All State and local N or D programs will be monitored by the U.S. Department of Education within the next three years. NDTAC's "Monitoring 101" guide is meant to help States prepare for Federal monitoring of State Title I, Part D programs. Use the outline below to skip ahead to a specific section of the guide or simply scroll down.

1. Introduction
   1. What is monitoring?
   2. Why does ED monitor State programs?
2. Background
   1. Who is monitored?
   2. What do monitors do before, during, and after a visit?
   3. When and how often are States monitored by ED?
3. Evaluation
   1. What criteria do monitors use to evaluate programs?
   2. What are “monitoring indicators”?
   3. What information should States be prepared to provide to monitors?
4. Followup
   1. What does a monitoring report include?
   2. What kind of followup is required of the State?
   3. What happens if significant issues are identified during monitoring?
   4. Are monitoring results used in any other way?
   5. Where can States get help with monitoring preparation and followup?
5. Resources
   1. Example of Monitoring Indicator Summary Table
   2. Example of monitoring finding, citation, and required action

Note: Much of the information in this guide is drawn from the Monitoring Procedures Handbook published on the Department of Education Web site.

I. Introduction

A. What is monitoring?

The U.S. Department of Education (ED) defines a monitoring review as “the regular and systematic examination of a State’s administration and implementation of a Federal education grant, a contract or a cooperative agreement administered by ED.”

In other words, a monitoring review measures how well States are able to administer federally-funded education programs by using a set of consistent criteria, or “indicators,” taken from the legislated grant requirements.

Title I, Part D, along with a number of other programs including Title I, Part A; Title I, Part B; and Title X, Part C, are all located within the Student Achievement and School Accountability (SASA) programs office, and all are part of SASA’s monitoring process.

B. Why does ED monitor State programs?

Part D programs, like all SASA programs, are monitored in order to ensure that all children have a fair, equal, and sufficient opportunity to obtain a high-quality education. Monitoring assesses the extent to which States provide leadership and guidance for local education agencies (LEAs), schools, and/or institutions in implementing policies and procedures that comply with the provisions of the N or D statutes and regulations.

Monitoring formalizes the relationship between ED and the States. Primarily, monitoring is done to ensure State and local accountability for using resources wisely in the venture of educating and preparing our Nation’s students. The use of monitoring indicators clarifies for States, and for ED monitors, the critical components of the accountability process and provides a performance standard against which State policies and procedures can be measured. As a result of monitoring, ED is able to gather accurate data about State and local needs and use that data to design technical assistance initiatives and national leadership activities.

Thus, monitoring serves not only as a vehicle for helping States to achieve high quality implementation of educational programs; it also helps ED to be a better advisor and partner with States in that effort.

II. Background

A. Who gets monitored?

Direct recipients of Federal grants are monitored; in other words, State education agencies (SEAs) and LEAs who receive Subpart 1 and 2 monies, respectively. However, evidence of program compliance will also be required from the State agencies (SAs) who receive grants through their SEA. This allows monitors to ensure that SEAs are providing adequate guidance and support to their grantee SAs. During monitoring, staff from SEAs, SAs, and LEAs may be contacted directly and interviewed by ED staff.

As part of this process, monitors will also interview principals, teachers, parents, and other stakeholders, both individually and in groups. This multilevel interview strategy allows monitors to gather information from a variety of perspectives and better evaluate the impact of the State’s administration on the implementation of the program at the LEA and school level.

B. What do monitors do before, during, and after a visit?

Before the onsite monitoring visit, a State contact on SASA’s staff is assigned to do “desk monitoring” and document review. As part of his or her desk monitoring, the State contact routinely gathers and analyzes data and information relevant to monitoring areas within the four Title I programs that SASA evaluates. He or she collects this information primarily through Web-based searches and document analysis. Through this process, SASA is able to continually track State progress in implementing the statutes and regulations.

The team that actually conducts the monitoring site visit is typically composed of five to six SASA staff members. One of the team members is designated as the team leader. When a State is identified for an onsite monitoring visit, the State contact briefs the monitoring team based on the content of the desk review. This briefing provides background and contextual information and highlights areas of potential interest or concern. As needed, the State contact also provides briefings to SASA and other senior leadership.

State contacts and site visit teams work together throughout the monitoring process, including planning, research, onsite review, debriefing, and report writing.

