Table B --Vermont Part C

Previously Identified Issues

+-----------------+-----------------+-----------------+-----------------+
| **Issue**       | ## S            | **OSEP          | **Required      |
|                 | tate Submission | Analysis**      | Action**        |
+=================+=================+=================+=================+
| **Indicator     | OSEP's November | Although the    | By June 1,      |
| 7:**            | 15, 2004 letter | State provided  | 2006, the State |
|                 | accepted the    | data in the SPP | must submit:    |
| OSEP's November | State's plan to | that indicate   | (1) its         |
| 15, 2004 letter | ensure          | continuing      | progress in     |
| accepted the    | compliance with | noncompliance   | ensuring        |
| State's plan to | the             | with the        | correction with |
| ensure          | requirements    | requirement     | this            |
| compliance with | listed below.   | regarding       | requirement for |
| the             | OSEP's          | 45-day timeline | Regions 1, 2    |
| requirements    | September 8,    | (34 CFR         | and 3; and (2)  |
| listed below.   | 2005 response   | §               | the cause(s)    |
| OSEP's          | to Vermont's    | §303.321(e)(2), | for delay       |
| September 8,    | FFY 2003 APR    | 303.322(e)(1)   | including any   |
| 2005 response   | required the    | and             | delays          |
| to Vermont's    | State to        | 303.342(a)),    | attributable to |
| FFY 2003 APR    | provide a final | the State's     | documented      |
| required the    | Progress Report | data            | family and      |
| State to        | in the SPP with | demonstrated    | child           |
| provide a final | data            | improvement     | circumstances.  |
| Progress Report | demonstrating   | from its FFY    | The State may   |
| in the SPP with | full            | 2003 APR data   | wish to review  |
| data            | compliance.     | indicating 45%  | its data for    |
| demonstrating   |                 | noncompliance.  | these three     |
| full            | The State       | In addition, it | regions to      |
| compliance.     | reported        | is unclear if   | determine       |
|                 | monitoring data | the State is    | whether delays  |
| The evaluation, | indicating      | including in    | attributable to |
| assessment and  | levels of       | its compliance  | documented      |
| initial IFSP    | compliance of   | calculation     | child or family |
| meeting are     | 50% in one      | delays that are | circumstances   |
| conducted       | region, 66% in  | attributable to | were included   |
| within the      | another, 75% in | documented      | in the          |
| 45-day timeline | two more, and   | child or family | compliance      |
| as required by  | 92% in the last | exceptional     | calculations    |
| 34 CFR          | two regions     | circumstances.  | and, if so,     |
| §               | monitored       |                 | provide these   |
| §303.321(e)(2), | regarding the   |                 | numbers to OSEP |
| 303.322(e)(1)   | 45-day          |                 | by June 1,      |
| and 303.342(a). | timeline.       |                 | 2006. Failure   |
|                 |                 |                 | to provide the  |
|                 |                 |                 | information     |
|                 |                 |                 | requested may   |
|                 |                 |                 | result in the   |
|                 |                 |                 | State being     |
|                 |                 |                 | identified as a |
|                 |                 |                 | "high risk"     |
|                 |                 |                 | grantee or      |
|                 |                 |                 | otherwise       |
|                 |                 |                 | affect the      |
|                 |                 |                 | State's FFY     |
|                 |                 |                 | 2006 grant      |
|                 |                 |                 | award.          |
|                 |                 |                 |                 |
|                 |                 |                 | [Othe           |
|                 |                 |                 | r]{.underline}: |
|                 |                 |                 | In the FFY 2005 |
|                 |                 |                 | APR, due        |
|                 |                 |                 | February 1,     |
|                 |                 |                 | 2007 and with   |
|                 |                 |                 | the June 1,     |
|                 |                 |                 | 2006 data, the  |
|                 |                 |                 | State should    |
|                 |                 |                 | not include in  |
|                 |                 |                 | the calculation |
|                 |                 |                 | children for    |
|                 |                 |                 | whom the State  |
|                 |                 |                 | has identified  |
|                 |                 |                 | the cause for   |
|                 |                 |                 | the delay as    |
