NC DPI Title III Monitoring Plan Page 20 of 21 January, 2015
Monitoring Plan 2014-15
Title III, Part A: English Language Acquisition, Language Enhancement, and Academic Achievement
The North Carolina Department of Public Instruction (NCDPI), together with the US Department of Education and the Office of Civil Rights (OCR), is charged with the responsibility of enforcing Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, or national origin. In Lau v. Nichols, the U.S. Supreme Court affirmed the U.S. Department of Education's May 25, 1970 Memorandum that directed LEAs to take steps to help English Language Learners overcome language barriers and to ensure that they can participate meaningfully in the educational programs.
The Elementary and Secondary Education Act (ESEA) Title III, Part A requires the State Educational Agency (SEA) to monitor the implementation of Title III program requirements and the expenditure of federal funds by all subgrantees. Monitoring Title III at the local level ensures compliance with regulations and assures the quality of the program and the instructional delivery being utilized with English Language Learners.
Title III, Part A provides supplemental financial assistance to States and eligible LEAs to develop and enhance their capacity to provide high-quality instructional programs designed to prepare limited English proficient children and immigrant children and youth to enter all-English instructional settings. Title III assists States in helping Local Educational Agencies (LEAs) increase their capacity to establish, implement, and sustain language instructional educational programs for limited English proficient students - “ The purposes of this part , Part A, are to help ensure that children who are limited English proficient, including immigrant children and youth, attain English proficiency, develop high levels of academic attainment in English, and meet the same challenging State academic content and student academic achievement standards as all children are expected to meet.” (Title III, §3102)
I. DEFINITION AND PURPOSE OF MONITORING
Monitoring is the regular and systematic examination of an LEA/Charter’s administration and implementation of a Federal education grant administered by NCDPI. Monitoring emphasizes accountability for using resources wisely in educating and preparing North Carolina’s students. As a result of monitoring, NCDPI is able to gather data about local needs and use that data to design technical assistance initiatives and statewide initiatives. Thus, monitoring serves not only as a means for helping LEAs/Charters achieve high-quality implementation of educational programs, it also helps NCDPI to be a better advisor and partner with LEAs/Charters in that effort.
NCDPI’s monitoring process will include technical assistance through onsite monitoring visits, targeted assistance for identified needs, and/or LEA/Charter self-evaluation. Monitoring outside of the scheduled cycle may be arranged as needed if an LEA/Charter has serious or chronic compliance issues or has unresolved issues identified during the monitoring process. The state wide monitoring plan will be reviewed and revised annually and/or as needed.
II. MONITORING INDICATORS
The content of NCDPI’s monitoring is based on States’ responsibilities to provide guidance and support to LEAs/Charters and schools based on the requirements of the ESEA. Monitoring LEA/Charter implementation of Title III means closely examining LEA/Charter policies, systems, and procedures to ensure school compliance with federal and state statutes and regulations.
NCDPI uses monitoring indicators to determine the degree and quality of implementation of Title III programs. Following the federal monitoring plan, indicators have been developed in each of the four monitoring areas (Standards, Assessment and Accountability; Instructional Support; and Fiduciary). The use of such criteria ensures a consistent application of these standards across monitoring teams and across LEAs/Charters. The published indicators provide guidance for all LEAs/Charters regarding the purpose and intended outcomes of monitoring by describing what is being monitored and providing the criteria for judging the quality of implementation (acceptable evidence).
Please note that the indicators are written broadly to cover all the requirements of each topic. Examples of documentation and evidence that LEAs/Charters can provide to show compliance with these requirements are listed for each indicator.
III. THE MONITORING PROCESS
Monitoring LEAs’/Charters’ implementation of Title III provides an opportunity to examine how LEAs/Charters have instituted policies, systems, and procedures to ensure LEA/Charter and school compliance with the statutes and regulations. Monitoring serves many purposes:
§ Formalizes the shared responsibility of North Carolina and the LEAs/Charters to improve student achievement and close the achievement gap in order to have all students reach proficiency.
§ Provides a vehicle to North Carolina’s legal responsibility to monitor the implementation of Title III.
§ Leverages support for broad scale implementation in all districts that receive these funds.
§ Ensures that school districts provide critical information to parents that enable them to be full partners in their children’s education.
§ Provides data that inform technical assistance that supports North Carolina’s and school districts’ efforts to improve teaching and learning.
§ Provides data to inform state policy and leadership activities.
