# Previously-Identified Issues 

+-------------+---------------+----------------+-----------------------+
| **Issue**   | ## Sta        | **OSEP         | **Required Action**   |
|             | te Submission | Analysis**     |                       |
+=============+===============+================+=======================+
| [SPP        | In the SPP,   | The SPP did    | As part of the final  |
| Indicator   | page 22, the  | not contain    | Special Conditions    |
| 7]{         | State         | valid and      | Report due April 14,  |
| .underline} | indicated     | reliable data  | 2006, ODH/HMG must    |
| -           | that:         | necessary to   | provide:              |
|             |               | determine      |                       |
| Special     | -   "Lack of  | whether Ohio   | -   Current, valid    |
| conditions  |               | has made       |     and reliable data |
| attached to | documentation | progress in    |     regarding the     |
| Ohio's FFY  |     of        | ensuring       |     number of         |
| 2005 Part C |     informed  | compliance     |     children for whom |
| grant award |     clinical  | with the       |     initial           |
| required    |     opinion;  | 45-day         |     evaluations and   |
| Ohio to     |     failure   | timeline       |     assessments and   |
| submit data |     to        | requirements.  |     the initial IFSP  |
| de          |     complete  | The monitoring |     meetings were not |
| monstrating |     and       | indicators     |     conducted within  |
| that        |     document  | used to obtain |     45 days and       |
| evaluations |     the       | baseline data  |     identify          |
| and         |     required  | did not        |     separately any    |
| a           |     vision,   | measure        |     delays due to     |
| ssessments, |     hearing   | compliance     |     documented        |
| including   |     and       | with the       |     exceptional child |
| family      |     nutrition | requirements   |     or family         |
| a           |               | of 34 CFR      |     circumstances     |
| ssessments, |   screenings; | §§             |     outside the lead  |
| and the     |     and lack  | 303.321(e)(2), |     agency's control. |
| initial     |     of        | 303.322(e)(1)  |     Monitoring data   |
| IFSP        |     personnel | and            |     may be used if    |
| meeting     |     or        | 303.342(a). .  |     the data measures |
| were        |     providers |                |     all components of |
| completed   |     to        |                |     the 45-day        |
| within 45   |     conduct   |                |     timeline          |
| days from   |     hearing   |                |     requirement;      |
| referral    |     and       |                |                       |
| under 34    |     vision    |                | -   The State's       |
| CFR         |               |                |     analysis of the   |
| §§303       |   screenings" |                |     causes for delays |
| .321(e)(2), |     are root  |                |     in each county;   |
| 30          |     causes    |                |     and               |
| 3.322(e)(1) |     for       |                |                       |
| and         |     continued |                | -   Corrective        |
| 303.342(a). |     n         |                |     actions approved  |
|             | oncompliance. |                |     by the State      |
| OSEP's      |               |                |     (including data   |
| January 20, | ```{=html}    |                |     required by the   |
| 2006        | <!-- -->      |                |     State from the    |
| response to | ```           |                |     county to         |
| Ohio's      | -   The HMG   |                |     demonstrate       |
| Special     |     Advisory  |                |     correction) to    |
| Condition   |     Council   |                |     ensure correction |
| Progress    |               |                |     as soon as        |
| Report      |    identified |                |     possible, but no  |
| stated that |     an        |                |     later than one    |
| the         |     inability |                |     year after the    |
| indicators  |     to obtain |                |     State's           |
| reported do |     provider  |                |     identification of |
| not         |     reports,  |                |     the               |
| adequately  |     finding   |                |     noncompliance.    |
| measure the |     personnel |                |                       |
| Special     |     with the  |                | Failure to provide    |
| Condition   |               |                | data demonstrating    |
| re          |  certificates |                | compliance with 34    |
| quirements. |     required  |                | CFR §§303.321(e)(2),  |
| No one      |     to        |                | 303.322(e)(1) and     |
| indicator   |     conduct   |                | 303.342(a) may result |
| or          |     the       |                | in the State's        |
| combination |               |                | continuing            |
| of          |  evaluations, |                | designation as a      |
| indicators  |               |                | "high risk" grantee   |
| measures    |    incomplete |                | or otherwise affect   |
