DESK AUDIT - Bureau of Indian Education

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DESK AUDIT
INDICATORS 11 AND 13
Bureau of Indian Education
Division of Performance and Accountability
WebEx
October 18, 2011
What is a Desk Audit?
A Desk Audit refers to a review of data done from the SEA
(DPA) rather than onsite at the LEA (school). It refers to data
that can be examined using an electronic database or data sent
to the SEA electronically. This term may also refer to review of
monitoring data sent to the SEA in hard copy.
Why a Desk Audit?
 DPA has revised it’s Special Education Integrated
Monitoring Process (SEIMP) to include desk audits
 Required monitoring priorities includes child find
and the system of transition services (616)(a)(3)(B)
 Indicator 11 and Indicator 13 are compliance indicators and
must be at 100% as defined in the State Performance Plan
(SPP)
 DPA has to report this data annually to the Office of Special
Education Programs (OSEP)
Indicator 11 – Child Find
 Percent of children who were evaluated within 60 days
of receiving parental consent for initial evaluation or, if
the State establishes a timeframe within which the
evaluation must be conducted, within that timeframe.
 Consent to Eligibility Determination - 60 calendar days
Definitions for Indicator 11
 An initial evaluation refers to the first complete assessment to
determine if the child has a disability under the IDEA and the
nature and extent of special education and related services
that the child requires.
 Parents have the right to withdraw their child from special
education and related services (revoke consent for special
education and related services). After revocation, a parent
always maintains the right to subsequently request an initial
evaluation to determine if the child is a child with a disability
who needs special education and related services. Thus the 60
day timeline applies.
 When a student transfers in from another state, the
school must provide the child with FAPE (including services
comparable to those described in the child’s IEP from the
previous public agency), until the new public agency


Conducts an evaluation pursuant to CFR 300.304 through
300.304 *(if determined to be necessary)
Then the 60 day timeline is applicable
CFR 300.323(f)(1)
*emphasis added
 Parent’s InformedWritten Consent
 Consent means:
 The parent has been fully informed in his or her native language or other
mode of communication of all information relevant to the activity for
which the consent is sought
 The parent understands and agrees in writing to the activity for which
his or her consent is sought, and the consent describes that activity and
lists the records (if any) that will be released and to whom
 The parent understands that the granting of consent is voluntary and may
be revoked at any time.
 The BIE Assessment Plan is the BIE form for documenting
the parent’s informed written consent.
 Eligibility Determination:
 After completion of the initial evaluation or reevaluation, the
school must compile all the evaluation data for review and
consideration to determine whether the child is a child with a
disability eligible for special education services
 A group of qualified professionals and the parent review the
collected evaluation data and make an eligibility determination
for the child
 It could be the IEP Team but it is not required that a full IEP
team make this decision
 The Team completes the BIE Evaluation Summary
Report or the SLD Determination Form
 60 Day Time Frame for Initial Evaluations
 Date of the written informed consent (BIE Assessment Plan)
to the date of the eligibility determination (Evaluation
Summary Report or the SLD Determination Form) is
within 60 calendar days.
 Two limited exceptions to the 60-day time frame:
 If the parent repeatedly fails or refuses to make the child available for
evaluation, the school is not bound by the time limit.
 When a child transfers to a school after the previous school has begun,
but not completed, an initial evaluation. The new school is not bound by
the 60-day time frame if it is making “sufficient progress” to ensure
prompt completion of its initial evaluation, and if the parent and new
school agree to a specific time when the evaluation will be completed.
Note: Refer to §300.304(c)(5) for the coordination between schools.
NASIS Special Education Module
 Memorandum to all Line Offices and Schools dated
February 2009 states:
 “After training is completed, the use of the NASIS
special education forms will be required for all BIE
funded schools.”
 “Primarily, the data base will allow the DPA to
collect data for specific reports sent to the United
States Department of Education, Office of Special
Education and Rehabilitative Services, Office of
Special Education Programs.”
DPA User Group and User Accounts
 Memorandum dated November 23, 2010 to all Line
Offices and schools states:
 “Therefore, the DPA will begin desk audit activities
as part of the data collection and monitoring
procedures.”
