DMS

REPORT

DIFFERENTIATED MONITORING AND SUPPORT

OFFICE OF SPECIAL EDUCATION PROGRAMS

U.S. DEPARTMENT OF EDUCATION

STATE MICHIGAN 

DATE JUNE 26, 2020

IDEA PART B

CONTENTS

LETTER .............................................................................................................................................. 1

ENCLOSURE ....................................................................................................................................... 3

DMS NOTICE................................................................................................................................... 21
400 MARYLAND AVE., S.W. WASHINGTON, D.C. 20202-2600

www.ed.gov

The Department of Education’s mission is to promote student achievement and preparedness for global competitiveness by 

fostering educational excellence and ensuring equal access.

UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES

LETTER

June 26, 2020 

Honorable Michael Rice

State Superintendent of Education 

Michigan Department of Education 

608 W. Allegan Street

P.O. Box 30008 

Lansing, Michigan 48909 

RiceM6@michigan.gov 

Dear Superintendent Rice: 

The purpose of this letter is to provide a summary of the results of the differentiated monitoring 

and support (DMS) activities conducted by the U.S. Department of Education’s (Department) 

Office of Special Education Programs (OSEP) during an on-site visit to the Michigan 

Department of Education (MDE) the week of September 16, 2019. In addition to OSEP staff, 

participants included representation from the Department’s Office of Elementary and Secondary 

Education and technical assistance providers. 

As part of the DMS process, OSEP conducts an organizational assessment (OA) of factors to 

identify States’ progress in meeting performance standards and complying with the requirements 

of Part B of the Individuals with Disabilities Education Act (IDEA) and its implementing 

regulations, the Education Department General Administrative Regulations and the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

(OMB Uniform Guidance). OSEP uses the information from the OA and an Engagement 

Decision Tree to make decisions about how it will engage with States over the course of the 

Federal fiscal year (FFY). The FFY 2018 DMS areas were: 1) Results; 2) Compliance; 3) State 

Systemic Improvement Plan (SSIP); and 4) Fiscal.

On April 9, 2018, OSEP sent MDE’s DMS notice to Superintendent Michael Rice and MDE’s 

Special Education Director, Teri Chapman. That notice provided a level of engagement of 

universal, targeted, or intensive for each of the four areas OSEP identified for DMS. The levels 

of engagement in the notice were based on a snapshot of the most recently available data in the 

corresponding four areas. The notice also identified the monitoring and support activities that 

would be carried out to address the factors contributing to the elevated need for monitoring and 

support in each of the areas that were identified for intensive engagement. We have attached a 

copy of the DMS notice for your convenience. 
Page 2 — Honorable Michael Rice

The enclosure describes the: 1) Background; 2) Monitoring1 for each DMS area; 3) Summary; 

and 4) OSEP’s conclusion including Next Steps and Required Actions. If OSEP is issuing

findings of noncompliance with the IDEA requirements, you will find specific details pertaining 

to the finding of noncompliance, along with the respective citation(s); and the corrective action 

required to address the identified finding of noncompliance. 

We appreciate your efforts to improve results for children with disabilities. If you have any 

questions, please contact Genee Norbert, your OSEP State Lead, at 202-245-7326. 

Sincerely,

/s/

Laurie VanderPloeg

Director

Office of Special Education Programs 

cc: Teri Chapman, State Director of Special Education

chapmant2@michigan.gov

Enclosures

1 Monitoring is broadly defined as including activities examining both compliance and performance issues and encompasses 

traditional monitoring reviews and technical assistance activities. This is consistent with the OMB Uniform Guidance.

See 2 C.F.R. § 200.331(d) and (e).
ENCLOSURE

Background

OSEP’s Differentiated Monitoring and Support (DMS) system is a component of Results Driven 

Accountability. DMS is designed to identify potential grantee risk to the U.S. Department of 

Education (Department) and to assist the Office of Special Education Programs (OSEP) in 

effectively using its resources to monitor grantees. DMS addresses State-specific and Entityspecific needs in the areas of Results, Compliance, State Systemic Improvement Plan (SSIP), and 

Fiscal systems by differentiating levels and types of monitoring and support based on each 

State’s and Entity’s unique strengths, progress, and challenges in each area.2

During the DMS visit, OSEP reviewed the Michigan Department of Education’s (MDE’s) 

Results, SSIP, and Fiscal systems and conducted the following activities:

 Review of MDE’s systems for collecting and reporting data MDE submitted for selected 

indicators in MDE’s Federal fiscal year (FFY) 2017 State Performance Plan 

(SPP)/Annual Performance Report (APR)3 under Part B of the Individuals with 

Disabilities Education Act (IDEA).