A. Description of the Monitoring Process
North Carolina’s monitoring plan involves a 3-tiered approach; Tier I is Annual Self-Evaluation, Tier II Needs Based Monitoring, and Tier III Onsite Monitoring. This approach helps LEAs/Charters build capacity to improve student achievement and ensure program compliance. A risk-based analysis of program components and characteristics is used to identify subgrantees for Tier II and Tier III monitoring. Risk factors include:
· size of subgrantee grant award,
· percentage of LEP students,
· program performance based on meeting AMAOs 1 and 2,
· student subgroup academic performance based on AMOs for LEP students,
· change in program or leadership, and
· the length of time since previous onsite monitoring.
Tier I – Annual Self-Evaluation
Tools are provided to guide subgrantees’ evaluation of program compliance.
· An annual evaluation survey allows LEAs/Charters to evaluate, summarize and report the effectiveness of program components, including supplement not supplant provisions, use of funds for technology purchases and the draft LIEP.
Tier II – Needs Based Monitoring
Direct technical assistance is provided to subgrantees with specific identified risks. The risks may include:
· Provisions for supplementing, not supplanting services for English language learners,
· Descriptions of LIEP services provided,
· Appropriateness of expenditures for technology,
· Failure to test all LEP students enrolled during the 2013 English language proficiency testing window,
· Failure to meet the 95% participation expectation on state reading and mathematics end-of-grade/end-of-course tests for LEP students,
· New leadership for Title III subgrantees,
· Challenges with data integrity, and/or
· Any other critical needs as revealed from Title III Application, Improvement Plan or State Technical Assistance.
Tier II monitoring may occur any time during the school year. LEAs/Charters will be notified on an individual basis.
Tier III – Onsite Monitoring
LEAs/Charters are selected for onsite monitoring based upon the annual risk-based assessment of subgrantees. During the site visit, the NCDPI Monitoring Team will review documentation, observe classrooms and interview LEA/Charter staff, principals, teachers, parents, and other stakeholders. This multi-level interview strategy will allow the monitors to gather information from a variety of perspectives and better evaluate the impact of the LEA’s/Charter’s administration on the implementation of Title III at the LEA/Charter and school levels. This strategy will also allow the monitoring team to conduct a thorough review of the indicators, and acquire a more complete picture of the degree of program implementation.
1. Preparation for Onsite Monitoring
LEAs to be monitored will be contacted within one month of the official release of AMAO data. LEA/Charter LEP Coordinators will be contacted by DPI Title III Staff, followed by an official letter to LEA Superintendents. A conference call will be scheduled with the LEA/Charter Title III Coordinator prior to the visit to ensure LEA/Charter staff is familiar with the monitoring process including a review of the monitoring indicators, guidance regarding documentation required during the monitoring visit, and the two-day monitoring schedule. Documents to assist the LEA/Charter in preparing for the onsite visit can be downloaded at http://eldnces.ncdpi.wikispaces.net/LEP+Coordinatorsunder under Title III Monitoring.
Prior to the monitoring visit, LEA/Charter staff will compile specific documentation providing evidence to address the monitoring indicators. Ideally this collection of documentation supporting compliance with Title III and state and local regulations should be an ongoing process.
2. Onsite Monitoring Process
The DPI Monitoring Team, typically consisting of a DPI Title III Consultant (or designee) and an LEA/Charter Representative, conducts the onsite monitoring by reviewing documentation, observing classrooms and interviewing LEA/Charter staff, principals, teachers, parents, and other stakeholders and collecting other evidence as indicated on the North Carolina Title III Monitoring Instrument and Report.
Indicators are rated on a scale of 1-3. The rating NA is only appropriate for item 2.3, when the LEA/Charter does not receive significant increase Immigrant Funds (PRC 111) and 2.4 for Charter Schools who do not serve Private Schools
i. A rating of “3” is optimum. Meets requirement.
ii. A rating of “2” indicates that a requirement is met in a minimal manner and that improvement is needed.
iii. A rating of “1” indicates that a requirement has not been met and that corrective action must be taken.
An exit conference is held at the conclusion of the onsite review for the purpose of reporting the preliminary results of the monitoring visit to the LEA/Charter. Typically, the DPI monitoring team meets with the LEA/Charter Title III Coordinator and the Superintendent or Superintendent’s designee to discuss potential findings and recommendations that the team will likely cite in the monitoring report. The team will summarize the visit’s activities, the potential findings and recommendations, and timeline for developing the monitoring report. The team also responds to questions posed by the LEA/Charter (both related to process and content). The team leader emphasizes that the information presented at the exit conference is preliminary, and explains that during the development of the monitoring report, the team will continue to review data and contact the LEA/Charter for additional information, as required.