Desk Audit Notification
 Memorandum dated September 28, 2011 to school
administrators and school special education
coordinators:
 Informs schools of desk audit beginning November
15, 2011
 Attaches Indicator 11 sample data collection form
(Timely Initial Evaluation for SY 2010-2011)
for schools to submit by November 10, 2011 to the
DPA
Indicator 11 Next Steps:
 DPA will verify the information submitted by the
schools
 How?
 Check the Assessment Plan of the student for date
of consent and signature to compare with the
submitted form
 Check the Evaluation Summary Report or the
Specific Learning Disability Determination form
for the date of Eligibility Determination and
compare with the submitted form
Indicator 11 tips
 Schools should ensure that the parental consent page is
signed, dated and scanned into the NASIS module
 Refer to the updated NASIS Special Education Process
Guide dated March 11, 2011 for instructions on how to
upload signature pages (required for Indicator 13 also)
 Process Guide can be accessed at the following website:
 www.bie.edu
 NASIS link, NASIS training
After Eligibility Determination
 During the evaluation process, the school should have
indicated the child’s Special Ed Status in the NASIS
enrollment tab as 02: Being Evaluated
 Once the determination is completed, the school needs
to change the child’s Special Ed Status in the NASIS
enrollment tab to:
 01: Regular Ed – Not Receiving Services or
 03: Receiving Services
Indicator 13 – Secondary
Transition Requirements (8)
(from the SPP)
 Percent of youth aged 16 and above with an IEP that
includes (1) appropriate measureable post secondary
goals that are (2) annually updated and based upon an
(3) age appropriate transition assessment, (4)
transition services, including (5) courses of study, that
will reasonably enable the student to meet those
postsecondary goals, and annual IEP goals related to
the student’s transition services needs.
Transition continued…
 There also must be (6) evidence that the student was
invited to the IEP Team meeting where transition
services are to be discussed and evidence that, (7) if
appropriate, a representative of any participating agency
was invited to the IEP Team meeting with the prior
consent of the parent or student who has reached the
(8) age of majority.
Indicator 13 Tips
1. Post secondary goals – describe activities
AFTER high school
2. Updated annually – to verify, we look at
previous IEPs, if this is the first transition one,
answer is NA
3. Transition Assessment – refer to the name of the
assessment used
4. Transition services – what the school is doing
while the student is still in high school
Indicator 13 continued…
5. Courses of study – indicate classes you think the student will be
taking until completion of high school.
6. Evidence student invited (scan the signature page of attendees).
If student not at meeting, scan the Meeting Invite form with
‘student’ circled (Parent/Student/Guardian).
7. Usually, NA, is marked. If there is evidence that an outside
agency was invited or attended the meeting, we look for the
form, titled ‘Permission for Consent Prior to Inviting Agencies
Related to Transition’, a simple form in NASIS.
8. If student signs for age of majority for the first time, scan that
page; if student signed in a previous IEP, make a note of that in
that space on the IEP or in the meeting notes.
Indicator 13 Process – 2 steps
1. Verify that corrections have been made from the spring 2011
findings, based on the CAPs submitted in June.
2. Review different files to ensure the school is following the
specific regulatory requirements.
3. If new non-compliances are identified, school will receive
written notification by December 31, 2011, with instruction
on the process.
More Indicator 13 Resources
 Refer to the BIE website for further secondary transition
information:
 www.bie.edu
 Programs Link
 Special Education
 Special Education Academy 2011
o Transition PPT
 News Link
 Newsletters
 Secondary Life Transitions
o Fall 2010 – first page, (info on item #7)
Notification of Findings –
Indicator 11 & 13
 For Indicator 11, by December 31, 2011 schools will
be notified of the results of the desk audits with
instructions on completing their Corrective Action
Plan if non compliance are found.
 For Indicator 13, by December 16, 2011 schools will
be notified of the results of the desk audits.
Contact Information
 Indicator 11
 Connie Albert, 505 563-5180,
connie.albert@bie.edu
 Indicator 13
 Sally Hollow Horn, 505 563-5276,
sarah.hollowhorn@bie.edu
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