE will use to determine school designations ensures schools of every degree of quality are represented in the accountability system. The school designation will determine the 23 source(s) and depth of technical assistance provided. As indicated in Table 3, under TA Responsibilities, the BIE in conjunction with the various units (DPA, ADDs, ERCs), is responsible for providing technical assistance to Comprehensive Support and Improvement; Targeted Support and Improvement: and Additional Targeted Support and Improvement for SIG Schools. The remainder of this document will concentrate on the processes and procedures used to support these identified schools. The school improvement process utilized by the BIE follows the U.S. Department of Education recommendations that schools in need of improvement: l. 2. 3. 4. conduct a needs assessment, develop a plan for improvement, implement the plan, and then evaluate the implementation of the plan in order to inform future practice. These tasks are the key responsibilities of school leadership teams. Technical assistance provided by the BIE and other support groups is intended to complement rather than disrupt the recommended cycle of improvement. Services typically provided to schools include the following: a. b. c. d. e. establishment of school leadership team and collaborative teams, assessment of readiness and building capacity, development of improvement plans, monitoring and adjustment of plans, technical assistance related to curriculum and instruction, student engagement and culture and climate, f. data training and support for using assessments. g. leadership development, h. support with parent and community involvement, and 1. Dissemination of knowledge. There are multiple reasons why schools are unable to fully address the needs of all students; therefore, efforts to help schools improve must be individualized. The actual services that are provided should reflect the documented needs of the school. Once local needs are identified, the BIE's system of support can draw from a host of supporting groups to customize services to reflect the schools' and districts' unique challenges. For those schools identified as Comprehensive Support and Improvement, Targeted Support and Improvement, and Additional Targeted Suppo1t and Improvement for SIG Schools, the BIE will provide targeted support that promotes school-wide efforts as follows: l. 2. 3. 4. Establishing a Positive Climate and Cohesive Culture; Building capacity and supporting effective School Leadership; Aligning instruction with Standards-Based Cuniculum and Assessments; Building infrastructure for Student Support Services and Family/Community/T1ibal Connections; 24 ---------------------------------------~-5. Developing and maintaining Educator Professional Growth and Development; 6. Building the infrastructure to support Efficient and Effective Management of the school and its federal education programs; and 7. Building a culture of Continuous School Improvement. BIE's Process for Identifying CSI and TSI Schools Including Exit Criteria Table 4: CSI Criteria for Identification Comprehensive Support and Improvement (CSI) Criteria Criteria Cate2ory Entrance Criteria Lowest 5% Title I Schools: 1 Ranked according to threeyear test averages in EILA and math and are among the lowest perfotming schools that arepresent 5% of all schools eligible for identification. 2 Low Graduation Rate All High Schools: Ranked according to threeyear four-year adjusted cohort graduation rates averaged and less than or equal to 67%. Exit Criteria A school may exit if the school no longer meets the lowest 5% entrance criteria AND demonstrates an improvement in the overall state assessment score greater than or equal to 3% of the gap between the baseline state assessment score and I00. This 3% improvement must be demonstrated from the highest of the three state assessment scores used in the three-year average to the current state assessment score. Attain a four-year adjusted cohort graduation rate greater than 67°0. Plan of Support • • • • • • Ongoing collaboration and technical assistance for continuous improvement District and school level reviews and walkthroughs Annual Title 1, Part A l 003(a) School Improvement Funds formula allocation Professional learning BIE School Improvement Education Program Specialist to support LEAs/schools in their plan of support for Comprehensive Support and Improvement (SCI) schools School Diagnostic Team - On-site, on-going support provided by a BIE ADD/ERC School Improvement Education Program Specialist and BIE ad hoc members as needed 25 Funding • As federal appropriations allow, the BIE, at the minimum. will annually award the I 003(a) fund allocations for each category of CSI schools as referenced in Table 5, below: T a bl e 5 Compre hens1ve support and Im1provement (CSI) Criteria Criteria Category Minimum 1003(a) Allocations 1 Lowest 5°0 $150,000 2 Graduation Rate 67% or Below $75,000 • • Schools that are identified based on multiple criteria will receive the highest amount allocated All funding is pending federal approval Guidelines • • • • Memorandum of Agreement (MOA) between LEA/school and BIE to set shared expectations and responsibilities ADDs/ERCs/EPA and School Improvement Specialists to create an LEA/school plan of support for identified schools Identified CSI Schools will conduct a CNA and create a School Improvement Plan (SIP) for 20 l 9-2020 Attend required BIE professional learning Targeted Support and Improvement (TSI) for BIE LEAs and Schools Note: Currently the BIE does not have adequate subgroup data to determine schools that would be placed in this category. All BIE schools identified at the moment rest in the Comprehensive Support and Improvement category. The BIE is requesting ED provide technical assistance in identifying subgroups that are specific to the BIE. Table 6: TSI: Criteria for Identification Targ~ted Support and Improvement (TS() Criteria Criteria Entrance Criteria Gate2orv 1 Consistently All Schools: UnderHave at least one subgroup performing that is performing in the Subgroup lowest 5% of all schools in at least 50% of the state assessment components. 26 Exit Criteria A school may exit if no subgroup is perfonning in the lowest 5% of all schools in at least 50% of state assessment components. 2 Additional Targeted Support ' All Schools: Among all schools identified for consistently underperfonning subgroup, have at least one subgroup that is perfonning in the lowest 5% of all schools in all state assessment components. A school may exit if no subgroup is perfonning in the lowest 5% of all schools in all state assessment components AND the subgroup's current score is greater than the previous score for all components in which the subgroup is no longer in the lowest 5% of all the schools in at least 50% of the state assessment components. Note: Title I schools identified for additional targeted support will move to the CSI list if they do not meet the TSI exit criteria after three consecutive years. I I Plan of Support • • • • • Ongoing collaboration and technical assistance for continuous improvement LEA/school level reviews and walkthroughs by the ADDt ERC School Improvement Specialist as requested Annual Title I, Part A 1003(a) School Improvement Funds fonnula allocation Professional learning BIE ADD 1ERC School Improvement Specialist to support LEAs/schools in their plan of support for identified schools Funding • As federal appropriations allow, the BIE, at the minimum, will annually award the I003(a) fund allotments below for LEAs/schools on behalf of TSI schools. All funding is pending federal approval • Tabl e 7 TSI Fun d.m~ Cntena . Targeted Support and Improvement (TSI) Criteria Criteria Category 1 Consistently Underperforrning Subgroup Additional Targeted Support 2 Minimum 1003(a) Allocations $ Amount TBD per school $ Amount TBD per school Guidelines • • • Memorandum of Agreement (MOA) between LEA/school and BIE to set shared expectations and responsibilities Create a LEA/school plan of support for identified schools Identified Schools will conduct a CNA and create a School Improvement Plan (SIP) for 2019-2020 27 • Attend required BIE professional learning For CSI and TSI schools only a School Improvement Plan template will be provided to those schools with the BIE offering Webinar trainings on how to complete the template. In addition the ADD/ ERC School Improvement Education Specialists will work with the schools identified as CSI and TSI in completing their school improvement plan. CSI TIMELINE Planning Year 2018-19 School year 2018-19 was a planning year for BIE schools. This was time BIE schools have not had in previous school improvement cycles. Schools have always been asked to plan and implement in a very short timeframe. This planning year allowed schools to work collaboratively with staff and stakeholders as well as to review and analyze the CNA, look deeper at the root causes for the primary needs and then to identify evidence based processes, programs, and/or interventions that would extinguish the root causes and result in a sustainable desired outcome. The goal was to ensure that the 2019-20, School wide/School Improvement Plan in Native Star specific, intentional and evidence-based, removing the identified root causes, leading to dramatic student achievement increases. This planning year will assist BIE schools now identified as CSI schools to have data which will assist these schools in completing the CSI application for the 2019-2020 school year. Evidence Based Decision Making6 Evidence-based decision-making & reflection are the core of the continuous school improvement process and are used in each step. The steps overlap. with each step leading into the next, so that, the Analyze step begins before the Implement step is completed. The BIE is aware the broad intents of the Elementary and Secondary Education Act (ESEA), as amended by Every Student Succeeds Act of2015 (ESSA), is to encourage evidence-based decision-making as a way for schools to implement their school continuous improvement plan. §200.21 of ESSA requires a state to review and approve each comprehensive support and improvement plan in a timely manner. Further, the regulations require the state education agency 6 Hale, S.