Click to edit Master title style Core Indicators, Reports, Negotiated Performance Targets,

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Carl D Perkins (Perkins IV)
Career
Technical
Education
Act
Click and
to edit
Master
title style
Core Indicators, Reports,
Negotiated Performance Targets,
and Perkins Funds
Regional Workshops
Chuck Wiseley
Spring 2008
1
Agenda
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• Why are we here – why do we care?
• Perkins IV
– Legislative requirements
• State & Local requirements
• Negotiating & Meeting Targets
– Not meeting targets & targeting funds
• Perkins funds - improving student success.
– Core Indicators, Reports, Performance Targets
• Setting Targets & Perkins IV Local Application.
Regional Workshops
2
Session 1 Goals
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• Perkins funds - improving student success.
• What are the Rules?
• Negotiating & Meeting Targets
– Tools for analysis
– Not meeting targets & targeting funds
Regional Workshops
3
Session 2 Goals & Objectives
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• Update on development
– Core Indicators, Reports, Performance Targets &
Perkins IV Local Application.
Participants will:
• View/Review Perkins IV Indicators & Reports
– what meaning can be derived
– changing performance with Perkins funds
• Discuss and Set Proposed Targets
–
–
–
–
negotiated targets (who & when)
strategies for negotiating targets.
strategies for program improvement,
strategies for getting buy-in
– Other necessary topics for inclusion
Regional Workshops
4
2004
Crystal
Ball
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• 109th Congress
• Some changes in Accountability
– Strengthened
– Common measures
• Wage gain
– Negotiated performance State & Local
5
Perkins IV
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• Carl D. Perkins Career and Technical
Education Improvement Act of 2006
• P.L. 109-270
• August 12, 2006.
• 2007-8 Transition Year
• 2008-9 First Year under the Act
Regional Workshops
6
Negotiating Targets
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• Perkins III
– State negotiates targets USDE
• Perkins IV
– State negotiates targets USDE
• Targets for 1 year and then 2 years (3rd & 5th)
– Locals either:
• Accept those targets
• Negotiate local targets
– Included in Local Plans
• Targets for next year
Regional Workshops
7
Sanctions in Law
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• Perkins III
– State
• Bundled – WIA & ESEA
• Improvement plan
• Two years below, Secretary MAY withhold funds
• Perkins IV
– State & Locals:
• 90% of Perkins Targets
• Improvement Plan
• Year 2 no improvement, <90% for 3 years for any
single target
– Feds or State SHALL provide technical assistance
– MAY withhold funds (all or part)
Regional Workshops
8
CCC Sanction Plan:
Meeting
Performance
Targets
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to edit
Master title
style
• Application is Improvement Plan
• Accountability Determination
– In compliance – at or above 90%
• Expenditures need not be linked to the areas with the largest
performance gaps
– Focused Improvement Status - < 90%
• Focused Improvement section
• Year 2 – No Improvement: Diagnostic Study
• Programs funded must address individual program performance gaps.
– Priority Focused Improvement – 3rd Yr < 90%
• Diagnostic Study and Action Plan
Regional Workshops
9
Priority Focused Improvement
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• Focused Improvement section
• Diagnostic Study
• Action Plan
– Expected outcomes,
– the Perkins and other funding dedicated to each
strategy, and
– the implementation dates expected for each
strategy.
Regional Workshops
10
Odds of being in:
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• Focused Improvement?
– Depends on how well the negotiation goes.
• Improving after Focused Improvement?
– Depends on last year.
• Priority Focused Improvement?
– Depends on how well the negotiation goes.
– Unlikely to occur?
Regional Workshops
11
The Negotiation Process
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• Negotiation Workbook
– Online
– Tables
– Charts
• Negotiation Worksheet
• Local Application
12
Negotiation Tables
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Regional Workshops
13
Mention Office 2003 v 2007
Problem?
90% x 55.6% = 50%
What has occurred?
Outcomes & Diagnostics
Faupl
Local Application: District
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17
Perkins IV funds
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• Improving student success.
– Nine Requirements
– 18 Permissive Uses
– Should address performance gaps
• Perkins IV Local Application.
– Improvement Plans
– Negotiating & Meeting Targets
– Progressive Oversight, Improvement Plans,
and Risk Monitoring
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19
With or Without Sanctions
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Basic criteria for expending Perkins funds
• Expenditures must
– Meet the purpose of the Act
– Be necessary and reasonable
• Expenditures may not be used for
– General purposes
– Maintenance of existing programs
20
What
rulestitle
apply?