 Review of:

 MDE’s previous SPP/APRs, including its SSIP submissions;

 MDE’s FFY 2019 annual application for funds under Part B of the IDEA;

 Information on MDE’s website related to the IDEA; and

 Other pertinent information related to MDE’s efforts to improve results for 

children with disabilities

 Gathering of additional information through interviews with:

 Dr. Michael Rice, State Superintendent;

 Sheila Alles, Chief Deputy Superintendent;

 Teri Chapman, Director, Office of Special Education;

 Janis Weckstein, Assistant Director of Special Education;

 Kelly Siciliano Carter, Director, Office of Strategic Planning and Implementation 

(OSPI);

 Venessa Keesler, Deputy Superintendent of Education Services;

 Alex Schwarz, Accountability Specialist, Office of Educational Assessment and 

Accountability;

 Bill Pearson, Director, Office of Partnership Districts;

 Liz Newell, State Transformation Assistant Administrator, OSPI;

2 For more information on OSEP’s monitoring procedures, measurement categories and ratings, see the DMS notice provided 

Attachment 1.

3 The FFY 2017 SPP/APR was the most recent SPP/APR submission at the time of the monitoring visit.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 4

 Bill Witt, Supervisor, School Improvement Support, Office of Educational 

Supports;

 Scott Koenigsknecht, Deputy Superintendent of P-20 System and Student 

Transitions;

 Gloria Chapman, Assistant Director of the Office of Partnership Districts;

 Mindy Westra, MDE Transformation Zone Administrator; and

 Erin Senkowski and Rebekah Hornak, Saginaw Intermediate School District 

(ISD)

During the visit, OSEP did not examine the DMS area of program compliance in which MDE

received a level of engagement of universal. However, OSEP will continue to work with MDE

on all the areas identified in the DMS notice during regular phone calls and provide universal 

technical assistance (TA) through national TA calls, webinars and documents posted on our 

websites.

Improving Educational Results and Functional Outcomes for Children with Disabilities

The vision and intent of IDEA is that children with disabilities will make meaningful progress in 

our education system. Protecting the rights of children with disabilities and their families is a key 

responsibility of State educational agencies (SEAs), but it is not sufficient if children are not 

attaining the knowledge and skills necessary to accomplish the ideals of IDEA: equality of 

opportunity, full participation, independent living, and economic self-sufficiency. SEAs must 

also be able to influence changes in practices in its local districts.

Under 34 C.F.R. § 300.600(b), the State’s monitoring activities must focus on: 

1. Improving educational results and functional outcomes for all children with disabilities; 

and 

2. Ensuring that public agencies meet the program requirements under Part B of the Act, 

with particular emphasis on those requirements that are most closely related to improving 

educational results for children with disabilities. 

The focus of OSEP’s DMS visit was on MDE’s progress supporting improved results for 

children with disabilities through its SSIP, Partnership Agreements with low performing school 

districts, and work through its State Personnel Development Grant (SPDG).

4 In addition, OSEP 

followed up on a customer complaints and a report from the Michigan Protection and Advocacy 

Service concerning how complaint investigators determine appropriate compensatory services 

when there is a finding in a State complaint that a child or group of children have been denied a 

free appropriate public education. For each area reviewed, OSEP has identified the major issues

and concerns that are supported by the information gathered at the State, ISD, and district levels.

4 The SPDG supports professional development for districts and schools to help implement effective practices. MIBLSI uses 

SPDG funds to provide capacity-building tools and resources for districts that support implementation of Multi-tiered Systems 

of Support.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 5

Results

In order to effectively ensure improved educational results and functional outcomes for all 

children with disabilities, the primary focus of the State’s monitoring activities must be on:

1. Improving educational results and functional outcomes for all children with disabilities; 

and 

2. Ensuring that public agencies meet the program requirements under Part B of the Act, 

with a particular emphasis on those requirements that are most closely related to 

improving educational results for children with disabilities. 34 C.F.R. § 300.600(b).

Overview of Results

Based on data Michigan reported in its FFY 2017 Part B SPP/APR, OSEP determined that 

Michigan needed intensive support in the area of results due to low percentages of:

• 4th grade children with disabilities scoring at basic or above in reading on the NAEP

(22%), 

• 8th grade children with disabilities scoring at basic or above in math on the NAEP (19%), 

• Children with disabilities who graduated with a regular high school diploma (68%),

5 and

• The high percentage of children with disabilities who dropped out (28%).

While graduation rates remained low and drop-out rates remained high, Michigan’s data indicate

progress over a four-year period. 

• Graduation rates showed an increase from 55.7% in the FFY 2014 APR, to 65.32% in the 

FFY 2017 APR.