• Dunn. L . Filby, N, Rice:. J., &. Van Houlcn. L. (201 7). friclc11c,·-bascd 1mpro1-cn1e11t: ti guide for stut.:s to strcng//,c11 theirframcll'orl,.s cmd :mpportr aligned tu th.: cviclc11cc rcq111rcmc11rs of ESSA . San Francisco: WcstEd. 28 (SEA) to monitor and periodically review each local education agency (LEA)'s implementation of its plan. The provisions in ESSA also lend themselves to the use of an iterative, continuous improvement process. The law specifies that states are to continuously evaluate the effectiveness of interventions carried out under several federal grant programs (e.g., ESSA, 2015, Section 4624[ 10]). Finally, regulations of ESSA (24 C.F.R. § 200.23, 2016) require states to evaluate the effects of evidence-based interventions on student achievement and other outcomes, and to disseminate the results of those evaluations to LEAs. Interventions must have an impact on "meaningful student outcomes". ESSA and, more generally, the evidence-based decision-making movement emphasize the importance of evidence in infonning decisions. Knowing and building on what has worked in the past, and specifically for whom and in what circumstances, offers a better chance of success in the future. A continuous school improvement process starts with the problem, rather than the solution. It includes addressing a discrete issue or problem by systematically testing potential solutions while tracking well-defined and measurable goals. The process is meant to be iterative--data are collected, analyzed, and discussed frequently so that adjustments can be made to the intervention or program. and then data are collected and analyzed once again. In addition, the scale of the initial effort often begins small and expands over time as the intervention is refined. Using this process, schools often start with a pilot intervention or activity and expand it as the fit to local conditions is better understood. Continuous school improvement cultivates a problem-solving orientation and close observation of the system that is producing the outcomes. This orientation is important to sustained improvement, especially when more than one change may be needed. Using data and evidence keeps the improvement process guided toward the desired outcomes. 29 .... Graphic Representation Example of the Alignment Between the Comprehensive Needs Assessment and the Continuous Improvement Cycle 8uNau of '"dlan 11:ducatlon: Oh11f1lon of P•rformanai eftd Auou"tabU.tt, All•n1n1 th• ketulu of the Comprehenaln Nffda A11eaament to t.h• Coftthtuoua ltnprvvement C'vd• I .....~ l o f t ~ St, ..~ t ~ l o n t f o r P'rb,W..a ...... ltr••ec¥ fv, ..,l0tltlf.d H .... •t II. RMOUt~ for ,.,tiortU1.d A. .. ...._..,,.... P,-od Need•l ===·=·==============~ -----------~I...... --....,.,.....,.,...._..,._. -~"-"•1 tt.stffna, C'Un'k4tb) A . f ~ ~ S t , .. ..., · - ~ .... H-.d.l n.,a~,-~,kktlt.,cf H.-1 •.i (•·•· laudco-t.. tt..N"'II- cwnn,16) \ .... A. l~---"'"e1.aff , - ~ ,... N-4•S •• flftOIHCfl fq, flfk,fltJffd ,.._. ., C• a bu.dpt. •UPTln.. aatrtc:\ol..) .... The results of the needs assessment process are identified and prioritized to begin the school's continuous school improvement cycle. .... School teams dig deeper to identify root causes of the prioritized needs, devise SMART goals based on the needs, and create action plans. .... The schools prioritized needs drive the selection of evidence-based strategies and interventions which also infonns the resources (e.g. budgets, staffing, curricula, and master schedule) necessary for implementation. .... School teams must then detem1ine how the evidence-based strategies and interventions will be monitored and evaluated throughout the continuous improvement cycle. 30 Graphic Representation Example of the Alignment Between the Comprehensive Needs Assessment and the Continuous Improvement Cycle Bureau of lndlan Educallon: Dlvl1lan of Performance end Aa:oun1ablllty Altanlna the Retulb af the CampteheftMve N••d1 Aa1n1ment ta the Cantlnuoua lmprov•m•nt Cycle Plan J A. 1-..~oMHI 5'no _ d..., ...... 0 °" PlC laemln& ttt. CotMlf not• ukJn, m•thadolop fDf a ll tt•ff. Matli6l•rin1 .ts,,.....r-t/lflltWW'fttlont ft;;J study - a t: 0 Monlto, ••11tl..r COf"ltent ~ c.J1• thrw1 1 ptKtkft. 0 Mor,IC.O, w"lty leuon p&.,na tor 00K ePped let ton •ctMU..~ end H\tnlfflenh.. 0 MonltOf' d 111.~ for OOIC aUcnt"d «th1U W" and ••wum•nts d urln1 lnnruaton•l rauncb/w•h..· rhfouah~ ' ° " ~ udy. - ··= ,..,.1Nt..fll•fs1,.t.1Ns/lf!'t.,.,...,._,.. , ., C Currkulom 11Uld•'I and w . .u., ~nan pea,.., wtll d earfy communlit.at• DOI all1n«t •cttvttle-1 and . ,.... , ~ 1 1 an ,.-.oon to cont~, priottty itar'ldan h •nd •nMtlat Pm,. 0 Slud•nt p,ofkl.nev 0tt Ce1;a.o PARCC UA •H•·um•nts wtll lnctffle by 1.S1'. •t~ In May 2019, the BIE identified the following schools as Comprehensive Support and Improvement {CSI) schools. Table 8: CSI Schools SY 2019-2020 COMPREHENSIVE SUPPORT AND IMPROVEMENT (CSI) SCHOOLS School Name Choctaw Central High School Mandaree Elementary School Havasupai Elementary School Naatsis'aan Community School Chilchinbeto Community School Little Eagle Grant School (Sitting Bull) Rough Rock Community School Porcupine Day School Loneman Dav School Wounded Knee District School Tiospaye Topa School Alamo Navajo Community School Type of School Tribally Controlled Tribally Controlled School Bureau Operated School Navaio-Tribally Controlled School Navajo-Tribally Controlled School Tribally-Controlled School Navajo-Tribally Controlled School Tribally Controlled School Tribally Controlled School Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School 31 Amount Funded $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 Wide Ruins Community School Rock Point Community School Mariano Lake Community School Pierre Indian Learning Center Indian Township School Hunters Point Boarding School Tate Topa Tribal School Hopi Junior/Senior High School Ch'ooshgai Community School Cottonwood Dav School Jeehdeez'a Elementary Schools Duckwater Shoshone Elementary School Noli School Santa Rosa Ranch School Coeur d'Alene Tribal School Dibe Yazhi Habitiin Oita', Inc. (Borrego Pass) Santa Rosa Day Boarding School Kin Dah Lichi' I Oita Ojo Encino Day School Rock Creek Grant School Pine Hill Schools Black Mesa Community School Lukachukai Community School BoJ.,'\.le Chillo Elementary School Greasewood Springs Community School, Inc. Many Fanns Community School Wl1ite Shield Elementary School Dilcon Community School Quileute Tribal School Kaibeto BoardinJ.! School Pine Springs Day School Wa He Lut Indian School Kayenta Community School Nazlini Community School Cove Day School Little Sin).!er Community School Second Mesa Day School St. Stephens Indian School Rockv Ridl!e Boardinl! School Lake Valley Navaio School Sherman Indian Hil!h School Navajo-Tribally Controlled School Navajo-Tribally Controlled School Navajo-Bureau Operated School Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School Navajo-Bureau Operated School Navajo-Tribally Controlled School Tribally Controlled School Tribally Controlled School Bureau Ooerated School Tribally Controlled School Navajo-Bureau Operated School $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 Bureau Ooerated School Navajo-Tribally Controlled School Navaio-Bureau Ooerated School Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School Navajo-Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 Navajo-Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School Navajo-Bureau Operated School Tribally Controlled School Navajo-Bureau Operated School Navaio-Triballv Controlled School Navajo-Bureau Operated School Navajo-Tribally Controlled School Tribally Controlled School Tribally Controlled School Navajo-Tribally Controlled School Navajo-Bureau Operated School Bureau Ooerated School $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 Also, in May 2019 the BIE identified high schools that had less than a 67 percent graduation rate for the past three years. 32 Table 8: High Schools <67% Graduation Rate SY 2019-2020 HIGH SCHOOLS WITH LOW GRADUATION RATES (GRAD RATE< 67% a11d GRAD RATES> %67) School Name Type of School Amount Funded Two Eagle River School Tribally Controlled School $75,000 Tribally Controlled School White Shield School $75,000 Pyramid Lake High School Tribally Controlled School $75,000 Shoshone-Bannock School Dist. No 512 Tribally Controlled School $75,000 Muckleshoot Tribal School Tribally Controlled School $75,000 Navajo-Tribally Controlled School Leuoo School, Inc. $75,000 Tribally Controlled School Takini School $75,000 Nay-Ah-Shing School Tribally Controlled School $75,000 Northern Cheyenne Tribal School Tribally Controlled School $75,000 Bug-0-Nay-Ge-Shig School Tribally Controlled School $75,000 Kickapoo Nation School Tribally Controlled School $75,000 Flandreau Indian Boarding School Bureau Operated School $75,000 Bureau Operated School Pine Ridl!e School $75,000 Dishchii'bikoh Community School Tribally Controlled School $75,000 Ahfachkee Day School Tribally Controlled School $75,000 Mandaree Day School Tribally Controlled School $75,000 Tohono O'odham High School Bureau Operated School $75,000 Tribally Controlled School Miccosukee Indian School $75,000 Lummi High School Tribally Controlled School $75,000 Tiospa Zina Tribal School Tribally Controlled School $75,000 Marty Indian School Tribally Controlled School $75,000 Northwest High School Navajo-Tribally Controlled School $75,000 Crow Creek Reservation High School* Tribally Controlled School -0Lower Brule Dav School Tribally Controlled School $75,000 Crazy Horse School Tribally Controlled School $75,000 Standing Rock Community School Tribally Controlled School $75,000 St. Stephens Indian School Tribally Controlled School $75,000 Little Wound School Tribally Controlled School $75,000 Cheyenne-Eagle Butte School Tribally Controlled School $75,000 Wingate High School Navaio-Bureau Ooerated School $75,000 Mescalero Apache School Tribally Controlled School $75,000 Tribally Controlled School Chief Leschi School $75,000 Yakama Nation Tribal School Tribally Controlled School $75,000 St. Francis Indian School* Tribally Controlled School -0• School receiving I 003(g) funds for SY 2019-2020. 