Click
to federal
edit Master
style
• Carl D. Perkins
Career and Technical Education Act
(Perkins IV)
• EDGAR
(Education Department
General Administration Regulations)
21
What federal rules apply? (Continued)
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• OMB Circulars (Office of Management and
Budget)
–
–
–
–
Circular A-87 Cost Principals – State and Local
Circular A-21 Cost Principals – Education Institutions
Circular A-133 Single Audit Requirements
Circular A-102 Grants and Cooperative Agreements
with State and Local Governments
– Circular A-110 Uniform Administration Requirements
for Grants and Agreements with Institutions of Higher
Education, Hospitals and Other Non-Profit
22
Organizations
What types of costs are
Click
to edit
Master title
style
generally
considered
eligible?
•
•
•
•
•
•
•
•
Administrative Costs (5%)
Personnel Services (time records)
Operating Expenses
Stipends
Consultants
Instructional Materials
Travel
Instructional Equipment
23
What
costs
are
NOT
eligible?
Click to edit Master title style
1.
2.
3.
4.
5.
6.
7.
8.
Student expenses or direct
assistance to students *
College tuition, fees, books*
Entertainment
Awards and memorabilia
Individual memberships
Membership with orgs. that
lobby
Fines and penalties
Insurance/self-insurance
9.
10.
11.
12.
13.
14.
15.
16.
17.
Expenses that supplant
Audits except single audit
Contributions and donations
Contingencies
Facilities and furniture *
General advertising
Alcohol
Fund raising
General administration
24
What are the 9 requirements for
Click
to editIV
Master
title style
Perkins
expenditures?
Funds made available to eligible recipients under this part shall be
used to support career and technical education programs that1.
2.
3.
4.
5.
Strengthen academic &
technical skills of students
Link secondary and
postsecondary CTE programs
(at least one program of study)
Provide students with strong
experience and understanding
all aspects of an industry (WBL)
Develop, improve, & expand use
of technology
Professional development
6.
7.
8.
9.
Evaluate programs with
emphasis in meeting needs of
spec. pops.
Initiate, improve, expand and
modernize quality programs
Provide services & activities of
sufficient, size, scope and quality
Provide activities to prepare
special pops. for high skill, high
wage, or high demand
occupations leading to selfsufficiency.
25
20 permissive uses of funds:
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1. Involve parents, business and labor in
planning & operation
2. Career guidance & academic
counseling
3. Business Partnerships - Work-related
experience students & faculty
4. Programs for spec. pops.
5. CTE student organizations
6. Mentoring & support services
7. Upgrading equipment
8. Teacher prep. programs
9. Improving and developing new CTE
courses including distance ed.
10. assist transition to BA degree programs
11.
12.
13.
14.
15.
16.
17.
18.
19.
support entrepreneurship education
initiatives for secondary students obtaining
postsecondary credit to count towards an
AA/AS or BA/BS degree
support small CTE learning communities
Family & consumer sciences
Adult CTE programs
Job placement programs
Support Nontraditional activities
Automotive technologies
*Pooling funds –
Teacher prep,
data & accountability,
assessments
20.
Support other CTE programs
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26
Effects of not achieving targets
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• Above 90% of targets:
– Freedom to fund any program improvements
– Encouraged to address low performance
• Below 90% - year 1
– Focused Improvement section
• Requires some analysis to write the narrative
– Must address low performance in funded Programs
– Encouraged to start a diagnostic study
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27
Effects of not achieving targets
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continued...
• Below 90% - year 2 or no improvement
– Focused Improvement section
– Diagnostic study
– Propose Effective Practice solutions
• Probably a more district level approach to
expenditures
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28
Effects of not achieving targets
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continued...
• Below 90% of target - 3 years
– Focused Improvement section
– Submit Diagnostic study w Action Plan to CO
– Action Plan
• Proposed Effective Practice solutions &
Implementation dates
• Probably an even more district level approach to
expenditures
– Risk Monitoring
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29
Break time
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• I am the messenger
– don’t kill the messenger
• Questions
• 20 minute break
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30
Data: Why?