Once the State contact has briefed the monitoring team, the team determines what additional SEA materials need to be collected. A thorough analysis of relevant documents is crucial to conducting an effective and efficient monitoring visit; document analysis helps team members identify important issues and questions before the visit, ensuring focused and productive interviews during the visit.

The actual visit typically takes 4–5 days. During the site visit, SASA staff review documentation that was not available prior to the trip and interview SEA and LEA staff. Typically, monitoring activities during the first day will be concentrated at the SEA level. The next one or two days may be at spent at facilities. On the final day monitors usually review any additional documentation, conduct closing interviews, and hold an exit conference with SEA level staff. After the onsite monitoring is completed, the team conducts two to three conference calls with LEAs across the State to complete its data collection. This strategy allows the monitoring team to confirm information gathered during the site visit and acquire a more complete picture of the degree of program implementation across the State.

C. When and how often are States monitored by ED?

States are monitored onsite on a regular cycle; each cycle begins on October 1 and concludes September 30, with onsite visits occurring during all months except for July and August.

SASA is required to monitor each State once every 3 years. However, SASA may monitor more often if, for example, a State has serious or chronic compliance problems.

III. Evaluation

A. What criteria do monitors use to evaluate programs?

SASA’s monitoring is based on States’ obligation to provide guidance and support to LEAs as required by the No Child Left Behind Act (NCLB). Those requirements, found in the statute and the regulations, are framed by the keystone principles of NCLB: accountability, choice, parental involvement, and the use of scientifically-based research or “what works.” Monitoring States’ implementation of SASA programs means taking a close look at how States have instituted policies, systems, and procedures in order to ensure LEA and school compliance with the statute and regulations. The requirements and principles are embedded in the three monitoring areas:

1. Assessment and accountability
2. Instructional support
3. Fiduciary responsibilities

SASA staff have created “indicators” for their programs in each of these three areas, which help them consistently measure how well States are doing.

B. What are monitoring indicators?

ED uses “monitoring indicators” so that all monitors have clear and consistent criteria to determine the degree of implementation of SEA programs and activities. The use of such criteria ensures a consistent application of these standards across monitoring teams and across States. The published indicators provide guidance for all States regarding the purpose and intended outcomes of monitoring by describing what is being monitored (the “critical element”) and providing the criteria for judging the quality of implementation (acceptable evidence). The monitoring indicators for Part D map to the requirements of the Title I, Part D legislation. SEAs are monitored on compliance with both Subpart 1 and Subpart 2 of Title I, Part D.

C. What information should States provide to monitors?

SEAs, SAs, and LEAs are required to provide evidence that they are addressing the critical elements for indicators in each of the three previously mentioned areas: assessment and accountability, instructional support, and fiduciary responsibilities.

Monitors request that States provide “acceptable evidence” by submitting documents and participating in interviews with SASA staff. Documentation requested from States can include:

• State applications for funding
• Procedures and guidance for SA applications under Subpart 1
• Procedures and guidance for LEA applications under Subpart 2
• Technical assistance provided to SAs and LEAs
• State oversight and monitoring plans and activities
• SA and LEA subgrant plans
• Local evaluations for SA programs
• Local evaluations for LEA programs

Click on the headings below for examples of specific elements and evidence required of States in the three identified areas.

1. Assessment and Accountability: This chart includes examples of critical elements and adequate evidence used to measure assessment and accountability for Subparts 1 and 2.
   
2. Instructional Support: This chart includes examples of critical elements and adequate evidence used to measure instructional support for Subpart 1.
   
3. Fiduciary Requirements: This chart includes examples of critical elements and adequate evidence used to measure fiduciary requirements for Subparts 1 and 2.

IV. Followup

A. What does a monitoring report include?

The SASA team provides a comprehensive monitoring report to the SEA within 30 business days of the onsite visit. The report contains recommendations, findings, and required actions that, together, provide an analysis of the implementation of Title I, Part A; Even Start; N or D; and Homeless implementation throughout the State. Each member of the monitoring team drafts individual sections, and the team leader oversees the development of the final report.

Each report includes an Indicator Summary Table that lists the indicators and the status of that indicator. Each indicator will receive one or more of the following three status assessments:

1. Met Requirements. This means that the State has fulfilled all the requirements for this indicator, and no actions are required of the State to address this issue.
   
2. Recommendation. This means that monitors recommend that a certain action be taken to improve programming; however, the State is not required to implement the recommendation.
   