33 CSI Timcline - SY 2019-2020 •Comprehensive Support & Improvement Schools Identified •CSI Application Release to Identified Schools •Webinar for Identified CSI Schools Reviewing Requirements for Schools in School Year 2019-2020 and to Review CSI School Application •Webinar for Identified CSI Schools Reviewing Requirements for Schools in School Year 2019-2020 and to Review CSI School Application •Webinar for Identified CSI Schools Reviewing Requirements for Schools in School Year 2019-2020 and to Review CSI School Application •CSI Applications due to BJE Division of Performance & Accountability •CSI Application to be Reviewed by BIE DPA-SEP Education Program Specialists •CSI Schools to Receive Allocations from 1003(a) Funds • CSJ Schools Training {1st of a series of technical assistance training) . 34 ITask A.3: Accountability & Reporting Subtask A.3.1: Annual Repo11 to the Secretary SY s 16-17 & 17-18, including proficiency, PartRate. Grad Rate, school improvement and other required elements. [ 1111 (h)(5)] Milestone A.3.1.1: Performance Metrics: (a) Complete Submission. (b) Provide evidence to ED. Completion Date: July 31, 2019 Status: SY 2017-18 Complete Justification: During Quarter 4, the BIE updated SY 2017-18 state assessment achievement and participation data and resubmitted the corrected data as verified by Enclosure A.3.1. l A SY 17-18 BIE EDEN System Submission Progress Reports. The resubmission was completed before the July 31, 2019 projected completion date. The original identified completion deadlines that were initially impacted by the government shutdown, seemed realistic at the time; however, state assessment data collection and consolidation required manual data entry and the work is tedious and time consuming. The BIE is unlike all other states. The states have single state assessments. with direct access to the assessment data which are already fonnatted consistently, and data fields can be extracted for rep011ing and analytical purposes. The BIE continues to be challenged with the following issues that affect collecting data across 23 states. • Cross-functional issues: The assessment data files are provided to the BIE in a variety of fonnats depending on which of the 23 states' assessments. The BIE collects demographic data in NASIS and these data are extracted from NASIS by BIE staff and must be manually entered into the master file to ensure that the demographic data for each student aligns with the assessment data. As stated, there is no 'standard' fonnat across states which results in common problems in data collection, listed below, that must be corrected in the master file prior to submitting. o hTelevant or duplicate data collected o Incomplete data with pe11inenl data fields omitted o Erroneous data collected or inadequate data due to inconsistency in headers o Insufficient time to make corrections effectively to meet projected timelines • Process issues: The BIE must manually extract and compile the necessary data fields into a master spreadsheet to ensure data fields are consistent across all 23 states. o Due to the large spreadsheet file size, staff have had issues with files "hanging up" and processing is slow and sometimes elicits timing out. Options are being addressed by reviewing software and system solutions. o Multiple users using data files lends to system errors 35 o • Verification by appropriate program staff has been an issue that is currently being addressed through creating process documents. o Lack of data entry staff. Currently, one Research Analyst is responsible for organizing assessment data with the help of NASIS Specialists as necessary. All staff that comprise the EDFacts team, have multiple assignments within AAO unit. NASIS Specialists key role is provision of continuous virtual technical assistance and training to their assigned schools. Each time they are utilized to enter and format data, means time away from provision of TA to schools. Reliability and validity issues: The BIE has been challenged with reliable and valid data and data comparisons across all grade levels. The BIE recognizes that the complete data sets may not be valid nor reliable, particularly with High School data sets. The BIE looks forward to a single assessment system following the finalization of the negotiated rule; however, the BIE funded schools must continue to follow 23 accountability systems until such time. The BIA continues moving forward collecting and consolidating data sets with consideration of the following: o Various high school grades levels are assessed across the 23 states depending on the states' accountability systems. This affects consolidation and comparisons of proficiency and participation data. o The flexibility in many aspects of state assessments, although advantageous for individual states with single assessments, compounds the complexity of data collection across BIE funded schools and impacts the time it takes to consolidate the data (see Enclosure A.3.1. IB - BIE Summative Assessments for SYs 2017-18 & 2018-19.) o The status of the individual state's implementation of accountability systems and each change or phase must be closely tracked by the BIE to anticipate effects on data consolidation and updates in data sharing agreements between states and the BIE. o The BIE must utilized extremely large data files (master spreadsheets) for submission of data which has Jed to unanticipated data processing and technology issues. The BIE is working with BIA IT on recommendations for specifications that will resolve such issues. The BIE is requesting technical assistance and recommendations from ED to address the inconsistency and data comparison across 23 states' ELA, Mathematics, and Science assessments, pm1icularly for BIE funded high schools' data. Milestone A.3.1.2: Submit SY 16-17 Annual Repo1t to the Secretary Performance Metrics: (a) Complete Submission. (b) Provide evidence to ED. Completion Date: August 30, 2019 Status: In Progress Justification: As mentioned in a prior SY2018-19 Quarterly CAP, the BIE determined that in SY 16-17 only partial sets of achievement and participation data were submitted to ED Facts (see 36 Enclosure A.3. l .2A - SY 16-17 BIE EDEN System Submission Progress Reports). During June of Quarter 4, the BIE also focused on completing these data sets and preparing data for resubmission applying lessons learned from the SY17-18 data submissions process. The ED Facts Team reconvened in June with a goal to meet the projected to be July 31, 2019 completion date in mind. The team faced additional and unforeseen data issues particularly with science data collection and formatting which will require extension of the completion date for resubmission of the SY 2016-17 state assessment achievement and participation data resubmissions. The new projected date is August 30, 2019. BIE anticipates that this completion data will be met. Subtask A.3.2: Publishing State and LEA report cards SYs 16-17 & SY 17-18 [l l I l(h)(l-2)] Milestone A.3.2.1: Performance Metrics: (a) Prepare data to populate SY 17-18 State report cards. (b) Prepare data to populate SY 16-17 State report card. (c) Publish at the BIE Website. Completion Date: September 30, 2019 (SY 17-18) September 30, 2019 (SY 16-17) Status: In Progress Justification: Populating the State report cards relies on submission of all state assessment achievement and participation data. As discussed in the Milestones A.3.1.1 and A.3.1.2, progress continues toward organization and resubmission of all assessment data. Lack of necessary staffing was also discussed as an issue due to the fact that staff are working on multiple years of data which were in various stages of submission/resubmission. Staff also continue to work around day-to-day schedules to ensure schools receive necessary training and TA on the student information system use, while working data formatting and additional data extraction requests into their regular schedules. Despite the added multiple duties, population of the report cards is still anticipated as September 30, 2019. Challenges that have affected the BIE during Quarter 4 included SY 2016-17 Science data files. The BIE was able to collect additional science assessment data files; but science data for Arizona schools were provided in a PDF format that could not be converted efficiently. NASIS Specialists were assigned data sets to manually enter into the spreadsheet. In addition, errors with SY 2016-17 participation data sets has hindered resubmission. During the month of June, NASIS Specialists were extremely busy assisting schools with technical data health checks and data cleanup relative to the Indian Student Equalization Program (!SEP) counts. The BIE is concurrently in process of SY 2018-19 assessment data collection. The table below remains unchanged; however, an update will be provided in the SY 2019-20 Quarter l CAP at which time the actual numbers will replace the (*) that indicates that the data is not yet available. 