IDEA 2004 and the Continuous Improvement and Monitoring System (CIMS) Emphasize Compliance and Quality in Secondary Transition Planning

by Larry Stemple

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On Dec. 3, 2004, President George W. Bush signed the reauthorized Individuals with Disabilities Education Act (IDEA) into law. Most provisions of the act went into effect on July 1, 2005. One of the priorities targeted by IDEA 2004 is the provision requiring transition services for students with an individualized education program (IEP). This issue of FOCUS on Results looks at transition requirements in IDEA 2004, and how they align with Michigan’s State Performance Plan and the Continuous Improvement and Monitoring System (CIMS). The overall goal of effective transition planning is to improve the likelihood that students will be successful and enjoy an improved quality of life when they exit the school system. This issue of Focus on Results also looks at how the Present Level of Academic Achievement and Functional Performance (PLAAFP) statements can help in developing effective transition IEPs.

Compliance Aligns With Quality

School districts often struggle with the concept of compliance versus quality. Compliance basically means following the specific requirements of the law. In the past, states were required to monitor school districts on their effectiveness in implementing the specific components of the law. School district administrators often perceived this state monitoring process as threatening and punishing, as districts were often cited for non-compliance and had to document corrective procedures. The emphasis was often on procedural and paperwork errors rather than on system changes developed to improve post school outcomes for students with disabilities.

Under IDEA 2004, schools must continue to follow the specific requirements of the law, but they are also accountable for developing a quality transition planning system that will improve graduation rates and increase the likelihood that students will have success as they move to post-school life. Today, school districts must follow the law, but they also must go beyond the basics and strengthen their use of quality practices to improve the in-school and post-school transition planning process.

Transition and IDEA 2004 —Key Points

The following is a list of quality transition planning requirements based on IDEA 2004 (see National Association of State Directors of Special Education, Inc., November 2004, www.nasdse.org). The specific section reference numbers to the law are provided here.

1. Transition services are designed to be part of a results-oriented process that is focused on improving the academic and functional achievement of the child with an IEP to facilitate the child’s movement from school to post-school activities. (602)
2. The transition process is based on the individual child’s needs, taking into account the child’s strengths, preferences, and interests. (602)
3. The transition process includes instruction, related services, community experiences, the development of employment, and other post-school adult living objectives. In some cases, it also includes the acquisition of daily living skills and a functional vocational evaluation. (602)
4. For a child whose eligibility for school is ending due to graduation or age, a local education agency shall provide the child with a summary of his or her academic achievement and functional performance, which shall include recommendations on how to assist the child in meeting his or her post-secondary goals. This is known as a summary of performance. (614)
5. Transition planning should begin not later than the first IEP to be in effect when the child is 16, and updated annually thereafter. (614) (Note: At this time, the Michigan Department of Education’s (MDE) Office of Special Education and Early Intervention Services (OSE/EIS) is recommending continuing use of the 14-year-old requirement.)
6. There should be appropriate measurable post-secondary goals based upon age appropriate transition assessments related to training, education, employment, and, where appropriate, independent living skills. (614)
7. There should be a description of the transition services (including courses of study) needed to assist the child in reaching those goals. (614)
8. Beginning not later than one year before the child reaches the age of majority under state law, there should be a statement that the child has been informed of his or her rights under this title, if any, that will transfer to the child on reaching the age of majority under section 615(m). (614)
9. There should be a statement of measurable annual goals, including academic and functional goals, designed to: (614)
   • (aa) meet the child’s needs that result from the child’s disability to enable the child to be involved in and make progress in the general education curriculum; and
   • (bb) meet each of the child’s other educational needs that result from the child’s disability...
10. In addition, there should be a description of how the child’s progress toward meeting the annual goals will be measured and when periodic reports on the progress the child is making toward meeting the annual goals will be provided (such as through the use of quarterly or other periodic reports, concurrent with the issuance of the report card)... (614)

State Performance Plan and Transition (Section 616 of IDEA 2004)

Under Section 616 of IDEA 2004, all states are directed by the Office of Special Education Programs (OSEP) to develop a performance plan to evaluate the state's efforts to implement the requirements and purposes of IDEA priorities and describe how the state will improve such implementation. Michigan has developed a plan that includes OSEP’s twenty indicators in this process. Two of the indicators are of great importance for improving transition planning and subsequent post school outcomes for students.