• Drop-out rates showed a decrease from 8.63% in the FFY 2014 APR to 6.76% in the FFY 

2017 APR.

To explore the potential causes for low performance, OSEP met with key members of MDE’s 

State staff including the Deputy Superintendent of P-20 System and Student Transitions; the 

Director of MDE’s Office of Special Education; the Assistant Director of Special Education; and 

several of MDE’s technical assistance providers. MDE staff informed OSEP of the strategies 

currently being implemented to improve outcomes for children with disabilities, as well as the 

specific initiatives underway in the State to address low performance on assessments, improve 

graduation rates and implement drop-out prevention strategies.

The State also reported that much of the State’s systemic improvement work, is guided by its 

ambitious strategic plan to become a top 10 education State in 10 years (“10 in 10”), and is 

focused on building its capacity to support local efforts to implement, with fidelity, evidence5 Data reported in Michigan’s FFY 2017 APR.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 6

based practices within a Multi-tiered System of Support (MTSS) framework to improve student 

reading and behavior, utilizing implementation science principles with support from the State 

Implementation and Scaling-up of Evidence-based Practices (SISEP) Center. According to MDE, 

their systemic improvement efforts have been hampered by turnover in leadership in MDE, and 

this may be a factor explaining why the math and reading scores for children with individualized 

education programs (IEPs) in elementary school grades three through five have not improved. 

For example, the reading proficiency rate for children with IEPs against grade level and alternate 

academic achievement standards remains low with a steady decrease in reading proficiency rates 

over a four-year period, e.g., from 27.4% in 2014, to a 26% rate in 2017 as illustrated below.6

Reading

FFY 2014 2015 2016 2017

% Proficient 27.4% 28.8% 27.8% 26%

Target 72 74 76 77

Math

FFY 2014 2015 2016 2017

% Proficient 25.98% 25.38% 24.81% 22.34%

Target 53 58 62 67

During interviews with MDE staff representing the Office of Partnership Districts; Office of 

Educational Supports; and other key members of MDE’s Leadership, OSEP learned that most of 

the interventions used by ISDs and member districts were universal approaches to improving 

educational outcomes for all students but not specifically designed to support the learning needs 

of students with disabilities or directly impact the State Identified Measurable Result (SIMR). 

MDE staff reported that there were four main ways MDE works with ISDs and member districts 

to support the use of these foundational practices: 

1. Partnership Agreements with low performing schools.

2. The SSIP (described in the following section). 

3. Michigan’s Integrated Behavior and Learning Support Initiative (MIBLSI). MIBLSI is a 

SPDG/IDEA and State-level funded activity. MIBLSI provides intensive technical 

assistance to districts to implement an integrated reading and behavior multi-tier system 

of support.

7

4. Meeting with financially distressed districts (e.g., Detroit, Flint, and Benton Harbor) to 

examine fiscal practices and examine ways of improving educational outcomes.

8

6 Data sources: Michigan’s FFY 2014, 2015, 2016 and 2017 APRs.

7 MIBLSI has recently been renamed Michigan’s MTSS Technical Assistance Center.

8 For an example, see “Improving Special Education Services in the Detroit Public Schools Community District.” 

https://files.eric.ed.gov/fulltext/ED593570.pdf
OSEP DMS REPORT MICHIGAN | 2019 PAGE 7

MDE began implementing a Partnership District Model in 2017 in order to improve educational 

outcomes through an agreement with low performing schools to make significant changes to the 

instructional and noninstructional programming based on needs identified through a 

comprehensive review of data. OSEP visited two districts with schools that have Partnership 

Agreements with the State: Saginaw Public Schools and Bridgeport-Spaulding Community 

School District. OSEP conducted interviews with leadership from the Saginaw Public Schools

leadership and Saginaw High School Partnership Team, and the Bridgeport-Spaulding Central 

Office Partnership Team and Elementary/Middle Partnership Team to understand how children 

with disabilities are included in the programming. Personnel interviewed explained that the focus 

of improvement efforts is on all students, with no specific focus on students with disabilities. All 

district and school personnel mentioned MTSS as their implementation framework but varied in 

their definition of MTSS and instructional practices. Further, in reviewing partnership 

agreements, OSEP saw instructional practices that were inconsistent with the MTSS 

recommendations and learned from staff that MDE and its partners did not have a process in 

place for addressing them. Additionally, although MTSS is a top 10 in 10 priority, as of OSEP’s 

visit, the practice profile was still in draft form and its last update was in May 20189

.