37 status o fD ata to popu ate AnnuaIReport Cards School Year SY 2018-19 SY 2017-18 SY 2016-17 BlE-wide Annual Report Cards 0 0 0 LEA/School Annual Report Cards Student Achievement Cohort Enrollment E/LA Math Science Grad Rate 173 173 173 * 169 170 * * 169 168 158 X * 60 60 Attendance * 173 173 BIE's Assessment and Accountability Office (AAO) under the Office of the Chief Academic Officer (CAO) continues to work with collaboratively with DPA ESSA and IDEA program staff to improve relevant reporting data. The work on Goal 6 of the BIE's strategic plan, AAO staff initiated discussion around a reporting calendar that may assist in clarifying roles and responsibilities surrounding accountability, assessments, data stewardship, training. technical assistance, etc. During Quarter 4, the AAO and DPA IDEA program staff also engaged in collaborative development of the BIE State Assessment Protocol facilitated by the IDEA Data Center (IDC). AAO anticipates that this is the beginning of ongoing collaborative efforts within the BIE to establish written data collection process documents (protocols). The draft document is provided as enclosure A.3.2.1 B - BIE State Assessment Protocol DRAFT. Milestone A.3.2.2: Performance Metric.,: (a) Prepare data and populate SY 17-18 LEA report cards. (b) Prepare data and populate SY 16-17 LEA report card. (c) Publish at the BIE Website Completion Date: September 30, 2019 (SY 17-18) September 30, 2019 (SY 16-17) Status: In Progress Justification: CAO-AAO staff continues to collaborate to improve accuracy of data that will eventually be used to populate report cards for prior years, while concurrently preparing SY 2018-19 data for timely submissions and improving data quality. As referenced under Milestones A.3.2.1, AAO staff will continue to collaborate with DPA ESSA and IDEA program staff to develop process documents in SY 2019-20. Continued collaboration between CAO, AAO, DPA program staff, and greater collaboration with ISEP program staff is necessary to identify and agree upon BIE's accountability indicators moving into SYs 2019-20 and 2020-21. BIE has requested technical assistance to design report cards that align with the accountability indicators that will result from finalization of the negotiated rule. ED is reaching out to technical assistance providers to assist the BIE in this effort. As stated in Quarter 3, AAO will populate the report card templates with the appropriate data sets after the appropriate data are submitted or resubmitted. 38 The NASIS Contract Team has completed the competitive process to identify a student information system vendor. During Quarter 4, review, selection, negotiation, and finalizing the contract was high priority for the AAO office. This effort will have a significant effect on the findings in the CAP. AAO ensured that the contract scope of work included important and significant updates intended to provide technological solutions to much of work currently being completed manually. AAO staff looks forward to efficient and effective automated solutions that will improve state assessment data collection, EDF acts reporting files, report card formatting and population with appropriate data, and creation of ad hoc reports geared toward state level use. AAO will work closely with the vendor to redesign training that will focus on data for school improvement by increasing BIE staff technology skill sets in using the system, increasing BIE's capacity to support schools in use of data, and a focus on increasing student outcomes by effective use of data. Progress updates will be provided in upcoming CAP reports. ! Task C.l: Fiscal Subtask C.1.4: The BIE will refresh the list of High-Risk LEAs/Schools for Monitoring Note: In Quaiters 1 and 2, this subtask was misstated to read: Low Performing Schools using BIE's current methodology or a modified methodology [ 1111 (c)(4)(D)]. That error is corrected above. Milestone C.l.4.1: Develop a BIE Manual for Monit01ing Schools to Ensure Compliance for Use of Federal Funds Performance Metrics: (a) Develop list of High-Risk LEAs/Schools for Monitoring (b) Develop and implement procedures for on-site monito1ing of High-Risk LEAslSchools Completion Date: December 31, 2018 Status: Completed May 2018. Justification: The BIE has developed a B/E High Risk Fiscal Oversight Handbook (30 1AM 19H), which was officially adopted as BIE policy in May 2018. The handbook covers the following areas: • • • • • Purpose of Monitoring High-Risk Identification of Schools to be Monitored, including methodology Roles and Responsibilities of Monitoring both for Team Leads and Team Members On-site Fiscal Review Processes Post Monitoring Procedures and Processes, including final written monitoring report and technical assistance plans for schools monitored 39 The handbook can be accessed at: https://www.bia.gov/sites/bia.gov/files/assets/public/raca/handbook/pdf/30 1AM 19H BIE%20High%20Risk%200versight%20Handbook Signed lssueDate 508.pdf In addition, a list of schools to be monitored in school year 2018-2019 has been developed and previously shared. The BIE continues to implement an annual fiscal monitoring plan. Each year the BIE reviews the processes for identifying and monitoring high-risk discretionary grantees. As part of the process, BIE conducts an annual high-risk detennination process, encompassing all BIE-funded schools (item 1). The monitoring cycle includes all BIE-funded schools. Schools ranked high-risk but not previously visited are included in the next year's monitoring schedule, so that the number of schools receiving onsite visits increases each year (item 2). The majority of the grants awarded by the BIE fall into two categories: fonnula grants, which are awarded based on statutorily defined formulas; and discretionary grants, which are competitively awarded. After award, the BIE is responsible for monitoring and oversight. The BIE tailors oversight activities based on the risk associated with grantees. Historically, the BlE has designated grantees with known issues such as "high-risk" or ..at-1isk." According to Title 34 Code of Federal Regulations {C.F.R.) § 80.12, the BIE may consider a grant to a local educational agency ( LEA) or school to be "high-risk'' if a grantee or sub grantee meets one or more of the following conditions: 1. Has a history of unsatisfactory perfonnance, 2. Is not financially stable, 3. Has a management system which does not meet the management standards [required by U.S. Depaitment of Education regulations]. 4. Has not conformed to tem1s and conditions of previous awards, or 5. ls otherwise not responsible. The regulation further states that if the BIE detennines that an award will be made, special conditions and/or restiictions shall correspond to the high-risk condition and shall be included in the award to LEAs/schools. The BIE's High Risk Fiscal Oversight Manual was issued as policy in May 2018, to work with all BIE Divisions that take part in the annual Programmatic and Fiscal On-Site Monitoring of high-risk LEAs/schools. The BIE reviews components of each LENschool from School Operations (Internal Controls and Budgeting); ESSA Title I, Part A and Title II, Part A and any discretionary grants the school receives from federal education monies; ISEP which is the base program monies that goes to the LENschool from the Indian School Equalization Program and IDEA to ensure that each program at the BIE and its LEAs/schools has effective procedures in place to assess and mitigate risk among its grantees. The BIE school system is comprised of two types of schools: Bureau Operated Schools and Tribally Controlled Schools. Funds expended by Bureau schools are included in the departmental federal financial system, so ongoing monitoring of expenditures is possible, although the use of 40 particular funds for allowable purposes required closer examination. The financial systems of Tribal schools are outside the federal financial system. Tribal schools operate their own financial systems or are part of the larger tribal financial system. Direct oversight of Tribal school expenditures is not possible for schools operating outside the federal financial system and oversight is accomplished only after the fact through onsite monitoring and the audit process. In regard to enforcement actions, the Department monitors A-133 audits of all Tribally Controlled Schools and administers enforcement actions against schools with audit findings (item 3) The current BIE High Risk Fiscal Oversight Manual allows the BIE monitoring process to develop a technical assistance plan for LEAs/schools being monitored that will assist the four BIE monitoring divisions to provide year-long technical assistance designed to correct monitoring issues discovered at the on-site monitoring This BIE Manual outlines the process and procedures for providing monitored grantees grant administration processes with greater focus by the BIE on determining LEA/school processes that focus on assessing risks, providing internal control skills to the LEA/school and sharing additional technical assistance information to the LEA/school while at the on-site monitoring visit. 