SPP: Public Agency Procedural Compliance Self-Assessment

Implementing Corrective Action Plans

Plan must correct all errors as soon as possible and no later than one year.

As in the last monitoring cycle, public agencies are required to take corrective actions and the WDPI reviews corrective action plans to ensure the proposed correction strategies are reasonably calculated to correct the identified noncompliance in a timely manner and ensure future compliance. The WDPI staff provides technical assistance to the public agencies to make any needed revisions. The public agency implements the corrective action plan after the WDPI approves it.

The public agency must implement adequate internal controls to ensure correction of noncompliance and to ensure future compliance. Internal controls include a process for identifying compliance errors in individual cases beyond the students in the self-assessment samples and ensuring corrective action is taken in each case where a compliance error is identified.

As provided in federal law, the Department will ensure that:

• public agencies are to take corrective action when one or more student records are out of compliance,
• for individual student errors and for public agency noncompliance, public agencies must take appropriate action to ensure future compliance for all students, and
• public agencies must correct all noncompliance as soon as possible and no later than one year after filing the self-assessment report with WDPI.

The WDPI has designed our electronic reporting system to assist public agencies in meeting these requirements.

Errors found in individual student records (errors in one or more records)

In the case of errors found in individual student records, the program will direct public agencies to take a specific action. For example, if you enter 1 or more student records not in compliance with the IEP Record Review Checklist Item I-18, which requires a child to receive services required by his or her IEP, then the program will note that for all individual records reviewed and found to be out of compliance, the agency must consider compensatory services. Take this action for all students whose records were out of compliance as soon as possible and maintain documentation within the public agency. There is a sample letter to use in cases where parents and the public agency agree no compensatory services are required for Items I-18, D-1, or N-4.

In addition, when the program identifies a compliance statement for which individual student errors were reported but not enough errors to trigger agency-wide corrective action, the public agency must take appropriate action to ensure future compliance. For example, you may determine that a memo, individual staff meeting, or revised record-keeping system will ensure future compliance. Take those actions and maintain documentation within the public agency.

Public agency noncompliance (significant error rate)

When the public agency's procedural compliance self-assessment indicates a significant error rate for one or more requirements, the public agency must develop intensive agency-wide corrective actions to correct the identified noncompliance and to ensure future compliance. The WDPI recommends specific corrective actions, which the public agency may implement, or the agency may develop and implement other corrective actions. All noncompliance must be corrected as soon as possible and no later than one year after the public agency files its self-assessment report with the WDPI. Take corrective actions and maintain documentation within the public agency.

The corrective action plan for public agency noncompliance must include adequate internal controls to ensure correction of noncompliance and to ensure future compliance. Develop and implement internal controls and maintain documentation within the public agency.

Recommended Corrective Actions for Public Agency Noncompliance.

Maintain documentation within public agency.

As you implement your corrective action plans, please maintain documentation within the public agency.

For errors in individual student records, you must be able to demonstrate: (1) as soon as possible, you corrected all identified noncompliance by taking the steps identified by WDPI and (2) the public agency took appropriate action to ensure future compliance.

For public agency noncompliance, you must be able to demonstrate: (1) the public agency took corrective actions to ensure future compliance and (2) the public agency has an internal review process to identify all noncompliance and correct as soon as possible and no later than one year.

The Department will verify that all noncompliance has been corrected.

• Special Education Mediasite Live Trainings - Select the training you wish to view.
• Self-Assessment Training Webcast Section 5, Implementing Corrective Action Plans:
  Webcast - PowerPoint Presentation
  
  
• Self-Assessment/Sampling Activities for the Cycle
• PI-3202-Assurances, for documenting correction of student-level errors and adoption of an internal control system.

If you have questions about the self-assessment process that are not answered in this section or on the Self-Assessment Questions and Answers page, please submit your question by email.

For questions about this information, contact Courtney Reed Jenkins 608-267-9183 or Patricia Williams 608-267-3720.

Last updated on 4/16/2008 1:10:24 PM