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• Funding
• Outcomes Analysis
• Telling the story
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31
Defining the Data
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•
•
•
•
SAM Codes
TOP Codes
Data Elements
Core Indicators
–
–
–
–
Funding
“The Law”
Definitions
Negotiated Performance Targets
Measurement Approaches/Formulas
Regional Workshops
32
Student Accountability Model (SAM)
Click
to edit of
Master
title(TOP)
style
& Taxonomy
Programs
• Priority “A“ - Apprenticeship
– Must have the approval of the Division of Apprenticeship
Standards
• Priority “B“ – Advanced Vocational
– Used sparingly, no more than two courses in any one
program
– “B” level courses must have a “C” prerequisite in the same
program area
• Priority "C" – Clearly Occupational
– Generally taken in the middle stage of a program, detracts
"drop-ins."
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33
Student Accountability Model (SAM)
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Master(TOP),
title style
& Taxonomy
of Programs
Continued
• Priority "D" – Possibly Occupational
– Taken by students in the beginning stages of their
occupational programs
– Can be survey course
• Priority “E” = Non-Occupational
Vocational Flag on TOP code
– Designed to identify vocational “Programs” for federal
reporting (*) - see Taxonomy of Programs, Sixth Edition,
July 2007
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34
Data Elements
MIS
System title style
Click to edit
Master
• Students, Courses, Degrees, Services
• Student VTEA Data Elements
–
–
–
–
–
–
Economically Disadvantaged
Single Parent
Displaced Homemaker
Cooperative Work Experience Education
Tech Prep
Migrant Worker
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35
Accountability Requirements
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edit Master
113(b)title style
5 core indicators of performance:
1.
Student attainment of technical skill proficiencies;
2.
Student attainment of credential, certificate, or degree;
3.
Student retention in postsecondary education or transfer;
4.
Student placement in military, apprenticeship, or employment
5.
Student participation/completion of non-traditional training
•
State and Local adjusted levels of performance
–
•
Levels of performance negotiated with USDE / State
Results reported annually
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36
Perkins III (1998)
Indicators
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edit Master
title style
1. Skill Attainment
Student Achievement – Successful course completion
•
•
Academic
Vocational and Technical
2. Completions
Student program completion – Certificates & Degrees
3. Placement and (3b) Retention
Placement and retention in employment
4. Equity -- Non-Traditional Employment
Participation/Completion of non-traditional training
•
•
4a - Participation
4b Completion
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37
Core Indicators
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1. Technical Skill Attainment
Successful CTE course completion
2. Completions
Program completion–Certificate, Degree & Transfer Ready
3. Persistence & Transfer
Student persistence in Higher Ed
4. Placement
Placement in apprenticeship, employment, military, fed gov
5. Equity -- Non-Traditional Employment
Participation (5a)/Completion (5b) - non-traditional training
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38
Cohort Definitions
for Master
Measurement
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to edit
title style
Participant: NT Participation
–
Perkins III -Any enrollment in a CTE course (TOP)
–
Perkins IV – concentrator using assigned major
Concentrator: All other indicators
•
Cohort of students enrolled during the cohort year and
–
Successfully completed at least one course in the middle or end of a
program (SAM A-C) and 12 vocational units within a single
discipline (two digit TOP) or
–
Program completion as indicated by receipt of ANY vocational credit
certificate or degree
Leavers: Not enrolled in year following cohort year
–
2P1 - Completions
–
4P1 - Placement (Employment)
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39
Assigning a Program to a Student
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1. Award –TOP code of CTE Certificate or Degree
2. Concentrators
•
Hierarchy based on SAM Priority code
•
Assigned to the TOP where most CTE units occurred
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40
What is not decided
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• Concentrator
– How long to accumulate 12 units in a two digit TOP (discipline)
• Two, three, or five years
• Completions
– Transfer Ready or Prepared
• Employment
– Which period for “employed”?