41 ITask D: Technical Assistance Subtask D.1: The BIE will report U.S. Department of Education-sponsored technical assistance provided to the Bureau of Indian Education by Education-funded providers. Note: Section C details IDEA-related technical assistance. A. Accountability Rulcmaking Planning Group Two staff from the Center on Standards and Assessment Implementation (CSA!) join weekly meetings with members of a Department of the Interior Accountability Rulemaking Committee (ARC) planning group on negotiated rulemaking activities. Deb Sigman Deputy Director, Standards, Assessment. and Accountability Services Director. Center on Standards and Assessment Implementation WestEd Bryan Hemberg Program Manager, Center on Standards and Assessment Implementation WestEd The ARC planning group met via teleconference on the following dates: • • • April 2, 9, 16, 23, 30 May 14, 28, June 18, 25 B. Strategic Performance Management Plan The BIE is involved in a critical organizational activity, which is the development of a strategic performance management (SPM) plan. The BIE SPM plan will support BIE's state system of support and intervention for school improvement and turnaround. The plan will define goals, directions, and operations of the state agency as well as those of schools served by the system of support. Technical assistance is being provided by: Allison Layland, Ph.D. Chief Education Strategist Academic Development Institute (ADI) Dr. Layland facilitated the following SPM sessions dming the quarter: Strategic Performance Management (SPM) April 23-25, 2019 Albuquerque, NM Strategic Performance Management (SPM) 42 June [1-13, 2019 Albuquerque,- NM SECTION C - ITask C.4.0: IDEA, Part B, SPECIFIC CONDITIONS Conduct School Monitoring. Subtask C.4.2 (Fiscal Monitoring): Implement fiscal monitoring system to ensure that BIEoperated schools and tribally-operated schools are ensuring the appropriate use of IDEA Part B funds and ESEA funds Milestone C.4.2.1: Implement adequate fiscal monitoring procedures. Pe,formance Metric: (a) Report on the implementation of fiscal monitoring procedures. including communications with schools, both before and after monitoring visits, technical assistance provided to the schools, and any barriers to effective fiscal monitoring of and support to the schools. (b) Provide updated fiscal monitoring procedures, if changes are made. Progress: During the fourth quarter, BIE offices and divisions are following the approved BIE High Risk Fiscal Oversight Policy to conduct programmatic and fiscal review onsite visits. Reviews proceeded as scheduled, with the exception of the monitoring visit for Tiospa Zina Tribal School. Tiospa Zina Tribal School's onsite program and fiscal review scheduled for April 2019 was hindered due to severe winter weather. The monitoring team was only onsite at the school for one day, and the remaining monitoring activities at the school had to be rescheduled. Currently, the visit is set for the upcoming 2019-20 school year monito1ing schedule. Milestone C.4.2.2: Issue fiscal monitoring repo11s. Performance Metric: Provide copies of fiscal monitoring reports issued to schools. Progress: Dming the fourth quarter, there were eight onsite visits to Pine Ridge School (SD), Tiospa Zina Tribal School (SD), Hopi Junior Senior High School (AZ). Crow Creek Sioux Tribal Elementary School (SD), Wide Ruins Community School (AZ), Turtle Mountain Elementary School (ND), Tohono O'odham High School (AZ), and Kickapoo Nation School (KS). DPA Special Education will be issuing Written Notification of Findings letters to schools during 2019-2020 Quarter I for all on-site monitoring programmatic/fiscal on-site visits conducted during SY 2018-2019. Table l Listing ofSchools Visited bv Quarters School & Quarter Visited Pine Ridge School Tiospa Zina Tribal School -*I day Hopi Junior Senior High School Crow Creek Sioux Tribal Elementary School 04 Q4 04 04 School Type BOS TCS TCS TCS ADD BOS TCS Navaio TCS Date of Onsite Visit April 2-4.2019 April 9, 2019 April 16-18, 2019 April 23-25, 2019 Written Notification of Findines Issued In progress- QI 2019-20 Rescheduled for Fnll 2019 In progress- Q 1 2019-20 In progress- Ql 2019-20 44 ---~------ Wide Ruins Communitv School Turtle Mountain Elementary School Tohono O'odham High School Kickapoo Nation School 04 Q4 TCS BOS Navaio BOS April 23-25, 2019 May 7-9, 2019 In progress- QI 2019-20 In progress- Q l 2019-20 04 04 BOS TCS BOS TCS May 7-9.2019 Mav 14-16, 2019 In orogress- QI 2019-20 In oroeress- QI 2019-20 Milestone C.4.2.3: Ensure timely correction of findings of noncompliance identified in fiscal monitoring reports. Performance Metric: Report the number of findings of noncompliance related to fiscal requirements that are timely corrected, and the number of findings of noncompliance related to fiscal requirements that are corrected more than one year after the State's identification of noncompliance; and provide evidence of cotTection. Progress: Outing the fourth quarter the schools were provided the findings and corrective actions through a final exit webinar. DPA Special Education will be issuing Writ1en Notification of Findings letters to schools during 2019-2020 Quarter l for all on-site monitoring programmatic/fiscal on-site visits conducted during SY 2018-2019. Milestone C.4.2.4: Ensure verification of correction of noncompliance related to fiscal requirements for which no written findings are issued. Performance Metric: Report instances of noncompliance related to fiscal requirements, identified through self-assessments and document reviews, for which the BIE does not issue a written finding; and evidence that the BIE has verified the school corrected the noncompliance. Progress: During the fourth quarter schools were provided with a technical assistance plan that detailed how findings could be corrected within a year. Task C.5.0: Conduct Dispute Resolution Processes in Accordance With IDEA Requirements and Timelines. Subtask C.5.t (State Complaints): Implement procedures to ensure compliance with State complaint requirements contained in 34 CFR §300.152(a) and (b). Milestone C.5.1.l: Ensure that State complaints are resolved within the 60-day timeline or an appropriately extended timeline due to the exceptional circumstances with respect to the particular complaint or because the parent (or individual or organization) and the public agency agree to extend the time to engage in mediation or other alternative means of dispute resolution, if available in the State, consistent with 34 CFR §300.152(a) and (b). Performance Metric: Provide a listing of State complaints, including the date the complaint was filed and the date the written decision was issued. 45 Progress: During the fourth quarter, two investigation reports were finalized: • Hunters Point Boarding School from the second quarter was issued on May 22, 2019 • Twin Buttes Day School from the third qum1er was issued on May 20, 2019 One state complaint was filed in the fourth qum1er regarding Ojibwa Indian School. The outcome of this compliant is still pending. Table 2 Listing ofState Complaints by Quarters School & Quarter of Complaint San Felipe Pueblo Elementary School Hunters Point Boarding School Hunters Point Boarding School Twin Buttes Day School Oiibwa Indian School School Type ADD Date Complaint Filed Date an Extension was Issued (if Date Written Decision Issued Number of Days it Took to Issue the Decision 12/31 /2018 140 QI BOS BOS 08113/20) 8 aoolicable) N.A Qi TCS Navajo 08 30,2018 NtA ll ,29i2018 91 Q2 TCS Navajo 12:06 12018 NA 05 2:!12019 167 03 TCS TCS 03 1512019 NI A 05 20•2019 66 04 BIE BIE 06/0312019 N, A Pendina Task C.6.0: Collect and Repo11 Data to the Secretary and the Public in Accordance With the Re uirements of Sections 612,616, and 618 of the IDEA. Subtask C.6.1 (Data Procedures and Processes): Develop and implement procedures to collect and repo11 valid and reliable data required under sections 616 and 618 of the IDEA in a timely fashion. Milestone C.6.1.l: Follow guidance of the Partner Support Center (PSC) and seek its assistance as needed. Performance Metric: Submit evidence of any contacts with PSC. Progress: During the fourth quarter, there were no protocols developed for IDEA data for sections 616 and 618. BIE did contact PSC for assistance with errors in formatting in the submission of ED Facts reporting for Child Count/Educational Environment and then again for the reporting of Coordinated Early Intervening Service (CEIS). Milestone C.6.1.2: Develop protocols, procedures and governance to ensure the collection and reporting of valid and reliable data required under sections 616 and 618 of the IDEA in a timely fashion. 46 Pe1forma11ce Metric: Provide protocols, procedures and governance for the collection and reporting of data required under sections 616 and 618 of the IDEA. Progress: During the fourth quarter, work is continuing on developing draft protocols for SPP/APR Indicators 1 (graduate), 2 (dropout), and 5 (least restrictive environment). Protocols for the remaining SPP/APR Indicators will also be developed in collaboration with IDEA Data Center. During Quarter 1 of school year 2019-2020 work on developing draft protocol for the collection, analysis and reporting of Indicator 3, State Assessment data is planned. Subtask C.6.2 (Section 616 Data): Develop and implement procedures to ensure that all section 616 data required in the SPP/APR are valid and reliable and reported in a timely fashion. Milestone C.6.2.1: Report valid and reliable data for Indicators 38 and 3C for FFY 2016 in the FFY 2017 SPP/APR, due on February l, 2019. Progress: During the fourth quarter, updated Indicator 3B (reading and math assessment) data were repo1ted in the FFY 2017 APR during clarification period. Although the targets were not met, there was no slippage. For Indicator 3C (reading and math assessment proficiency) were reported in the FFY 2017 APR during clarification period. Milestone C.6.2.2: Report valid and reliable data for all Indicators for FFY 2017 in the FFY 2017 SPP/APR. due on February l. 2019. Performance Metric: Provide the required data for all SPP/ APR indicators in the FFY 2017 SPP/APR. Progress: During the fourth quarter, updated data was reported for Indicator 38, 3C, 11 and 13 in GRADS360 during the FFY 2017 APR Clarification. Subtask C.6.3 (Section 618 Data): Develop and implement procedures to ensure that all section 618 data required are valid and reliable, and reported in a timely fashion. Milestone C.6.3.1: Report valid and reliable data for the