• Indicator 13: Percent of youth aged 16 and above with an IEP that includes coordinated, measurable, annual IEP goals and transition services that will reasonably enable the student to meet the post-secondary goals.
• Indicator 14: Percent of youth who had IEPs, are no longer in secondary school, and who have been competitively employed, enrolled in some type of post-secondary school, or both, within one year of leaving high school.

Once the State has finalized the methods for collecting performance data on these two indicators, improvement plans can be developed, if needed, to improve outcomes for all students with disabilities. Indicator 13 results will need to show 100% compliance by 2010. IEP teams must therefore be trained in the necessary components of an effective transition IEP. In addition, Indicator 14 will provide information as to the effectiveness of post-school planning for students and provide the basis for training and improvement strategies to be implemented over the same time period.

What Is the CIMS?

The MDE, OSE/EIS is developing and refining a new monitoring and quality assurance system with a focus on improving educational results for Michigan students with an IEP. The CIMS balances the need for continuous procedural compliance with a focus on improving student results and outcomes. The goal of the CIMS is to have districts and agencies better understand the operation and effectiveness of programs for students with disabilities and develop plans for targeted use of their resources. The CIMS process outlines 12 key performance indicators (KPIs) to achieve this goal.

1. Child Find— Effective schools have a written system that is systematically implemented to locate, evaluate, and identify students suspected of having disabilities, from birth through age 25.
2. Positive Behavior Support— Effective schools implement school wide behavior support systems that define, teach, and consistently apply developmentally appropriate behavior expectations for all students, including those with IEPs.
3. Student Assistance Teams— Effective schools have a written and systematic process for the functional assessment and the development of problem-solving interventions for students who are not making sufficient academic and/or social, emotional, or behavioral progress.
4. Family Participation— Effective schools create climates that engage parents and families of students with IEPs in district, school, and student-level decision making.
5. IEP Development, Implementation and Timeliness— IEPs that address the student's educational needs identified through assessment are fully implemented and modified to ensure the student's success.
6. Curriculum— Effective schools provide students with access to the general education curriculum taught in their schools.
7. Least Restrictive Environment— Effective schools provide consultation and intervention within general education, providing pull-out only as needed, with an emphasis on increased participation in general education settings.
8. Participation in the State General Assessment— Effective schools have a systematic plan to encourage and maintain full student participation in the state general assessment.
9. Preparation & Planning for Post School Life— Effective schools prepare students for post-school outcomes such as advanced education, job training, or employment.
10. Instructional Practices Based on Peer-Reviewed Research— Effective schools provide a successful range of instructional practices and interventions based on peer-reviewed research for students with disabilities.
11. Highly Qualified Teachers— Effective schools demonstrate improved performance outcomes when teachers have the necessary training to educate students.
12. Data Use— Effective schools use information on student performance to evaluate, plan, and modify programs and services for students with disabilities, resulting in increased student performance.

Service Provider Self-Review

Transition plays a significant role in the Service Provider Self Review (SPSR) process of the CIMS. This process addresses how well the service provider meets the needs of infants, toddlers, students with IEPs, and their families. It also establishes a baseline for measurement of progress. Service providers include local educational agencies, public school academies, Early On® service areas, and intermediate school district (ISD) run programs.

In addition, the SPSR reflects how well the service provider meets federal and state requirements and provides a free appropriate public education (FAPE) in the least restrictive environment (LRE). Self-Review requires oversight by a local district steering team comprised of parents, staff, and administrators. The steering team has the responsibility of using service provider agency data for analyzing the district’s performance and for developing improvement plans. The local steering team will use data generated by local district student record reviews, educational benefit reviews, IEP implementation reviews, and a variety of stakeholder surveys to analyze the district’s performance on 12 KPIs as outlined in the CIMS process. (Visit training.cimsmichigan.org for complete details.)