MDE’s Plan to Improve Results for Children with Disabilities

Following the Department’s determination in 2018 that Michigan needs intervention in 

implementing the requirements of Part B of the IDEA, MDE responded by developing The Path 

Forward Strategic Action Plan (Plan) that includes such actions as:

1. Implement drop-out prevention and proactive strategies

2. Improve instructional practices.

3. Establish, implement, and sustain a positive school climate and culture so students will 

successfully complete the Michigan Merit Curriculum requirements and graduate from 

high school.

4. Generate and analyze the data (ISD Level) of technology use to determine alignment 

between instruction and assessment.

5. Explore innovative ways to deliver the Michigan Student Test of Educational Progress

(M-STEP)10 statewide assessment; example constructive response, reduced multiple 

choice, questions combining subjects (reading/science).

6. Explore additional diploma options (for all students unless noted) and consider which 

have the largest positive intended benefits and lowest unintended consequences. (See pp. 

9, 15.)

9 https://www.michigan.gov/documents/mde/MDE_MTSS_Practice_Profile_v_4.5__May_3_2018_-Complete_622702_7.pdf

10 M-STEP a summative assessment, is administered to students grades 3 through 8 and measures current student knowledge of 

Michigan’s academic standards in English language arts, mathematics, science, and social studies. 
OSEP DMS REPORT MICHIGAN | 2019 PAGE 8

The Plan includes the following implementation timeline: Phase One will being implemented 

through June 2021; Phase Two will be implemented from July 2021 through June 2022: and 

Phase Three will be implemented from July 2022 through July 2023. It is critical that the State

align these strategies with system-wide improvement strategies, including the SSIP, to create 

focus and coordination.

Required Actions/Next Steps

OSEP strongly encourages the State to increase oversight of improvement efforts and evaluate 

the effectiveness of initiatives intended to improve results for children with disabilities. OSEP is 

looking forward to further discussions with MDE regarding its efforts to improve results for

children with disabilities in reading, math, and graduation rates that includes the disaggregation 

of data specific to children with disabilities from the overall data reported under the Every 

Student Succeeds Act (ESSA), and the allocation of resources and technical assistance to support 

results for students with disabilities in LEAs not targeted under ESSA or its improvement 

strategies. In addition, OSEP will engage with MDE to receive updates on MDE’s progress in 

implementing its Plan according to the following schedule:

1. November 1, 2020

2. May 1, 2021

SSIP

The SSIP is a comprehensive multi-year plan for improving results for students with disabilities, 

that meets the requirements of OSEP’s accountability system set forth under Indicator 17 of the 

State Performance Plan. 

Under 20 U.S.C. § 1416(b)(2)(B)(i) and 34 C.F.R. § 300.601(b)(1), each State (see 

34 C.F.R. §§ 300.708(d) and 300.716), must collect valid and reliable information as needed to 

report annually to the Secretary on the indicators established by the Secretary for the State 

Performance Plans. As part of Phase III of the SSIP, MDE must, consistent with its evaluation 

plan described in Phase II, assess and report on its progress implementing the SSIP. As part of 

the evaluation of its SSIP, MDE must:

 Summarize the infrastructure improvement strategies that were implemented, and the 

short-term outcomes achieved. 

 Describe the next steps for each infrastructure improvement strategy and the anticipated 

outcomes to be attained during the next fiscal year. 

 Summarize the specific evidence-based practices that were implemented and the 

strategies or activities that supported their selection and ensured their use with fidelity.

 Describe any additional data (e.g., progress monitoring data) that was collected to support 

the on-going use of the evidence-based practices and inform decision-making for the next 

year of SSIP implementation.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 9

Overview of MDE’s SSIP

MDE was identified as needing intensive support in the area of the SSIP based on OSEP’s 

analysis of the State’s progress related to: (1) Infrastructure changes to support SSIP initiatives; 

(2) Selection and Implementation of Evidence-based practices to support the State Identified 

Measurable Result (SIMR); and (3) Progress toward achieving the SIMR. MDE’s SIMR focus is:

The percent of K-3 students with an individualized education program (IEP) in 

participating schools who achieve benchmark status in reading as defined by a 

curriculum-based measurement.

In the FFY 2016 IDEA Part B SPP/APR, MDE reported data for its SIMR at 43.75%, below the 

FFY 2016 target of 47%. FFY 2017 was the first time MDE submitted data in its IDEA Part B 

SPP/APR from districts selected for the “transformation zone.” As a result, the State established 

a new baseline, which it described as aligned to the curriculum-based measurement being used 

by transformation zone districts. The FFY 2017 data that MDE reported for its SIMR was 45.5%, 

below the target of 46%.

As shown in the chart below, the continued lack of progress in implementing evidence-based 

practices has been a consistent reason for OSEP’s level of engagement with Michigan on its SSIP

over the past three years (FFY 2016, FFY 2017, and FFY 2018).