IDEA Section 618 data collections to EDFacts Submission System (ESS} for SY 2017-18 Personnel, SY 2017-18 Exiting, and SY 2017-18 Discipline; and to ED Facts Metadata and Process System (EMAPS) for SY 2017-18 Dispute Resolution. Performanc:e Metric: (a) Resubmit data resolving data quality issues identified by the ESS reports and OSEP Prefill reports, as well as the HTML report and edit check warnings in EMAPS, by November I, 2018. (b) Submit final data, addressing all data quality issues identified by OSEP, if any, by May 30, 2019 in order to ensure inclusion in publicly reported data. 47 Progress: As previously reported in the third quarter, data for SSY 2017-18 Personnel, SY 2017-18 Exiting, and SY 2017-18 Discipline was reported to the EDFacts Submission System. The SY 2017-18 Dispute Resolution data was reported to EDF acts Metadata and Process System. Milestone C.6.3.2: Report valid and reliable data to ESS for the IDEA Section 618 data collection for SY 2018-19 Child Count and SY 20 l 8-19 Educational Environment. Performance Metric: a) Resubmit data resolving data quality issues identified by the ESS reports and OSEP Prefill reports by April 4, 2019. b) Submit final data, addressing all data quality issues identified by OSEP, if any, by the deadline designated by OSEP, in order to ensure inclusion in publicly reported data. Progress: During the fourth quarter, the SY 2018-19 Child Count and SY 2018-19 Educational Environment were submitted in EDEN on April 3. 2019. Milestone C.6.3.3: Report valid and reliable data to EMAPS for the IDEA Section 618 data collection for FFY 2017/SY 2017-18 LEA MOE Reduction and CEIS. Performance Metric: a) Resubmit data resolving data quality issues identified by the EMAPs reports by May 2, 2019. b) Submit the final data. addressing all data quality issues identified by OSEP, if any, by the deadline designated by OSEP, in order to ensure inclusion in publicly reported data. Progress: During the fourth quarter, the FFY 2017/SY 2017-18 CEIS data was submitted in EMAPS on April 26, 2019 before the May I, 2019 deadline. The BIE does not report data for MOE Reduction. Subtask C.6.4 (Public Reporting of Assessment Data): Develop and implement procedures to ensure public reporting of assessment data in accordance with IDEA requirements in a timely fashion. Milestone C.6.4.1: Develop and implement procedures to ensure that the BIE will publicly report on the assessment of children with disabilities in the same manner and frequency as it reports on the assessment of children without disabilities, as required under 34 CFR §300. l 60(f). Perfornumce Metric: Within 90 days of receipt of the BIE's detennination letter, submit a Web link demonstrating that the BIE has reported, for FFYs 2015 and 2016, to the public on the participation and performance of children with disabilities in accordance with the requirements of 34 CFR §300.160(t). In addition, submit a Web link in the FFY 2017 SPP/APR that demonstrates compliance with 34 CFR §300.160(f) for FFY 2017. 48 Progress: During the fourth quarter BIE, with IDC support, continues to prepare the FFY 2015 and FFY 2016 data in preparation to publicly report on the participation and perfonnance of children with disabilities. The BIE anticipates that the public report will be completed during the first quarter of SY 2019-20. A web link was previously provided in GRADS360 for the FFY 2017 data as to where the data will be housed. Task C.7.0: Demonstrate Compliance with Secondary Transition Requirements. Subtask C.7.1 (Submission of Corrective Action Plan): Develop and implement a corrective action plan to demonstrate compliance with secondary transition requirements and improve the accuracy of the secondary transition data. Milestone C.7.1.1: Develop and implement a corrective action plan that addresses the actions the BIE will take to demonstrate compliance with the secondary transition requirements in IDEA section 614(d)(l)(A)(i)(Vlll) and 34 CFR §§300.320(b) and 300.321(b) and improve the accuracy of the secondary transition data. Performance Metric: Submit a report on the status of implementation of the actions the BIE is taking to demonstrate compliance with secondary transition requirements and improve the accuracy of the secondary transition data. Progress: In the previous quarter, BIE had reported in the FFY 2017 Annual Performance Report a compliance rate of 99°,o for Indicator 13 (secondary transition). However, after consulting with OSEP duting the BIE Differentiated Monitoring and Support (DMS) onsite visit in March 2019, BIE was instructed by OSEP to rep011 a compliance rate of 8.39%, which represented BIE's position prior to cotTecting the incidents of noncompliance. After the Indicator 13 was amended, Indicator 13 compliance rate of 8.39° o represented a decrease from the FFY 2016 compliance rate of 14.98%. Thus, this progress report for this milestone aligns with what was reported in the FFY 2017 APR during clarification period. On a positive note, the findings of noncompliance have already been verified as corrected so this is what will be reported in the FFY 2018 APR. This was as a result of one special education staff member who was designated to coach and mentor high schools on quality secondary transition lEPs and supported the BIE-funded high schools with correction of non-compliance. The designated staff member communicated with high schools to discuss findings and provided guidance on how to improve individual components of secondary transition (e.g., student invitation, agency invitation, annual IEP goals). It is important to note, that although overall compliance appeared to be down, there was marked improvement in individual components over last year's data collection. Six of the eight components improved over last year's perfonnance (i.e., measurable post-school goals, goals updated annually, transition assessments, course of study, student invitation, and agency representation). 49 Subtask C.7.2 (Use of Directed Administrative Funds): Develop and implement a spending plan demonstrating that the directed funds will be used to address the noncompliance with secondary transition requirements and to improve the accuracy of the secondary transition data. Milestone C.7.2.1: Submit a report on and analysis of FFY 2017 secondary transition compliance data, disaggregated by compliance item and BIE-funded school. Performance Metric: No later than October l, 2018, provide the following: (a) A report of the BIE's secondary transition compliance data for the pe1iod July 1. 2017 through June 30, 2018, disaggregated by i. Compliance item (i.e., each particular component of the secondary transition requirements associated with SPP/ APR Indicator 13-for example, whether there is evidence that the student was invited to the IEP Team meeting where transition services are to be discussed); and 11. BIE-funded school. (b) The BlE's analysis of the disaggregated data, including suspected or known reasons for any noncompliance. Progress: During the fourth quarter, DPA special education staff presented on IDEA School Required Reporting (which included Preparing high schools for Secondary Transition IEP file reviews and Preparing schools for post-school outcomes data collection) at three locations: Sherman Indian High School (CA), Wingate High School (NM), and Haskell Indian Nations University (KS). Three additional trainings on the same topic will be conducted during the first quarter of SY 2019-20. These trainings are part of the BIE Summer Regional Trainings on various topics. The SY 2018-19 secondary transition IEP file reviews are taking place during this quarter. The initial findings of noncompliance identified will be reported in the FFY 2018 Annual Performance Rep011. Schools will be contacted to correct any findings of noncompliance identified during the first quarter of SY 2019-20. Milestone C.7.2.2: Develop and implement a spending plan to expend directed funds by July I, 2019 that demonstrates how the directed funds will be used to pay for strategies and activities that address the suspected or known reasons for the noncompliance with the secondary transition requirements in IDEA section 614( d)( 1)(A)(i)(VIII) and 34 CFR §§300.320(b) and 300.321 (b) and that are reasonably designed to correct that noncompliance and improve the accuracy of the data. The BIE's proposed spending plan must include: (1) the activities that will be carried out with those fonds; (2) the costs associated with each of the activities: (3) a projected timeline for using the funds to pay the costs associated with each of the activities that demonstrates that the funds will be used by July I, 2019; and (4) an explanation of how the activities will result in improved compliance with secondary transition requirements and improved accuracy of the data. The BIE must also desciibe the documentation it will provide to demonstrate funds were used in accordance with the FFY 2018 spending plan. In addition, to ensure that the BIE can increase compliance with the secondary transition requirements and improve data accuracy within one year, the BIE must expedite the use of the directed FFY 2018 IDEA Part B administrative funds 50 and target the use of those funds for activities that are based on careful review of the BIE's FFY 2017 secondary transition data. Performance Metric: (a) By October I, 2018, submit the proposed spending plan for OSEP approval. (b) With each quarterly report for the 2018-2019 CAP, provide evidence that the BIE has directed the use of funds, as appropriate, during the reporting period. (c) With each quarterly report for the 2018-2019 CAP, provide the amount of the $300,000 of the BIE's IDEA Part B administrative funds that were used during the reporting period to carry out the activities described in the BIE's spending plan to address