3. Finding. This means that the State is not fulfilling a requirement of the Part D law. The monitoring report will cite the part of the law that is not being upheld, and state the required action to be taken by the State to address the issue. In this case, the State must take steps to rectify the problem.
   
   » View a sample Indicator Summary Table.

B. What kind of followup is required of the State?

Upon receipt of the report, the SEA has 30 business days to respond to any findings and required actions. When the monitoring team determines whether the response indicates that the SEA has taken steps to ensure full compliance in the identified areas, SASA sends a letter to the State approving its proposed actions.

SASA staff then reviews the SEA’s response and determines which areas are acceptable and which will require further documentation of implementation. SASA will allow 30 additional business days for receipt of further documentation. If corrective actions require longer than the prescribed 30 days, ED will work with the SEA to determine a reasonable timeline.

If necessary, the State can request a followup review within the year. The SASA State Contact can also recommend a followup review as to why required actions have not been adequately implemented and to provide technical assistance as necessary. Followup monitoring visits occur during the summer months subsequent to a State’s onsite review.

» View a sample monitoring “finding,” along with actions required of the SEA.

C. What happens if significant issues are identified during monitoring?

When SASA identifies significant compliance issues in a State, it works closely with that State to develop and implement plans for corrective action. In some instances, SASA may determine that a followup monitoring visit is necessary to verify implementation of a State’s actions resulting from its plan for correction.

States with significant compliance findings will also have conditions attached to the grant award for that program. Usually this means that the grant is subject to the resolution of issues identified by ED during its monitoring visit. Conditions are normally attached only after the State has had the opportunity to respond to the monitoring report and outline its corrective action plans. The issue is resolved once the State submits information or evidence of the implementation of the corrective actions it has taken and ED concludes that the actions taken address all the findings in an appropriate manner.

D. Are monitoring results used in any other way?

SASA maintains a database of all site visit reports by monitoring cycle. From the database, SASA analyzes the findings, recommendations, and commendations from each report in order to obtain a more complete picture of implementation trends nationwide. These analyses will inform efforts to provide leadership activities and technical assistance to States on a regional and national level.

E. Where can States get help with monitoring preparation and followup?

The NDTAC provides assistance to States with questions on how to prepare for monitoring visits and addresses findings and recommendations issued by Federal monitors. Our Web site, http://www.neglected-delinquent.org, provides information on Title I, Part D law, as well as materials and resources in areas such as Teacher Quality, Special Education, State Reporting, Neglected Students, and more. Check out our Self-Study Toolkits for information on how facilities can improve collection and use of data, comprehensive assessment of students, academic assessment of students, and transfer and maintenance of student records.

The NDTAC is also available to address specific requests by States. Contact your NDTAC State liaison with questions or comments about monitoring or other areas relevant to Title I, Part D.

In addition, much of the language and information in this guide is taken from ED’s Web site. Take a look at that site for an overview of Title I Monitoring, examples of State Monitoring Reports, and information from a Web cast on monitoring Title I, Part A.

V. Resources

You can take a look some of the monitoring results of the following programs authorized by the Elementary and Secondary Education Act of 1965 (ESEA), as amended by NCLB: Title I, Part A; Title I, Part B, Subpart 3; Title I, Part D; and Title X, Part C, Subtitle B, of the ESEA (also known as the McKinney-Vento Homeless Education Assistance Improvements Act of 2001).

• 2004-2005 Monitoring Cycle
• 2003-2004 Monitoring Cycle

A. Example of Monitoring Indicator Summary Table

The chart below is an example of the Monitoring Indicator Summary Table that will be included in your monitoring report. The page numbers indicate where further description of the recommendation, finding, or required action can be found.