| compliance  |               |                | its FFY 2006 grant    |
| with the    |  evaluations, |                | award. OSEP           |
| 45-day      |     etc., as  |                | encourages the State  |
| timeline    |               |                | to determine whether  |
| r           |    additional |                | it can demonstrate    |
| equirements |     causes of |                | compliance within the |
| in 34 CFR   |     n         |                | required timeframe,   |
| §303        | oncompliance. |                | and, if not, to       |
| .321(e)(2), |               |                | determine whether the |
| 30          |               |                | State wishes to       |
| 3.322(e)(1) |               |                | request a compliance  |
| and         |               |                | agreement, which, if  |
| 303.342(a). |               |                | negotiated and agreed |
|             |               |                | to by the Department  |
|             |               |                | and the State, would  |
|             |               |                | provide the State     |
|             |               |                | with up to three      |
|             |               |                | years to demonstrate  |
|             |               |                | compliance.           |
+-------------+---------------+----------------+-----------------------+
| [SPP        | -   "The data | -   ODH/HMG    | As part of the final  |
| Indicator   |     reflect   |     submitted  | Special Conditions    |
| 8]{         |     that      |     no         | Report due April 14,  |
| .underline} |     indicator |     monitoring | 2006, ODH/HMG must    |
| --          |     #52 -     |     data       | provide:              |
|             |     'Every    |     regarding  |                       |
| Special     |     child     |     whether a  | -   Current, valid    |
| conditions  |     exiting   |     transition |     and reliable data |
| attached to |     the HMG   |     conference |     regarding the     |
| Ohio's FFY  |     system    |     was held   |     notification to   |
| 2005 Part C |     has a     |     at least   |     LEA, if child is  |
| grant award |     written   |     90 days    |     potentially       |
| required    |               |     prior to   |     eligible for Part |
| Ohio to     |    transition |     the        |     B, of the         |
| submit      |     outcome   |     eligible   |     transition        |
| updated     |     page as   |     child's    |     planning          |
| data in     |     part of   |     third      |     conference at     |
| their SPP   |     the IFSP  |     birthday.  |     least 90 days     |
| regarding   |     that      |                |     before the        |
| timely      |     adheres   | -   The SPP    |     child's 3rd       |
| transition  |     to        |     did not    |     birthday, and of  |
| planning    |               |     contain    |     IFSP transition   |
| under 34    |    transition |     valid and  |     planning content  |
| CFR         |     timelines |     reliable   |     requirements;     |
| §§303.1     |     as        |     data       |                       |
| 48(b)(2)(i) |     outlined  |     necessary  | ```{=html}            |
| and         |     in the    |     to         | <!-- -->              |
| 303.344(h). |               |     determine  | ```                   |
|             |   interagency |     whether    | -   The number of     |
|             |     agreement |     Ohio has   |     counties not      |
|             |     between   |     made       |     meeting           |
|             |     ODH and   |     progress   |     transition        |
|             |     ODE and   |     in         |     requirements and  |
|             |               |     ensuring   |     the descriptions  |
|             |    transition |     compliance |     of why the        |
|             |               |     with       |     timelines were    |
|             |  guidelines', |     transition |     not met;          |
|             |               |     planning   |                       |
|             |  demonstrates |                | -   The State's       |
|             |     the       |   requirements |     analysis of the   |
|             |     lowest    |     as         |     causes for delays |
|             |     level of  |     required   |     in each county;   |
|             |     c         |     in OSEP's  |     and               |
|             | ompliance..." |     FFY 2005   |                       |
|             |     (SPP,     |     Part C     | -   Corrective        |
|             |     page 25). |     grant      |     actions approved  |
|             |               |     award      |     by the State      |
|             | -   "Ohio     |     letter.    |     (including data   |
|             |               |     The        |     required by the   |
|             |    recognizes |     monitoring |     State from the    |
|             |     that the  |     indicators |     county to         |
|             |     lack of   |     used to    |     demonstrate       |
|             |               |     obtain     |     correction) to    |
|             | documentation |     baseline   |     ensure correction |
|             |     of a      |     data did   |     as soon as        |
|             |               |     not        |     possible, but no  |