Infrastructure Improvement

Phase I of the SSIP process required States to conduct a root cause analysis to determine the 

factors contributing to low student performance. As a result, MDE identified “lack of adequate 

infrastructure at the state, regional, district, and building levels to deliver the technical assistance 

needed to implement effective instruction” as the deepest driver of poor performance by students 

with disabilities. To address this issue, MDE proposed to embark on a comprehensive overhaul 

of its system at the State level. In its Phase II SSIP submission MDE highlighted: (1) leadership, 

(2) prioritization, (3) workflow processes, and (4) communication as the primary levers for 

change at the SEA-level. MDE’s proposed approach included collaborating with SISEP and 

implementing a teaming structure at the SEA consisting of a State management team, design 

team, and transformation specialists. The teams were intended to promote collaboration and 

build capacity across MDE.

In Phase II, MDE also outlined expected short, medium, and long-term outcomes of its 

infrastructure efforts. They are as follows: 

Short-term outcomes:

(1) Increased internal MDE capacity to support implementation, 

(2) Established MDE governance / leadership processes around identified priorities, and 

(3) Established MDE and ISD implementation teams.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 10

Mid-term Outcomes:

(1) Improved MDE intra-agency collaboration, 

(2) Improved culture and climate, 

(3) Increased internal capacity to support ISD implementation, and

(4) Increased ISD capacity to support local implementation.

Long-term Outcomes:

(1) Increased capacity to deliver instructional practices at schools and classroom level, 

(2) Improved student outcomes (SIMR) and other student-level outcomes specific to 

evidence-based practices such as behavior or an integrated model), and 

(3) Development of an innovative and cohesive state education agency that supports an 

aligned, coherent education system at all levels, i.e., State, ISD, district and school.

MDE provided information in each Phase III SSIP submission on activities conducted to improve 

the State’s infrastructure; however, the information does not specify progress that has been made 

and how these activities have impacted MDE’s ability to support ISDs, districts, and schools in 

implementing practices aimed at improving literacy for students with disabilities. Furthermore, 

MDE’s benchmarks for capacity, collaboration, and communication that will enable it to 

adequately support districts and schools are unspecified.

MDE has maintained that the SSIP work is a critical component of the “10 in 10” strategic plan. 

During the visit, MDE communicated that building capacity at the SEA-level is a primary goal of 

its statewide infrastructure initiative. The State selected three focus areas aimed at achieving 

infrastructure goals: (1) learner centered supports, (2) effective educators, and (3) strategic 

partnerships. On-site, OSEP learned from interviews with the Chief Deputy Superintendent, the

Deputy Superintendent of Education Services, and other members of MDE staff that it has 

engaged in book studies, collaborative efforts to change its culture, and has shifted to a customer 

service focus to make its State infrastructure more cohesive, coordinated, and aligned. OSEP 

notes that in its 2019 SSIP submission, MDE articulated some barriers to making progress on its 

infrastructure, such as lack of consensus among leadership regarding the development of the 

system’s infrastructure and challenges with the validity of the State Capacity Assessment results. 

Furthermore, the data reported on MDE’s organizational culture survey demonstrated gains of 

1% to 6% but remains in the very unfavorable category.

Theory of Action 

MDE’s theory of action for the SSIP work consists of eleven SEA-focused action items:

(1) Articulate a vision; (2) Communicate effectively; (3) Identify issues; (4) Determine priorities;

(5) Provide guidance in a timely and responsive manner; (6) Leverage and allocate resources to 

support local improvement; (7) Engage strategically with P-20 partners; (8) Utilize datainformed decision-making processes; (9) Implement a differentiated framework of support to 

improve local district outcomes; (10) Support the development of effective personnel; and

(11) Hold local districts accountable for clearly defined, measurable results.

Many of the strands in the theory of action align with the work to build capacity and improve 

infrastructure that MDE described on-site. For example, MDE walked through identified 

priorities, and actions it has taken to enhance communication and collaboration across the 
OSEP DMS REPORT MICHIGAN | 2019 PAGE 11

agency. However, little information was provided on how some strands are being operationalized 

through the SSIP work, e.g., provide guidance in a timely and responsive manner, engage 

strategically with P-20 partners, and hold local districts accountable for clearly identified, 

measurable results.

Evidence Based Practices

As shown in the chart below, the continuing lack of progress in implementing evidence-based 

practices was a consistent reason for OSEP’s level of engagement with Michigan on its SSIP 

over the past three years (see table below). Through the DMS process OSEP identified that MDE 

did not select or implement evidence-based practices as required by the measurement table for 

reporting on Phase III implementation.