the suspected or known reasons for the noncompliance with secondary transition requirements and to improve the accuracy of the data. ( d) With each quarterly report for the 2018-2019 CAP, provide documentation that the BIE used those FFY 2018 IDEA Part B administrative funds during the reporting period in a manner consistent with the BIE's spending plan. Progress: As previously reported in the first, second, and third quarters, a spending plan was developed for the amount of $300,000. The plan outlined allocation of directed funds to support strategies and activities reasonably designed to correct noncompliance with secondary transition requirements and improve the accuracy of the data. During the fomth quarter, no fonds have been expended to carry out the activities that were described in the BIE spending plan to address the suspected or known reasons for the noncompliance with secondary transition requirements and to improve the accuracy of the data. Therefore, no documentation that the funds were used consistent with the spending plan are available. During the fourth quarter, discussion and planning will continue to take place to offer a series of professional development activities ( l-2 days of training) on Quality Secondary Transition IEPs for BIE-Funded high schools through four regional BIE Special Education Regional Capacity Building Institutes on Secondary Transition. The professional development activities will help strengthen partnerships between DP A Special Education, Education Resource Centers, and the Associate Deputy Director (ADD) Regional Offices for positive student outcomes- a shared responsibility. The purpose of the capacity building trainings is to increase knowledge and selfefficacy of ERC staff and relevant high school level staff. DPA will continue to collaborate with NTACT to implement during the fall of 2019. ITask C.8.0: Improve Exiting Data In Accordance With IDEA Requirements. Subtask C.8.1 (Improving Exiting Data): Improve existing data by utilizing available technical assistance resources. Milestone C.8.1.1: The BIE must report on: (1) the sources from which it received technical assistance related to those exiting data elements for which the BIE received a score of zero on the 20 I 8 Part B Results Matrix; and (2) the actions it took as a result of that technical assistance. 51 Performance Metric: With the FFY 2017 SPP/APR, due on February 1, 2019, provide agendas, schedules, and/or other documentation that demonstrates evidence of receipt of technical assistance related to those exiting data elements for which the BIE received a score of zero on the 2018 Part B Results Matrix and subsequent actions the BIE took as a result of that technical assistance. Progress: During the fourth quarter, the BIE continues to collaborate with IDC for intensive technical assistance to improve the exiting data elements (percentage of children with disabilities who dropped out over previous three years and percentage of children with disabilities who graduated with a regular high school diplomas over previous three years). Data was reported in the FFY 2017 Annual Performance Report. 52 NOTE: Below is the CAP template for School Year (SY) 2019-2020, which is a requirement of the Specific Conditions contained in the July 1, 2019 Grant Award Letter. This template will be used to report progress in meeting the Specific Conditions. SECTION C - !Task C.4.0: IDEA, Part B, SPECIFIC CONDITIONS Conduct School Monitoring. Subtask C.4.2 (Fiscal Monitoring): Implement fiscal monitoring system to ensure that BIEoperated schools and tribally-operated schools are ensuring the appropriate use of IDEA Part B funds. Milestone C.4.2.1: Implement adequate fiscal monitoring procedures. Performance Metric: (c) Report on the implementation of fiscal monitoring procedures, including communications with schools, both before and after monitoring visits. technical assistance provided to the schools, and any barriers to effective fiscal monitoring of and support to the schools. (d) Provide updated fiscal monitoring procedures, if changes are made. Progress: Milestone C.4.2.2: Issue fiscal monitoring reports. Performance Metric: Provide copies of fiscal monitoring reports issued to schools. Progress: Table I Listinf! of Schools Visited bv Quarters School & Quarter Visited School Type ADD Date of Onsite Visit Date Monitoring Report Issued Milestone C.4.2.3: Ensure timely correction of findings of noncompliance identified in fiscal monitoring reports. 53 Performance Metric: Report the number of findings of noncompliance related to fiscal requirements that are timely corrected, and the number of findings of noncompliance related to fiscal requirements that are corrected more than one year after the State's identification of noncompliance; and provide evidence of correction. Progress: Milestone C.4.2.4: Ensure verification of cotTection of noncompliance related to fiscal requirements for which no written findings are issued. Performance Metric: Report instances of noncompliance related to fiscal requirements, identified through self-assessments and document reviews, for which the BIE does not issue a written finding; and evidence that the BlE has verified the school corrected the noncompliance. Progress: Task C.5.0: Conduct Dispute Resolution Processes in Accordance With IDEA Requirements and Timelines. Subtask C.5.1 (State Complaints): Implement procedures to ensure compliance with State complaint requirements contained in 34 CFR §300. I 52(a) and (b). Milestone C.5.1.l: Ensure that State complaints are resolved within the 60-day timeline or an appropriately extended timeline due to the exceptional circumstances with respect to the paiticular complaint or because the parent (or individual or organization) and the public agency agree to extend the time to engage in mediation or other alternative means of dispute resolution, if available in the State, consistent with 34 CFR §300. I 52(a) and (b ). Performance Metric: Provide a listing of State complaints, including the date the complaint was filed and the date the written decision was issued. Progress: Table 2 L·1st111~ . o(State Comp Iams · t bV Ouarters School & Quarter of Complaint School Type ADD Date Complaint Filed 01 02 03 04 54 Date an Extension was Issued (if aoolicable) Date Written Decision Issued Number of Days it Took to Issue the Decision Task C.6.0: Collect and Report Data to the Secretary and the Public in Accordance With the Re uirements of Sections 612,616, and 618 of the IDEA. Subtask C.6.1 (Data Procedures and Processes): Develop and implement procedures to collect and report valid and reliable data required under sections 616 and 618 of the IDEA in a timely fashion. Milestone C.6.1.1: Follow guidance of the Partner Support Center (PSC) and seek its assistance as needed. Performance Jvfetric: Submit evidence of any contacts with PSC. Progress: Milestone C.6.1.2: Complete development and implementation of protocols, procedures and governance to ensure the collection and reporting of valid and reliable data required under sections 616 and 618 of the IDEA in a timely fashion. Pe1forma11ce Metric: Provide completed protocols, procedures and govemance for the collection and reporting of data required under sections 616 and 618 of the IDEA, and report on implementation of the protocols, procedures, and governance, as well as the Data Governance Board. Progress: Subtask C.6.2 (Section 616 Data): Develop and implement procedures to ensure that all section 616 data required in the SPP/ APR are valid and reliable and reported in a timely fashion. Milestone C.6.2.1: Report valid and reliable data for Indicators 38 and 3C for FFY 2016 in the FFY 2018 SPP/APR, due on February 3, 2010. Progress: Milestone C.6.2.2: Repm1 valid and reliable data for all Indicators for FFY 2018 in the FFY 2018 SPP/APR, due on February 3, 2020. Pe,iornumce Melric: Provide the required data for all SPP/ APR indicators in the FFY 2018 SPP/APR. Progress: 55 Subtask C.6.3 (Public Reporting of Assessment Data): Develop and implement procedures to ensure public reporting of assessment data in accordance with IDEA requirements in a timely fashion. Milestone C.6.3.1: Develop and implement procedures to ensure that the BIE will publicly report on the assessment of children with disabilities in the same manner and frequency as it reports on the assessment of children without disabilities, as required under 34 CFR §300.160(£). Performance Metric: Within 90 days of receipt of the BIE's 2019 determination letter, the BIE must provide to OSEP a Web link that demonstrates that it has reported, for FFYs 2015, to the public, on the statewide assessments of children with disabilities in accordance with-34 CFR §300.160(1). As soon as possible after the BIE reports publicly on the assessments of nondisabled children for FFY 2016 and FFY 2017, the BIE must provide to OSEP a Web link that demonstrates that it has reported, for FFY 2016 and FFY 2017, to the pub Iic, on the statewide assessments of children with disabilities in accordance with 34 C.F.R.§300. 