|             |    transition |     measure    |     later than one    |
|             |     plan on   |                |     year after the    |
|             |     the IFSP  |    compliance. |     State's           |
|             |     and data  |                |     identification of |
|             |     entry are | -   OSEP's     |     the               |
|             |     systemic  |     January    |     noncompliance.    |
|             |     problems, |     20, 2006   |                       |
|             |     and       |     response   | Failure to provide    |
|             |     therefore |     to Ohio's  | data demonstrating    |
|             |     requires  |     Special    | compliance with 34    |
|             |     state     |     Condition  | CFR 34 CFR            |
|             |     level     |     Progress   | §§303.148(b)(2)(i)    |
|             |     changes   |     Report     | and 303.344(h) may    |
|             |     in order  |     stated     | result in the State's |
|             |     to        |     that it is | continuing            |
|             |               |     unclear if | designation as a high |
|             |   demonstrate |     "ODH/HMG   | risk grantee or       |
|             |               |     is         | otherwise affect its  |
|             |  improvement" |     measuring  | FFY 2006 grant award. |
|             |     (SPP,     |     or         | OSEP encourages the   |
|             |     page 26). |     monitoring | State to determine    |
|             |               |     for        | whether it can        |
|             | -   "The      |     compliance | demonstrate           |
|             |     survey    |     with Part  | compliance within the |
|             |     from the  |     C's 90-day | required timeframe,   |
|             |     Service   |     transition | and, if not, to       |
|             |     Delivery  |     conference | determine whether the |
|             |     committee |                | State wishes to       |
|             |     contained |   requirements | request a compliance  |
|             |     the       |     in 34 CFR  | agreement, which, if  |
|             |     following |     §30        | negotiated and agreed |
|             |     reasons   | 3.148(b)(2)(i) | to by the Department  |
|             |     for not   |     and the    | and the State, would  |
|             |     meeting   |     transition | provide the State     |
|             |               |     planning   | with up to three      |
|             |    transition |                | years to demonstrate  |
|             |               |   requirements | compliance.           |
|             | requirements: |     of 34 CFR  |                       |
|             |     child     |     §          |                       |
|             |     enters    | §303.148(b)(4) |                       |
|             |     HMG       |     and        |                       |
|             |     system to |                |                       |
|             |     close to  |   303.344(h)." |                       |
|             |     third     |                |                       |
|             |     birthday; |                |                       |
|             |     schools   |                |                       |
|             |     do not    |                |                       |
|             |     meet over |                |                       |
|             |     the       |                |                       |
|             |     summer    |                |                       |
|             |     which     |                |                       |
|             |     slows     |                |                       |
|             |     down,     |                |                       |
|             |     lack of   |                |                       |
|             |               |                |                       |
|             |  availability |                |                       |
|             |     of school |                |                       |
|             |     district  |                |                       |
|             |     re        |                |                       |
|             | presentative, |                |                       |
|             |               |                |                       |
|             |    especially |                |                       |
|             |     in        |                |                       |
|             |     summer;   |                |                       |
|             |     etc."     |                |                       |
|             |     (SPP,     |                |                       |
|             |     page 28). |                |                       |
+-------------+---------------+----------------+-----------------------+
| [SPP        | -   Baseline  | -   The only   | -   By March 1, 2006, |
| Indicator   |     data      |                |     ODH/HMG must      |
| 9]{         |     stated    |    information |     provide its       |
| .underline} |     "See Part |     in the     |     written           |
| --          |     C         |     Baseline   |     explanation of    |
|             |               |     data       |     how it monitors   |
| Special     |    Attachment |     section    |     for, and timely   |