The NCDPI Title III Monitoring Team will prepare a written report within 30 business days of the onsite monitoring visit. The final report will be sent to the LEA/Charter from the NCDPI Chief Academic Officer. The monitoring letter and report will be mailed to the LEA/Charter Superintendent. In conjunction with this mailing the DPI ESL Consultant will e-mail the letter and report to the LEA/Charter LEP Coordinator. The entire process may take up to 3 months. Within 30 business days from receipt of the Monitoring Report, the LEA/Charter will submit a written response with proposed resolutions to any findings from the monitoring visit to the DPI ESL Consultant. The DPI ESL Consultant will respond to the proposed resolutions as to whether or not they are satisfactory. If the proposed resolutions are not satisfactory, the DPI ESL Consultant will provide technical assistance to the LEA/Charter so that acceptable resolutions are identified.
North Carolina Title III Monitoring Instrument and Report
Tier III - Onsite Monitoring Instrument and Report
LEA/Charter: /Rating Scale
1 - Does Not Meet Requirements2 - Meets Requirements But Improvements Needed
3 - Meets Requirements
NA* - Not Applicable
*NA is only allowable on 2.3 for LEAs/Charters who do not receive Immigrant Funds and on 2.4 for Charter Schools who do not serve Private Schools
Contact Person:
e-mail:
Phone:
Date(s) Conducted:
Date of Report:
Members of monitoring team: (Names may be added, as appropriate.)
(Printed name) (Position) (Signature)
(Printed name) (Position) (Signature)
Note: The NC Department of Public Instruction is required to monitor all federal programs. The State shall advise subgrantees of requirements imposed on them by Federal laws/regulations and monitor the activities of subgrantees as necessary to ensure that Federal awards are used for authorized purposes. (Office of Management and Budget Circular A-133) References for Program Requirements: Title III Language Instruction for Limited English Proficient Students Public Law 107-110, Sections 3001 – 3304; EDGAR; OMB Circular A-87; ED Compliance Supplement; Office of Management and Budget Circular A-
Monitoring Indicators for Title III
Standards
1.1: English Language Proficiency (ELD) Standards. [§3113]Guiding Questions / Acceptable Evidence / Compliance Indicator(s) Rating
Questions:
§ Has the LEA/Charter implemented the State established ELD Standards that are derived from the four domains of speaking, listening, reading, and writing and cover grades K-12?
§ Has the LEA/Charter participated in State training and/or technical assistance for implementation of State ELD Standards?
§ Has the LEA/Charter disseminated the ELD Standards to content and ESL teachers, and provided training and technical assistance on implementation of the standards?
/ Possible Documentation:
Workshop announcements
Workshop agendas
Workshop evaluations
Sign-in sheets from workshops
Teacher reflections
Professional Development plan on ELD Standards
Evidence of continued application of training
Pacing guide/documentation tool noting use of ELD Standards (WIDA Standards)
Evidence of participation in State training and/or technical assistance for implementation of State ELD Standards
Staff describes how the State ELD Standards have been implemented at the district level, including professional development provided to teachers and other staff, and curriculum development activities
Other relevant documents/resources noting
evidence of ELD Standards implementation / Rating:______
For a rating of ‘2’, list the change(s) suggested to be implemented.
For a rating of ‘1’, list the action(s) required to be taken to meet compliance requirements.
Monitoring Indicators for Title III
Assessment and Accountability
1.2: English Language Proficiency (ELP) Assessment. [§3113 and §3116(b)(3)(A,B,C)]Guiding Questions / Acceptable Evidence / Compliance Indicator(s) Rating
Questions:
§ Does the LEA/Charter have a process for verifying number and percentage of Title III LEP students tested on ELP assessment and method for reporting results to the State?
§ Describe the process for providing technical assistance to schools in your jurisdiction on how to administer the ELP assessment.
§ What is the LEA’s/Charter’s process for initial identification and placement of LEP students? / Possible Documentation from previous and current school year:
W-APT score data
ACCESS testing schedules
Documentation of LEA/Charter process for identification and placement
Documentation of number of students not tested under state ELP Assessment by grade including reasons for non-assessment
Other relevant documents/resources / Rating:______
For a rating of ‘2’, list the change(s) suggested to be implemented.
For a rating of ‘1’, list the action(s) required to be taken to meet compliance requirements.
Monitoring Indicators for Title III