• Feds want quarter 2 - Oct-Dec
• Any of 4 quarter
• NT Participation
• CRCC
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41
Negotiating Targets
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• Perkins III
– State negotiates targets USDE
• Perkins IV
– State negotiates targets USDE
• Targets for 1 year and then 2 years (3rd & 5th)
– Locals either:
• Accept those targets
• Negotiate local targets
– Included in Local Plans
• Targets for next year
• Negotiations complete by May 15
Regional Workshops
42
Sanctions in Law
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• Perkins III
– State – Bundled with WIA, ESEA, Adult Ed
• Improvement plan
• Two years below, Secretary MAY withhold funds
• Perkins IV
– State – Perkins – each indicator
• 90% of Target
• 3 years for any single target
– Locals:
• 90% of Targets
• Improvement Plan
• Year 2 no improvement, 3 years <90% for any single target
– State SHALL provide technical assistance
– State MAY withhold funds (all or part)
Regional Workshops
43
CCC Sanction Plan:
Meeting
Performance
Targets
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to edit
Master title
style
• Application is Improvement Plan
• Accountability Determination
– In compliance – at or above 90%
– Focused Improvement Status - < 90%
• Focused Improvement section
• Year 2 – No Improvement: Diagnostic Study
– Priority Focused Improvement – 3rd Yr < 90%
• Diagnostic Study and Action Plan
Regional Workshops
44
Timeline for Outcomes & Outputs
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• Negotiating Performance 2008-09
– Spring 2008
• Cohort Year (2006-07)
• +1 yr for outcomes (2007-08)
–
–
–
–
Transfer
Persistence
Employment
Spring 2009
• Outcomes have already occurred
– Target low performance now!
45
Local Application: District
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46
Spring 2008 Sessions
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7 Regional Sessions for District/College Teams
– Content so far from this session
•
•
•
•
TOP & SAM Codes
Data Elements
Core Indicators
“The Law”
– Definitions & Negotiated Performance Levels
– CCC Strategies
– CI Measurement Approaches/Formulas/Targets
– Reports
• Negotiation – Strategies
• Compliance – Local App
• Program Improvement
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47
Core Indicators & Targets
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1. Technical Skill Attainment
Successful CTE course completion
2. Completions
Program completion–Certificate, Degree & Transfer ready
3. Persistence & Transfer
Student persistence in Higher Ed
4. Placement
Placement in apprenticeship, employment, military, fed gov
5. Equity -- Non-Traditional Employment
Participation (5a)/Completion (5b) - non-traditional training
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48
Core Indicator 1
Click
to edit Skill
Master
title style
Technical
Attainment
• Successful Course Completions
– Technical Skill Proficiencies
• Vocational (CTE) Courses
– SAM A-C
– Vocational TOP
• G.P.A. Concentrators
– Grade reports (moved to Data Mart)
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49
Core Indicator 1: Measurement &
Click Performance
to edit Master
title style
Levels
SAM A - C Courses:
# Students with GPA > 2.00
÷
# Students with Grades A - F
Year
2002-03
2003-04
2004-05
2005-06
2006-07
TargetActual*
77.76%
84.01%
78.76%
84.73%
79.76%
84.70%
84.02%
83.69%
83.70%
??.??%
* Based on Perkins III data. Regional Workshops
99.6%
50
Core Indicator 1: Measurement &
Click
to edit Master
title style
Performance
Levels (Analysis)
SAM A - C Courses:
# Grades A-C & Cr
÷
# Grades A–F, Cr-NoCr, W, & I
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51
Core Indicator 2
ClickProgram
to edit Master
title style
Completions
• Completers (numerator)
– Award in Current Year
– AA/AS degrees
– Certificates
– Transfer Ready (or Prepared)
– or Equivalent
• Leavers & Completers (denominator)
– Left system (college) for one year and/or
– Award in Current Year
– AA/AS degrees
– Certificates
– Transfer Ready
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52
CI 2-Completions:
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title style
Measurement
& Master
Performance
Levels
Certificate/Degree/Transfer Ready
÷
All Concentrators (Leavers & Completers)
Year
2002-03
2003-04
2004-05
2005-06
2006-07
TargetActual*
59.82%
76.36%
59.82%
74.89%
60.82%
73.42%
73.00%
73.73%
73.00%
??.??%
* Based on prior indicator definition.
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53
Core Indicator 3
ClickPersistence
to edit Master
title style
& Transfer
Concentrators who were not leavers
in the year following the cohort year
Or
Transfers (CSU/UC/Clearinghouse)
÷
All Concentrators
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54
Core Indicator 4
Click to edit
Master title style
Placement
• Placement
• UI wage file match 1st year out
• Apprenticeship, Military, Fed Gov
• Minus Continuing in Four Year Institution
– CSU, UC, Clearinghouse
• Not resolved
• Four quarters in Academic Yr after leaving
• Quarter 2
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55
CI 4 Placement :
Click to edit
title style
Measurement
& Master
Performance
Levels
Leavers & Completers in UI covered employment or
Apprenticeship, Military, Fed Gov
÷
All Leavers & Completers
Year
2002-03
2003-04
2004-05
2005-06
TargetActual*
83.19%
84.08%
83.19%
82.53%
83.19%
82.07%
82.07%
81.76%
98.65%
99.62%
*Based on prior indicator definition.