11

SSIP DMS Levels of Engagement

Year Level of Engagement Reason

2018-2019 Intensive

 Not implementing evidence-based practices

 Lack of progress toward the SIMR

2017-2018 Targeted

 Not having selected or implemented evidence-based 

practices

 Lack of details around its data sources for key 

measures and process for analyzing data

 Lack of activities and outputs as related to the SIMR

 Lack of progress toward the SIMR.

2016-2017 Targeted  Implementation of the coherent improvement 

strategies (State infrastructure work); 

 Implementation of evidence-based practices and 

stakeholder engagement

On-site, the State informed OSEP that MDE’s ISDs are currently building their capacity to 

implement evidence-based practices. Specifically, they are conducting usability tests of the 

MTSS practice profiles and periodically conducting district capacity assessments. MDE did not 

specify when districts and schools would begin implementing practices intended to positively 

impact the SIMR for children with disabilities.

MDE selected two ISDs to implement MTSS for the SSIP and put in place transformation zone 

specialists to support the work and ensure multi-level communication to promote problemsolving and alignment, and to develop the SEA’s capacity to create and sustain regional 

implementation teams. While each ISD selected an area of focus for implementing MTSS, i.e., 

literacy, math, or behavior supports, none have begun implementing evidence-based practices 

aimed at improving literacy for students with disabilities per the SIMR. 

11 The State must summarize the specific evidence-based practices that were implemented and the strategies or activities that 

supported their selection and ensured their use with fidelity.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 12

To explore the potential barriers that have impacted the State’s progress toward achieving its 

SSIP targets, OSEP met with MDE leadership and staff members responsible for implementing 

the SSIP, including staff from two ISDs (one of which is in the transformation zone), local 

educational agency staff, teachers, and representatives from OSEP-funded technical assistance 

centers. In addition to hearing that schools in the transformation zone were not yet implementing 

evidence-based practices, OSEP also learned from these meetings that ISD, district, and school 

staff had not collected data to show the impact of their current efforts on improving results for 

children with disabilities and staff were unaware that the purpose of the transformation zone 

work was to improve outcomes specifically for students with disabilities. District leaders stated 

that had they known children with disabilities were the focus in the area of literacy, they would 

not have spent time exploring a focus area for the MTSS framework, (i.e. literacy, math, or 

behavior supports) and they would have had different staff involved in the transformation zone 

work.

OSEPAnalysis

The State is partnering with two ISDs (Lenawee and Saginaw) and a handful of districts within 

each ISD to implement its SSIP. As of the Phase III, Year 3 submission, the State did not provide 

specific data in relation to its SIMR, instead using the SSIP to address systemic issues within the 

State of Michigan. MDE’s approach to statewide systemic change using the SSIP as the vehicle 

to accomplish improved outcomes for all children, while ambitious, has been ineffective in 

producing positive change toward achieving the SIMR for children with disabilities over the past 

six years, demonstrating a tenuous connection between MDE’s SIMR and the SSIP. MDE’s focus 

has been on making systemic improvements at the SEA-level to build local capacity to improve 

general education. The lack of qualitative information or quantitative data to support a 

connection between improvement efforts for SPP/APR Indicator 17 raises a question as to 

whether the SIMR data is valid and reliable given that it is intended to be a student-level 

measurement reflecting improvements in the State’s system.

OSEP’s feedback to MDE regarding the SSIP has been clear and consistent for the past four 

years. OSEP has communicated serious concerns about MDE’s delay in selecting and 

implementing evidence-based practices in schools, and the State’s failure to sufficiently connect 

the SEA restructuring work to its SIMR. On a February 2016 site visit to Michigan, OSEP staff 

communicated to MDE in a SSIP meeting the importance of implementing practices that impact 

students with disabilities in schools and connecting the State infrastructure work to outcomes for 

students with disabilities. In 2017, members of MDE’s SSIP team visited the Department and 

met with OSEP staff, who again communicated the SSIP requirements and concerns about 

MDE’s delayed implementation of evidence-based practices in schools.12 During the 2017 

12 The Measurement Table in the SPP/APR for Indicator 17, State Systemic Improvement Plan states, “In Phase III, the State 

must, consistent with its evaluation plan described in Phase II, assess and report on its progress implementing the SSIP. This 

includes: (A) data and analysis on the extent to which the State has made progress toward and/or met the State-established 

short-term and long-term outcomes or objectives for implementation of the SSIP and its progress toward achieving the Stateidentified Measurable Result(s) for Children with Disabilities (SIMR);” and “the State must summarize the specific evidencebased practices that were implemented and the strategies or activities that supported their selection and ensured their use with 

fidelity. [The State must also] [d]escribe how the evidence-based practices, and activities or strategies that support their use, 

are intended to impact the SIMR.”
OSEP DMS REPORT MICHIGAN | 2019 PAGE 13

meeting, OSEP staff walked MDE staff through the steps the State would have to take and report 

in the next SSIP submission, in order to demonstrate adequate progress towards the SIMR. 