Summary of Title I, Part D Monitoring Indicators

Monitoring Area 1, Title I, Part D: Accountability
Indicator Number	Critical Element	Status	Page
Indicator 1.1	The SEA has implemented all required components as identified in its Title I, Part D (N or D) plan.	Met Requirements	N/A
Indicator 1.2	The SEA ensures that SA’s plans for services to eligible students who are N or D meet all requirements.	Finding	31
Indicator 1.3	The SEA ensures that LEA’s plans for services to eligible students who are N or D meet all requirements.	Recommendation	31
Monitoring Area 2, Title I, Part D: Instructional Support
Indicator Number	Critical Element	Status	Page
Indicator 2.1	The SEA ensures that institutionwide programs developed by the SA under Subpart 1 use the flexibility provided to them by law to improve the academic achievement of all students in the school.	Met Requirements	N/A
Monitoring Area 3, Title I, Part D: Fiduciary
Indicator 3.1	The SEA ensures each SA has reserved not less than 15 percent and not more than 30 percent of the amount it receives under Subpart 1 for transition services.	Met Requirements	N/A
Indicator 3.2	The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Title I, Part D program requirements.	Finding Recommendation	32

B. Example of monitoring finding, citation, and required action

Indicator 3.2. The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Title I, Part D program requirements.

Finding: ED staff found that SEA has not conducted compliance monitoring reviews for either Subpart 1 or Subpart 2 programs.

Citation: Section 1414 of the SEA plan contains assurances that programs assisted under Title I, Part D will be carried out in accordance with the State plan. The SEA is required to ensure that the SAs and LEAs receiving Part D subgrants comply with all applicable statutory and regulatory requirements. Additionally, Section 1426 requires the SEA to hold LEAs accountable for demonstrating student progress in identified areas. Finally, Section 9304(a) of the ESEA requires that the SEA ensures that programs authorized under the ESEA are administered with all applicable statutes, regulations, program plans, and applications.

Further action required: SEA must provide a plan to ED that indicates how it will implement a monitoring process that determines whether SAs and LEAs with Title I, Part D subgrants are complying with Part D requirements and carry out comprehensive monitoring to ensure that SAs and LEAs implement requirements.

1. Assessment and Accountability: The chart below includes examples of critical elements used to measure assessment and accountability for Subparts 1 and 2.

Part D, Subpart 1, Critical Element 1.1

Element 1.1: The SEA has implemented all required components as identified in its Title I, Part D (N or D) plan. What are the required components of the SEA State plan? For this information, take a look at Sec 1414(a) of the Title I, Part D law.

1.1 SEA Evidence Documentation Evidence that the SEA has developed and implemented a plan that includes program goals, objectives, and performance measures used to assess the effectiveness of the N or D program. Interview The SEA describes its plan and how it is used to guide the N or D program.

Part D, Subpart 1, Critical Element 1.2

Element 1.2: The SEA ensures that the SA’s plans for services to eligible students who are N or D meet all requirements. What are the requirements for SA plans? For this information, take a look at Sec. 1412(a), as well as Sec. 1414(a) and (c) of the Title I, Part D law.

1.2 SEA Evidence Documentation Evidence the SEA provides guidance to SAs on developing or revising Subpart 1 applications and plans. Evidence that the SEA has a written review process for awarding Part 1 subgrants to SAs. SEA provides evidence that SA Subpart 1 programs demonstrate that the programs address the intent and purposes of the N or D program. Interview The SEA describes guidance it provides the SA on developing or revising its N or D plan. The SEA describes the SA application and selection process for Subpart 1. The SEA describes how it reviews and evaluates the Subpart 1 plans.

1.2 SA Evidence Documentation SA plans contain the 19 required elements, including procedures, assurances, and descriptions of services. Evidence that the SA’s N or D program is supplemental to the required instructional program. Interview The SA describes the 19 required elements in its plan. The SA describes the overall school program, including length of school day.

Part D, Subpart 2, Critical Element 1.3

Element 1.3: The SEA ensures that the LEA’s plans for services to eligible students who are N or D meet all requirements. What are the requirements for LEA plans? For this information, take a look at the requirements for LEA applications (considered to be LEA plans) as detailed in Sec. 1423 and Sec. 1425 of the Title I, Part D law.

1.3 SEA Evidence Documentation Evidence that the SEA provides guidance to LEAs on developing or revising Subpart 2 applications and plans. Evidence that the SEA has a written review process to award Part 2 subgrants to LEAs. SEA provides evidence that LEA Subpart 2 programs demonstrate that the programs address the intent and purposes of the N or D program. Interview The SEA describes the guidance it provides the LEA on developing or revising its N or D plan. SEA describes the LEA application and selection process for Subpart 2. SEA discusses application and review process for LEA Subpart 2 funding, including eligibility determination based on “high numbers or percentages.”