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56
Core Indicator 5
Click to edit
Master
Gender
Equitytitle style
Training leading to Nontraditional Employment
(e.g., Men in Nursing – Women in Auto)
75% / 25% from 2000 census employment data
• Job codes (SOC) mapped to 2000 Census data
• SOC codes mapped to CIP (USDE)
• NAPE developed Nontraditional CIP table
• CIP codes mapped to TOP (CCC)
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57
Core Indicator 5
Click to edit
Master
Gender
Equitytitle style
In Programs leading to Nontraditional Employment
Nontraditional Gender Students
÷
All Students in NT Program
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58
CI 5a: Participation
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title style
Measurement
Performance
Levels
Nontraditional participants enrolled in a
nontraditional TOP Code
÷
All participants enrolled in a
nontraditional TOP Code
Year
2002-03
2003-04
2004-05
2005-06
Target
27.98%
28.98%
29.98%
35.31%
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Actual
36.98%
36.80%
35.31%
37.16%
59
CI 5b Completion:
Click to edit
title style
Measurement
& Master
Performance
Levels
Nontraditional “completers”
of nontraditional programs
÷
All “completers” of nontraditional programs
Year
2002-03
2003-04
2004-05
2005-06
TargetActual
26.95%
24.42%
26.95%
24.21%
25.05%
23.25%
23.25%
25.66%
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60
CI 5b Completion:
Click to edit
title style
Measurement
& Master
Performance
Levels
Nontraditional “completers”
of nontraditional programs
÷
All “completers” of nontraditional programs
Year
2002-03
2003-04
2004-05
2005-06
TargetActual
26.95%
24.42%
26.95%
24.21%
25.05%
23.25%
23.25%
25.66%
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90.6%
89.8%
92.8%
61
Click to edit Master title style
Do these indicators really measure
what education in CCC does?
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62
Click to edit Master title style
Do these indicators really measure
what education in CCC does?
They are only indicators.
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63
Click to edit Master title style
Are they meaningless?
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64
Click to edit Master title style
Are they meaningless?
No. Student success matters.
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65
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How can we use the indicators to
improve student success?
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66
Click to edit Master title style
How can we use the indicators to
improve student success?
Understand “What” is happening to students.
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67
Click to edit Master title style
How can we use the indicators to
improve student success?
Understand “What” is happening to students.
Why is it happening?
SLOs, CATs, Research, etc.
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68
Click to edit Master title style
How important is setting an
appropriate target ?
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69
Accessing the Data
Click to edit Master title style
•
•
•
•
•
Access
Report Formats
Report Structures
Report Contents
Report Examples
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70
Reports
Click to edit Master title style
• New reports
– Developed for negotiations
•
•
•
•
District and College Level
Special Pops detail
8 years history
Final version mid February 2008
• All Reports
– Easier access – Excel or SQL reports
– ??? Late February 2008 ???
• Progressive scrutiny on use of reports
– Below 90% of Targets in
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71
Access
Click to edit Master title style
• http://www.cccco.edu
• Important Documentation
–
–
–
–
Quick Reference
Negotiation Report Instructions
System Documentation
System Requirements
• No more Installing plug-in
• No Administrative rights requirements
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Report Formats
Click to edit Master title style
• Print Version
– For administrators, faculty, students & PIOs
• Printing from the WWW
• Local Applications and Final Reports
• For exporting to
– word processor
– spreadsheet
• Data Download Version
– For Researchers, IS & Technophiles
• CSV For Export to:
– Excel
» SPSS, SAS or other Stat Package
» BRIO
» Access or other database software
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73
Data Download
Click to edit Master title style
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74
Negotiation Workbooks
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•
•
•
•
Instructions
Counts
Percentages
Charts
– Rates
– Counts
• Data work tables
75
Negotiation Tables
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Negotiation Charts
Click to edit Master title style
3P1 - Rates
100.00%
95.00%
91.4%
92.1%
92.7%
93.6%
94.0%
94.8%
95.0%
94.6%
93.3%
93.2%
93.8%
California Employment Rate (source: BLS)
90.00%
Grand Total
Female
83.32%
85.00%
84.07%
84.18%
84.60%
84.90%
84.08%
Est
82.53%
82.07%
80.99%
80.00%
81.14%
79.15%
Male
Non-traditional
Economically Disadvantaged
CA Empl Rate
75.00%
70.00%
1995-96 1996-97 1997-98 1998-99 1999-00
2000-1
2001-2
2002-3
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2003-4
2004-5
2005-6
est
77
2P1 - Counts
140,000
Fee increases
seemed to have
the impact starting
in 2002-3
academic year.