In addition to in-person meetings, OSEP had communicated concerns about MDE’s SSIP work 

during annual SSIP feedback calls and conversations related to OSEP’s DMS process, of which 

the SSIP is a major component. In each SSIP report of Phase III implementation, OSEP 

identified that MDE had not implemented evidence-based practices or demonstrated adequate 

progress toward the SIMR, as required by the SPP/APR. As illustrated below, MDE was 

designated an intensive level of engagement for the 2018-2019 DMS cycle due to: (1) not 

implementing evidence-based practices; and (2) lack of progress toward the SIMR. For the 2017-

2018 DMS cycle, MDE was designated as needing targeted support for the SSIP due to evidencebased practices, data quality and the evaluation plan, SSIP activities and output, and progress 

towards the SIMR. MDE was also designated a targeted level of engagement for the SSIP during 

the 2016-2017 DMS cycle for implementation of the coherent improvement strategies (State 

infrastructure work), evidence-based practices, and stakeholder engagement.

Required Actions/Next Steps

OSEP strongly encourages the State to increase oversight of its improvement efforts and evaluate 

the effectiveness of initiatives intended to improve educational results and functional outcomes

for all children with disabilities as required in 34 C.F.R. § 300.600(b), including developing clear 

processes for effective communication among those implementing and evaluating the SSIP 

activities at the State, ISD, district, and building levels.

In its FFY 2019 submission, as required by the measurement for IDEA Part B SPP/APR 

Indicator 17, consistent with 20 U.S.C. § 1416(b)(2)(B)(i) and 34 C.F.R. §§ 300.601(b)(1), 

300.708(d), and 300.716, MDE must:

1. Describe outcomes achieved for infrastructure improvements including:

a. How they were evaluated;

b. How they related to the theory of action;

c. The positive impact on the State’s system; and

d. How they are necessary for achieving the SIMR.

2. Identify specific evidence-based practice(s) and explain how they are necessary to 

achieve the SIMR.

3. Describe the professional development activities implemented to support the knowledge 

and use of selected evidence-based practices that occurred since the last SSIP submission 

and any data collected to inform decisions about additional professional development 

and/or coaching.

4. Describe the State’s efforts to evaluate practice change and any data collected to assess 

practice change.

5. Describe the State’s efforts to evaluate fidelity of implementation for selected evidencebased practices including fidelity data and decision-points. 
OSEP DMS REPORT MICHIGAN | 2019 PAGE 14

6. Clearly and strategically connect evidence-based practices and coherent improvement 

strategies and any reported progress to the activities conducted.

7. Report SIMR data that are aligned with the State’s SSIP.

MDE and OSEP will discuss the State’s progress towards completing these required actions 

during monthly TA calls.

Fiscal

Overview

Under the IDEA and the Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (OMB Uniform Guidance), SEAs are responsible for oversight 

of the operations of IDEA supported activities. Each SEA must monitor its own activities, and 

those of its LEAs, to ensure compliance with applicable Federal requirements and that 

performance expectations are being achieved. Monitoring must cover each program, function, 

and activity. Subrecipient monitoring is at the core of the SEA’s general supervisory 

responsibilities and can support the SEA in ensuring that its LEAs are in compliance with IDEA 

and related requirements, as well as aligned with SEA priorities designed to improve results for 

children with disabilities. The focus of OSEP’s fiscal monitoring was to review MDE’s fiscal 

subrecipient monitoring system. For IDEA Part B, MDE’s subrecipients consist of 56 ISDs and 

three State agencies.13 These entities, along with the member districts that may receive IDEA 

funds from their ISD, are the focus of MDE’s subrecipient monitoring activities.

OSEP’s monitoring included an examination of information related to each of the following 

components of MDE’s fiscal subrecipient monitoring system: (1) MDE’s Risk Assessment and 

tiered fiscal monitoring approach; (2) Program Fiscal Reviews (PFRs); (3) TA Targeted Training; 

(4) Universal supports; (5) Data and application review processes; and (6) Single audit review 

process. OSEP’s analysis is based on interviews with MDE fiscal staff, OSEP’s review of

supporting documentation submitted by MDE and other publicly available information, and 

audits conducted under the OMB Uniform Guidance. Details related to OSEP’s review, are 

provided below.