|                 |                 |                 | exceptional     |
|                 |                 |                 | child or family |
|                 |                 |                 | circumstances   |
|                 |                 |                 | documented in   |
|                 |                 |                 | the child's     |
|                 |                 |                 | record. The     |
|                 |                 |                 | State must      |
|                 |                 |                 | include in its  |
|                 |                 |                 | discussion of   |
|                 |                 |                 | data, the       |
|                 |                 |                 | numbers it used |
|                 |                 |                 | to determine    |
|                 |                 |                 | its calculation |
|                 |                 |                 | under this      |
|                 |                 |                 | indicator and   |
|                 |                 |                 | report          |
|                 |                 |                 | separately the  |
|                 |                 |                 | number of       |
|                 |                 |                 | documented      |
|                 |                 |                 | delays          |
|                 |                 |                 | attributable to |
|                 |                 |                 | child or family |
|                 |                 |                 | circumstances.  |
+-----------------+-----------------+-----------------+-----------------+
| **Indicator     | In its cover    | There is no     | As part of its  |
| 8:** Whether    | letter          | current         | FFY 2006 Part C |
| the State       | accompanying    | interagency     | application,    |
| provides timely | its SPP, the    | agreement       | the State lead  |
| transition      | State reported  | between the     | agency must     |
| planning to     | being on track  | lead agency and | submit a copy   |
| support the     | to submit a     | VDE on early    | of its signed   |
| child's         | final           | childhood       | interagency     |
| transition to   | interagency     | transition      | agreement with  |
| preschool by    | agreement that  | matters. Part C | the Vermont SEA |
| the child's     | includes the    | regulations at  | that meets      |
| third birthday. | transition      | 34 CFR          | these           |
|                 | requirements by | §303.148(c)     | requirements.   |
| Based on        | June 30, 2006.  | require that if |                 |
| information     |                 | the State       |                 |
| obtained during |                 | educational     |                 |
| the July 2004   |                 | agency, which   |                 |
| verification    |                 | is responsible  |                 |
| visit and from  |                 | for             |                 |
| the FFYs 2003   |                 | administering   |                 |
| and 2004 APRs,  |                 | preschool       |                 |
| OSEP            |                 | programs under  |                 |
| conditionally   |                 | Part B of IDEA, |                 |
| approved the    |                 | is not the lead |                 |
| State's FFY     |                 | agency under    |                 |
| 2005 Part C     |                 | Part C, the     |                 |
| grant. This     |                 | lead agency     |                 |
| conditional     |                 | must submit an  |                 |
| approval was    |                 | interagency     |                 |
| based on the    |                 | agreement       |                 |
| State's         |                 | between the two |                 |
| assurance that  |                 | agencies to     |                 |
| it would submit |                 | ensure          |                 |
| to OSEP by June |                 | coordination on |                 |
| 30, 2006 its    |                 | transition      |                 |
| interagency     |                 | matters. The    |                 |
| agreement with  |                 | interagency     |                 |
| the Vermont     |                 | agreement must  |                 |
| Department of   |                 | conform to the  |                 |
| Education       |                 | requirements at |                 |
| (VDE), which    |                 | 34 CFR          |                 |
| would include   |                 | §§303.523       |                 |
| all of Part C's |                 | through 303.525 |                 |
| transition      |                 | as well as the  |                 |
| requirements in |                 | requirements at |                 |
| 34 CFR          |                 | 34 CFR          |                 |
| §§303.148 and   |                 | §§300.132,      |                 |
| 303.344(h).     |                 | 303.148(b) and  |                 |
|                 |                 | 303.344(h).     |                 |
+-----------------+-----------------+-----------------+-----------------+
| **Indicator     | Under Indicator | While this      | OSEP looks      |
| 9B:** 1. All    | 9(b), pages 40  | level of        | forward to      |