The district’s performance assessment analysis would indicate one of the following for each of the 12 indicators:

• Strength
• Meets Requirement
• Needs Improvement
• Not in Compliance

Improvement planning would follow as determined by the local team.

Key Components of the Transition and Service Provider Self Review (SPSR)

There are nine key components of the transition and SPSR for the CIMS process. The local steering team will review and align the following nine components with the 12 KPIs of the CIMS to ensure a quality transition process that is in compliance with IDEA 2004.

1. Preparation and Planning for Post-School Life—This component involves how a local school system is practicing student-focused planning in the IEP process; how it provides a planned course of study connected to students’ post-school goals; and how it is preparing students for post-school outcomes such as advanced education, job placement, and establishing community connections.
2. Student Record Review— A minimum of three student records must be reviewed to determine if transition standards are being met. These standards include required and quality components.
3. IEP Implementation Review— The overall purpose of the review is to report on the status of services listed in the student’s IEP and to ensure that the student receives the services as described in the IEP. These services may include transition activities if the student is of the appropriate age.
4. 30 Day Corrective Action— If an IEP does not clearly define programs, services, supplemental services, and transition services, the district must correct the problem areas within 30 calendar days, usually by developing a new IEP.
5. Transition Activities and the Educational Benefit Review— This process involves the review of a student’s records over three consecutive years to determine if the IEP process was reasonably addressing the needs of the student. If the student is of transition age, then transition planning must be included.
6. Assessment Results Related to Student’s Post-Secondary Needs— The IEP team must use appropriate transition assessments to help determine the student’s post- secondary needs and goals.
7. Student Surveys to a Sample of Transition-Age Students— The results will provide important nput about the students’ perception of their own transition IEP experiences.
8. Graduate Surveys—School districts will send surveys to all students with IEPs who graduated over a three-year period. This data will target the students’ experiences since leaving school and help the school improve services and programs to better meet the post school needs of students.
9. Administrator, Special Education Provider, Parent Surveys to a Selected Sample Size—Each of these surveys has questions addressing transition planning.

PRESENT LEVEL OF ACADEMIC ACHIEVEMENT AND FUNCTIONAL PERFORMANCE

One of the fundamental components of the IEP is the statement of the child’s present level of academic achievement and functional performance (PLAAFP) that insures quality and compliance. The PLAAFP:

• Addresses functional performance based on transition assessments. This includes the child’s daily environment: in classrooms, in the community, on the bus, using other forms of transportation, etc.
• Describes both academic and non-academic areas of need related to the child’s disability.
• Includes current formal and informal educational performance data such as curriculum based measurements, IEP progress monitoring, observation, classroom performance data, behavior rating scales, etc.
• Uses understandable language.
• Describes specific learning accommodations and learning strategies that the child needs, the child’s level of independence, and the child’s general need for assistance.
• Addresses the impact of the disability on the child’s life, particularly the ability to benefit from post-secondary training or employment.

The following is a basic example of a PLAAFP with an emphasis on the framework for the development of the child's transition IEP.

Conclusion

The IDEA of 2004, Michigan’s State Performance Plan, and Michigan’s new CIMS are having a profound impact on transition planning for students with disabilities in Michigan. The required elements of effective transition planning have been expanded and reemphasized. In addition, under the CIMS, there is strong focus on both compliance and quality transition planning. As stakeholders become more involved in this process and awareness grows, positive systems change will help to improve outcomes for all students as they move to adult life.

Author

Larry Stemple, Wayne County Regional Educational Service Agency (RESA) Transition Coordinator, Coordinator of Educational Accountability (formerly known as a monitor) and Special Education Consultant for Wayne County RESA, 33500 Van Born Road, Wayne, MI 48184, (734) 334-1541, Fax (734) 334-1494,
stempll@resa.net.

Reference

National Association of State Directors of Special Education. Inc. (November 2004). The Individuals With Disabilities Education Act: A Comparison of P.L. 105-17 (IDEA ’97) to H.R. 1350 (IDEA ‘04) As Passed by Congress on November 19, 2004. Retrieved February 12, 2006, from www.nasdse.org.

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