1.3 LEA Evidence Documentation LEA plan contains the 13 required elements, including procedures, assurances, and descriptions of services. Evidence that the N or D educational program in the local facility or institution is comparable to the one the LEA operates in the school that such youth would otherwise attend. Evidence that agreements between LEAs and correctional facilities provide the 11 required activities. Interview LEA articulates how N or D program in the local facility or institution uses Subpart 2 supplemental funds to carry out activities, procedures, and policies that are stated in the plan submitted to the SEA.

Back to Indicators Overview

2. Instructional Support: The chart below includes examples of critical elements used to measure Instructional Support for Subpart 1.

Part D, Subpart 1, Critical Element 2.1

Element 2.1: The SEA ensures that institution-wide programs developed by the SA under Subpart 1 use the flexibility provided to them by law to improve the academic achievement of all students in the school. For more information on institution-wide programs, take a look at Sec. 1416

2.1 SEA Evidence Documentation Evidence that the SEA provides guidance to SAs on the intent and purpose of institutionwide programs and program requirements. Evidence that the SEA provides guidance to SAs on developing or revising institution-wide program plans. Interview The SEA describes its process for guidance, applications, approvals, and reviews for institutionwide projects. The SEA demonstrates knowledge about the process of combining funds in institution-wide programs.

2.1 SA Evidence Documentation The SA institutionwide plans include the eight required provisions, descriptions, and assurances. The SA ensures that institutionwide program schools maintain records that demonstrate that the program addresses the intent and purposes of the programs consolidated to support it. Interview The SA describes the institutionwide program and how it serves the needs of all students.

Back to Indicators Overview

3. Fiduciary Requirements: The chart below includes examples of critical elements used to measure Fiduciary Requirements for Subparts 1 and 2.

Part D, Subpart 1, Critical Element 3.1

Element 3.1: The SEA ensures each State agency has reserved not less than 15 percent and not more than 30 percent of the amount it receives under Subpart 1 for transition services. For more information about transition requirements, see Sec. 1414(a)(1)(B) and Sec 1418(a) and (b).

3.1 SEA Evidence Documentation Evidence of guidance or notification sent to SAs outlining requirements for reserving funds for transition services under Subpart 1. Interview SEA describes information and assistance provided to SAs on reservation requirements for transition services including: successful reentry, preplacement programs, worksite programs, and other postinstitution support services.

3.1 SA Evidence Documentation Evidence that the SA reserves the appropriate amount of funds as required for transition services. Evidence that transition services are included in the SA’s N or D application. Evidence the SA provides transition services. Interview Staff responsible for transition describe the transition plan and transition services provided to students in the N or D program.

Part D, Subparts 1 and 2, Critical Element 3.2

Element 3.2: The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Title I, Part D program requirements. For more details about subgrantee monitoring requirements, see Sec 1426 and Sec. 1431.

3.2 SEA Evidence Documentation Evidence the SEA monitors Subpart 1 and Subpart 2 programs, including: Established cycle of monitoring Copies of reports, corrective actions Monitoring policies and procedures Sample of letters, checklists, forms, etc. to SAs and LEAs Interview The SEA discusses monitoring process for Subparts 1 and Subpart 2 programs. The SEA discusses process for reviewing LEAs’ outcomes for students who are N or D and, where necessary, identifying LEAs and institutions for reducing or terminating Subpart 2 funding.

3.2 SA and/or LEA Evidence Documentation Evidence that the SA evaluates its N or D program to determine the program’s impact on students. Evidence that the LEA evaluates its N or D program to determine the program’s impact on student.s Evidence that the SA assesses the academic progress of students in correctional institutions or facilities. Evidence that the LEA assesses the academic progress of students in correctional institutions or facilities. Interview The SA and LEA discuss how it measures and reviews student progress in order to determine the impact of the N or D program.

Back to Indicators Overview

 

Published December 2005

Preparing for Federal Monitoring—Suggestions From States
What can you learn from States that have been monitored previously? Read this summary of the Department of Education’s April 2004 Title I Monitoring Web cast to learn 8 tips for readying your SEA for Federal monitoring.

Subgrantee Monitoring: How do States Monitor Their SAs and LEAs?
In this webinar Presenters Joe Hiznay, Dr. John Stewart, and Maggie Rivers presented on the process they go through in monitoring SA and LEA subgrantees in their respective States.

The Monitoring & Compliance Library
For additional resources related to monitoring, see NDTAC's Monitoring & Compliance library page.

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