120,000
114,362
100,000
104,203
93,319
80,000
88,227
106,925
96,833
92,159
70,296
69,356
68,890
69,700
62,140
60,000
50,507
44,245
40,000
32,438
118,405 117,427 119,035
39,790
41,990
40,881
42,100
45,166
60,376
46,101
64,125
48,028
68,337
50,172
Es
72,572
Es
52,296
30,963
20,000
fees increase
Sp 2003
from $11 - $18
CA hits
6.6% high
unemp rate
Jan 04
2001-2
2002-3
2003-4
2004-5
2005-6
est
fees increase
Fall 2004
from $18 - $26
0
1995-96 1996-97 1997-98 1998-99 1999-00 2000-1
Total
50,507
44,245
70,296
69,356
68,890
69,700
62,140
60,376
64,125
68,337
72,572
Success
32,438
30,963
39,790
41,990
40,881
42,100
45,166
46,101
48,028
50,172
52,296
All CCC Awards
88,227
93,319
92,159
96,833 104,203 106,925 114,362 118,405 117,427 119,035
Est SP
23,991
25,362
34,210
36,598
36,090
36,483
38,287
Program Year
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38,394
40,004
43,589
46,604
Total
Success
All CCC Awards
Est SP
Although CCs are
helping more
people succeed
(including special
population
students), the
numbers of
students leaving the
system without a
certificate or degree
is increasing at a
higher rate.
Report Structures
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• Negotiation Workbooks
• Forms
• Perkins IC - Local Application
• Perkins IC - Final Report
• Summaries
– All five Indicators on one page
• Answer Sheet Style
• Detailed
– Percents and counts
– Detailed breakouts for each Indicator component
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CI Report Contents
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• CI Reports
– State, District, College
– 2-4-6 digit TOP
– Special Populations breakouts
– Identified on each report
• Performance below negotiated levels
– Performance below is highlighted
– Low numbers (denominator < 10)
• Blue-italics
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CI Contents (continued)
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1. Summary
•
•
•
College, District & State
Identifying Low Performance & Low Numbers
Comparing Performance across Programs
2. Detailed
•
•
•
•
Program Area (6 digit TOP)
Three Year Trends
Identifying Low Performance areas
Comparing Performance within Programs
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Report Examples
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• Final Report Form
• College by TOP Form
• Summary – College
– Summary - 5 digit TOP
• Summary – Detail
• Core 2 – Completions
– Core 2 - 5 digit TOP
• Course Voc Status/SAM Code
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Negotiation Report Contents
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• District, College?
• Special Populations breakouts
• Numerators, Denominators, & Rates
• Charts for analysis
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College Local App -Final
Report Form
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Dist Local App - Final Report
Form
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Final Report Form
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College by TOP Form
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Summary - College
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Summary – College 5 Digit
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Summary - Detail
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Core 2 - Completions
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Core 2 - Completions 5 digit
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Course Voc Status/SAM Code
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Using the Data
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• Negotiate or accept state-adjusted levels
– Trends over time for your college
– By program, special population, Tech Prep
• Workshops, Committees & Faculty Information
– Circulate to faculty for their use & input
• Factor in allocation decision-making
for Local Plans
– Supplement MIS data with
your own knowledge and follow-up of students
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Practice using the Data
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Negotiation Exercise:
• Review FAUPL Worksheet
• Walk through common scenarios
• Review the pre-printed report for a sample
college
• Conduct a guided practice using first
indicators
• Negotiate or Accept State Targets
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Faupl
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96
Negotiation Workbook
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97
Discussion
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• Improving Session Content:
– Order – Negotiations earlier or later
– Detail
– Strengthen funding ties or are sanction threats
sufficient?
– Other?
– Resources: JSPAC, IWITTS, NAPE
Chuck Wiseley, cwiseley@cccco.edu, 916.327.5895
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