| eligible        | and 41 of the   | compliance is   | reviewing data  |
| children have a | SPP, the State  | below 100% for  | in the APR, due |
| single service  | reported a      | some providers  | February 1,     |
| coordinator     | Statewide level | and requires    | 2007, that      |
| identified on   | of 92%          | improvement     | demonstrate     |
| the IFSP as     | compliance      | activities to   | full compliance |
| required by 34  | based on        | achieve full    | with the single |
| CFR §303.23(a). | monitoring of   | compliance,     | service         |
|                 | three regions   | OSEP recognizes | coordinator     |
| OSEP's November | regarding the   | the effort made | requirement in  |
| 15, 2004 letter | requirement to  | by the State in | 34 CFR          |
| accepted the    | have a single   | working toward  | §303.23(a).     |
| State's plan to | service         | compliance with |                 |
| ensure          | coordinator     | the requirement |                 |
| compliance with | identified on   | at 34 CFR       |                 |
| the above       | the IFSP as     | §303.23(a).     |                 |
| requirement.    | required by 34  |                 |                 |
| OSEP's          | CFR §303.23(a). |                 |                 |
| September 8,    |                 |                 |                 |
| 2005 response   |                 |                 |                 |
| to Vermont's    |                 |                 |                 |
| FFY 2003 APR    |                 |                 |                 |
| required the    |                 |                 |                 |
| State to        |                 |                 |                 |
| provide a final |                 |                 |                 |
| Progress Report |                 |                 |                 |
| in the SPP with |                 |                 |                 |
| data            |                 |                 |                 |
| demonstrating   |                 |                 |                 |
| full compliance |                 |                 |                 |
| with this       |                 |                 |                 |
| requirement.    |                 |                 |                 |
+-----------------+-----------------+-----------------+-----------------+
| **Indicator     | Under Indicator | The State       | By June 1,      |
| 9B:**           | 9B, page 41 of  | provided data   | 2006, the State |
|                 | the SPP, the    | that            | must submit:    |
| 2\. IFSPs must  | State reported  | demonstrate     | (1) its         |
| contain each    | a Statewide     | continuing      | progress in     |
| child's present | level of 56%    | noncompliance   | ensuring        |
| level of        | compliance      | with the        | correction for  |
| development in  | based on        | requirement     | Regions 1, 2    |
| five domains as | monitoring of   | regarding       | and 3 with this |
| required by 34  | three regions   | present level   | requirement;    |
| CFR             | regarding the   | of development  | and (2) its     |
| §303.344(a)(1). | requirement     | in five domains | analysis as to  |
|                 | that IFSPs      | (34 CFR         | the cause(s)    |
| OSEP's November | contain the     | §               | for IFSPs not   |
| 15, 2004 letter | present level   | 303.344(a)(1)). | reflecting      |
| accepted the    | of development  | However, given  | present levels  |
| State's plan to | in each of five | that the        | of development, |
| ensure          | developmental   | State's data    | including       |
| compliance with | domains as      | indicate        | potentially     |
| the above       | required by 34  | noncompliance   | incomplete      |
| requirement.    | CFR             | with Part C's   | evaluations.    |
| OSEP's          | §303.344(a)(1). | 45-day          | Failure to      |
| September 8,    |                 | timeline, OSEP  | provide the     |
| 2005 response   |                 | recommends the  | information     |
| to Vermont's    |                 | State review    | requested may   |
| FFY 2003 APR    |                 | data to         | result in the   |
| required the    |                 | determine if    | State being     |
| State to        |                 | the cause for   | identified as a |
| provide a final |                 | noncompliance   | "high risk"     |
| Progress Report |                 | with 34 CFR     | grantee or      |
| in the SPP with |                 | §303.344(a) is  | otherwise       |
| data            |                 | lack of         | affect the      |
| demonstrating   |                 | complete        | State's FFY     |
| full compliance |                 | evaluations     | 2006 grant      |
| with this       |                 | that would      | award.          |
| requirement.    |                 | provide the     |                 |
|                 |                 | present level   |                 |
|                 |                 | of development  |                 |
|                 |                 | in each         |                 |
|                 |                 | developmental   |                 |
|                 |                 | area.           |                 |
+-----------------+-----------------+-----------------+-----------------+