| conditions  |     1" (SPP,  |     states     |     corrects any      |
| attached to |     page 29). |     "See Part  |     findings          |
| Ohio's FFY  |               |     C          |     regarding, Part   |
| 2005 Part C | -   The State |     Attachment |     C's 45-day        |
| grant award |     described |     1" (SPP,   |     timeline and      |
| required    |     its       |     page 29).  |     transition        |
| Ohio to     |     process   |                |     conference        |
| submit      |     for       | -   Ohio did   |     planning          |
| updated     |     i         |     not        |     requirements."    |
| data in     | dentification |     submit, in |     (OSEP Special     |
| their SPP   |     and       |     the SPP,   |     Conditions        |
| regarding   |               |     data       |     Response, page    |
| correction  |    correction |     regarding  |     4.)               |
| of          |     of        |     its status |                       |
| State       |               |     in         | -   In the FFY 2005   |
| -identified | noncompliance |     correcting |     APR due February  |
| no          |     through   |     St         |     2, 2007, ODH/HMG  |
| ncompliance |               | ate-identified |     must provide data |
| under 34    |    Continuous |                |     regarding timely  |
| CFR         |               | noncompliance, |     correction of     |
| §           |   Improvement |     including  |     noncompliance in  |
| 303.501(b). |     Plans     |     areas      |     response to       |
|             |     (CIPs).   |     still      |     Indicator #9.     |
| OSEP\'s     |     Each      |                |                       |
| October 4,  |     county is |    outstanding | Failure to provide    |
| 2005 letter |     required  |     from       | data demonstrating    |
| to OH       |     to submit |     OSEP's     | compliance with 34    |
| indicated   |     CIP to    |     2001       | CFR                   |
| the State   |     ODH on    |     Monitoring | §§303.148(b)(2)(i)    |
| had not     |     each      |     Report as  | and 303.344(h) may    |
| resolved    |     indicator |     required   | result in the State's |
| the finding |     scored    |     in OSEP's  | continuing            |
| from        |     below     |     FFY 2005   | designation as a high |
| OSEP\'s     |     100%.     |     Part C     | risk grantee or       |
| 2001        |               |     grant      | otherwise affect its  |
| Monitoring  |               |     award.     | FFY 2006 grant award. |
| Report that |               |                | OSEP encourages the   |
| the State   |               | -   SPP, page  | State to determine    |
| had failed  |               |     3, states  | whether it can        |
| to timely   |               |     "Each year | demonstrate           |
| correct     |               |     f          | compliance within the |
| State       |               | orty-four (44) | required timeframe,   |
| -identified |               |     counties   | and, if not, to       |
| no          |               |     are        | determine whether the |
| ncompliance |               |     monitored  | State wishes to       |
| as required |               |     through an | request a compliance  |
| under 34    |               |     on-site    | agreement, which, if  |
| CFR         |               |     visit by   | negotiated and agreed |
| §           |               |     the HMG    | to by the Department  |
| 303.501(b); |               |     State      | and the State, would  |
|             |               |     Monitoring | provide the State     |
|             |               |     Team."     | with up to three      |
|             |               |     However,   | years to demonstrate  |
|             |               |     the number | compliance.           |
|             |               |     of early   |                       |
|             |               |                |                       |
|             |               |   intervention |                       |
|             |               |     system     |                       |
|             |               |     programs   |                       |
|             |               |     identified |                       |
|             |               |     as         |                       |
|             |               |                |                       |
|             |               |   noncompliant |                       |
|             |               |     and data   |                       |
|             |               |     regarding  |                       |
|             |               |     correction |                       |
|             |               |     of         |                       |
|             |               |                |                       |
|             |               |  noncompliance |                       |
|             |               |     within one |                       |
|             |               |     year of    |                       |
|             |               |                |                       |
|             |               | identification |                       |
|             |               |     was not    |                       |
|             |               |     included.  |                       |
+-------------+---------------+----------------+-----------------------+