160(f). Progress: Task C.7.0: Demonstrate Compliance with Secondary Transition Requirements. Subtask C.7.1 (Submission of Corrective Action Plan): Develop and implement a corrective action plan to demonstrate compliance with secondary transition requirements and improve the accuracy of the secondary transition data. Milestone C.7.1.1: Update and implement a corrective action plan that addresses the actions the BIE will take to demonstrate compliance with the secondary transition requirements in IDEA section 614(d)(l)(A)(i)(VIII) and 34 CFR §§300.320(b) and 300.32l{b) and improve the accuracy of the secondary transition data. Performance Metric: Submit a report on the status of implementation of the actions the BIE is taking to demonstrate compliance with secondary transition requirements and improve the accuracy of the secondary transition data. Progress: Subtask C.7.2 (Use of Directed Administrative Funds): Develop and implement a spending plan demonstrating that the FFY 2019 directed funds will be used to address the noncompliance with secondary transition requirements and to improve the accuracy of the secondary transition data. 56 Milestone C. 7.2.1: Submit a report on and analysis of FFY 2018 secondary transition compliance data, disaggregated by compliance item and BIE-funded school. Performance Metric: No later than October 31, 2019, provide the following: (c) A report of the BIE's secondary transition compliance data for the period July l, 2018 through June 30, 2019, disaggregated by Ill. Compliance item (i.e., each particular component of the secondary transition requirements associated with SPP/ APR Indicator 13- for example, whether there is evidence that the student was invited to the IEP Team meeting where transition services are to be discussed); and iv. BIE-funded school. (d) The BIE's analysis of the disaggregated data, including suspected or known reasons for any noncompliance. Progress: Milestone C. 7.2.2: In addition to implementing the approved spending plan for the use of the directed FFY 2018 funds (for which the Depai1ment granted a six-month extension to December 31, 2019), the BIE must develop and implement a spending plan to expend the directed FFY 2019 funds by July l, 2020 that demonstrates how the directed funds will be used to pay for strategies and activities that address the suspected or known reasons for the noncompliance with the secondary transition requirements in IDEA section 614(d)( I )(A)(i)(VIII) and 34 CFR §§300.320(b) and 300.321 (b) and that are reasonably designed to con-ect that noncompliance and improve the accuracy of the data. The BIE 's proposed spending plan must include: ( 1) the activities that will be carried out with those funds: (2) the costs associated with each of the activities; (3) a projected timeline for using the funds to pay the costs associated with each of the activities that demonstrates that the funds will be used by July I, 2020; and (4) an explanation of how the activities will result in improved compliance with secondary transition requirements and improved accuracy of the data. The BIE must also desctibe the documentation it will provide to demonstrate that the directed FFY 2018 funds were used in accordance with the FFY 2018 spending plan, and the separate documentation it will provide to demonstrate that the directed FFY 2019 funds were used in accordance with the FFY 2019 spending plan. In addition, to ensure that the BIE can increase compliance with the secondary transition requirements and improve data accuracy within one year, the BIE must expedite the use of the directed FFY 2019 IDEA Part 8 administrative funds and target the use of those funds for activities that are based on careful review of the BIE's FFY 2018 secondary transition data. Per/omumce Metric: (e) By October I, 2019, submit the proposed spending plan for the directed FFY 2019 IDEA Part B administrative funds for OSEP approval. (f) With each quarterly report for the 2019-2010 CAP, provide evidence that the BIE has directed the use of funds, as appropriate, during the reporting period. (g) With the first and second quarterly report for the 2019-2020 CAP, provide the amount of the $300,000 of the BIE's FFY 2018 IDEA Part B administrative funds that were used during the reporting period to carry out the activities described in the BIE's FFY 2018 57 spending plan to address the suspected or known reasons for the noncompliance with secondary transition requirements and to improve the accuracy of the data. (h) With the second, third and fourth quarterly report for the 2019-2020 CAP, provide the amount of the $300,000 of the BlE's 2019 IDEA Part B administrative funds that were used during the reporting period to carry out the activities described in the BIE's FFY 2019 spending plan to address the suspected or known reasons and to improve the accuracy of the data. (i) With each quarterly report for the 2019-2010 CAP, provide documentation that the BIE used those FFY 2018 and/or FFY 2019 IDEA Part B administrative funds during the reporting period in a manner consistent with the BIE's respective spending plan. Progress: ITask C.8.0: Improve Exiting Data In Accordance With IDEA Requirements. Subtask C.8.1 (Improving Exiting Data): Improve exiting data by utilizing available technical assistance resources. Milestone C.8.1.1: The BIE must report on: (I) the sources from which it received technical assistance related to those exiting data elements for which the BIE received a score of zero on the 2019 Pm1 B Results Matrix: and (2) the actions it took as a result of that technical assistance. Performance Metric: With the FFY 2018 SPP/ APR, due on February 3, 2020, provide agendas, schedules, and/or other documentation that demonstrates evidence of receipt of technical assistance related to those exiting data elements for which the BIE received a score of zero on the 2019 Part B Results Matrix and subsequent actions the BIE took as a result of that technical assistance. Progress: Task C.9.0: Ensure the provision of related services and timely initial evaluations in accordance with the re uirements of IDEA. Subtask C.9.1: Ensure correction of noncompliance previously identified by OSEP in San Felipe Pueblo Elementary School and other BIE-funded schools covered by the expired contracts for related services and timely initial evaluations Milestone C.9.1.1: The BIE must report on the status of the expired contracts at San Felipe Pueblo Elementary School and other BIE-funded schools that resulted in the disruption of related services and timely initial evaluations. 58 Performance Metric: With the first quarterly report for the 2019-2020 CAP due on October 31, 2019, the BIE must provide as assurance that: (I) all the expired contracts have been renewed, (2) IEP Teams considered, on an individual bases, whether compensatory services were needed as a remedy for the services previously not provided; and (3) any compensatory services detennined necessary by the IEP Teams have been, or are being provided. Progress: Subtask C.9.2: Implement procedures to ensure compliance with requirements to provide related services in accordance with students' IEPs and to conduct timely initial evaluations at San Felipe Pueblo Elementary School and other BIE-funded schools covered by the expired contracts. Milestone C.9.2.1: Ensure that all students with disabilities enrolled in San Felipe Pueblo Elementary School and other BIE-funded schools covered by the expired contracts received related services in accordance with their IEPs and any compensatory services detennined necessary by the IEP Teams, as required by IDEA section 612(a)(l) and 34 C.F.R. §§300.320 and 300.323(c )(2), and that all initial evaluations are conducted within 60 days of receiving parental consent for the evaluation in accordance with 34 C.F.R. §300.30l(c)(l). Perfornumce Metric: With each quarterly report for the 2019-2020 CAP, report on: ( l) the number of students with disabilities. at San Felipe Pueblo Elementary School and any other BIE-funded school that falls under the same contracts, who are still not receiving relat4ed services in accordance with their IEPs; (b) the steps that the BIE is taking to ensure that these students receive the required services in accordance with their IEPs and any compensatory services determined necessary by the IEP Teams; (c) the number of requested initial evaluations that have not been conducted or have been delayed; and (d) the steps that the BIE is taking to ensure that those evaluations are conducted as soon as possible. Progress: Subtask C.9.3: Implement procedures to ensure compliance in all other BIE-f8nded schools with the requirements to provide related services in accordance with students' IEPs and to conduct timely initial evaluations. Milestone C.9.3. l: Detennine if any other BIE-funded schools are unable to provide services or conduct timely initial evaluations due to contracting delays. The BIE may develop a reasonable monitoring plan that examines a sample of BIE-funded schools per year, in lieu of examining all BIE-funded schools at the same time. If the BIE selects this option, it must submit the monitoring plan to OSEP for approval. Performa11ce Metric: (a) lf the BIE opts to develop a monitoring plan, it must submit the plan to OSEP for approval with the first quarterly report for the 2019-20 IO CAP due on October 31, 2019; (b) With each quarterly report for the 2019-2010 CAP, report on: (i) the number of students with disabilities who are not receiving related services in 59 accordance with their lEPs; (ii) the steps that the BIE is taking to ensure that these students receive the required services in accordance with their IEPs and any compensatory services determined necessary by the IEP Teams; (ii) the number of requested initial evaluations that have not been conducted or have been delayed; and (iv) the steps that the BIE is taking to e4nsure that those evaluations are conducted as soon as possible. Progress: Subtask C.9.4: Implement procedures to prevent contractual problems that could result in a similar disruption of services in the future Milestone C.9.4.1: Submit a plan to prevent contractual problems that could result in a similar disruption of services in the future. Performance Metric: With the first quarterly report for the 2019-2010 CAP, the BIE must provide a plan to prevent contractual problems that could disrupt services, by ident9fying specific policies, procedures, processes and staff positions that are responsible for implementation and oversight of compliance with this requirement. Progress: 60