Risk Assessment: OSEP notes that MDE’s fiscal year (FY) 2017 single audit included a finding 

in which the auditor established that MDE did not evaluate each subrecipient’s risk of 

noncompliance with program requirements to determine appropriate monitoring for all 

subrecipients.14 Through OSEP’s audit resolution process, and again in the documentation 

collection process for OSEP’s monitoring, MDE provided OSEP with the spreadsheet that it used 

to determine each subrecipient’s level of risk for its FFY 2018 IDEA Part B subgrants. The 

factors contained within MDE’s risk assessment included, but were not limited to, considerations 

such as the size of the subgrant, single audit findings, date of last monitoring activity, and the 

13 Michigan’s Department of Health and Human Services, Department of Corrections, and Department of Community Health.

Note, while not related to MDE’s subrecipient monitoring, these subgrants are the source of a finding and associated required 

actions related to MDE’s allocation process on pages 16 and 17 of this report.

14 Reference Finding 2017-028 of MDE’s FY 2017 single audit, ACN 05-17-810863.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 15

number of deficit districts within the ISD.15 MDE’s risk assessment also included the aggregate 

risk scores for each subrecipient, and the level of monitoring that MDE proposed in order to 

ensure proper accountability and compliance with program requirements and achievement based 

on its assessment of risk. Specifically, as a result of its FY 2019 risk assessment,16 MDE used a 

tiered fiscal monitoring approach to identify five ISDs for PFRs, 16 ISDs for TA Targeted 

Trainings, and 38 ISDs for universal supports during FY 2019.

However, OSEP found that MDE did not perform the tiered monitoring activities determined by 

its risk assessment during FY 2019. MDE reported that, due to the departure of key staff 

involved with these processes and resulting limited capacity, MDE’s fiscal monitoring efforts 

were focused on the completion of one PFR and addressing appeals from two additional ISDs. 

OSEP further found that, due to its limited capacity, MDE has not developed policies and 

procedures guiding its risk assessment process and coordinated tiered fiscal monitoring 

activities,17 and did not perform an assessment of each subrecipient’s risk of noncompliance for 

FY 2020.

MDE provided OSEP with an updated version of its FY 2019 risk assessment that it used to 

determine tiered fiscal monitoring activities in FY 2020. Those planned monitoring activities 

continue to include the five ISDs for PFRs, 16 ISDs for TA Targeted Trainings, and 38 ISDs for 

universal supports included in the previous version of the assessment. While MDE’s planned 

activities appear reasonably designed to monitor the activities of its subrecipients, and ensure 

compliance with applicable Federal fiscal requirements, OSEP notes that the implementation 

issues and lack of internal controls noted above create concerns related to MDE’s capacity to 

implement these activities. 

Program Fiscal Reviews: MDE’s PFR process is designed to provide comprehensive monitoring 

for subgrantees (ISDs), their member districts, which includes charter schools, identified as 

being higher risk through MDE’s risk assessment process. MDE utilizes PFRs to review 

subrecipient expenditures, ensure the allowable use of IDEA and State funds, monitor 

compliance with key Federal and State fiscal and programmatic requirements, and ensure that 

expenditures involving IDEA funds are adequately documented. MDE’s PFR process is guided 

by MDE’s Office of Special Education Program Fiscal Review (PFR) Process. The PFR process 

provides information regarding the role of MDE monitors, areas and supporting documentation 

that MDE will review as a part of the PFR, and phases of the PFR process. MDE provided 

documentation illustrating the components of its PFR process, including MDE’s notification to

an ISD and member districts, and MDE’s report to the ISD on the results of MDE’s monitoring. 

The report included fiscal findings and required actions for the ISD, districts, and charter schools 

related to a number of Federal fiscal requirements, including but not limited to the 

documentation of personnel expenses, property management, proportionate share, contractual 

arrangements, cash management, and accounting procedures.18 MDE’s PFR submissions also 

included an example of its follow-up activities related to the resolution of findings made by 

15 MDE considers a district to have a deficit fund balance if it has adopted a deficit budget or incurred an operating deficit.

16 MDE’s FY 2019 risk assessment was completed on May 2, 2019.

17 MDE provided OSEP with policies related to its PFR process, but not comprehensive procedures related to its fiscal oversight.

18 We note that the MDE’s findings under accounting procedures demonstrated MDE’s review of a number of specific fiscal 

requirements (e.g., salaries and fringe benefits, comingling, etc.).
OSEP DMS REPORT MICHIGAN | 2019 PAGE 16

MDE during the monitoring (including enforcement actions such as the recovery of funds),19 and 

MDE’s notification of the resolution of findings for the ISD and member districts. 

TA Targeted Training: MDE also provided documentation illustrating the components of its TA 

Targeted Training process. MDE utilizes this process to review ISD IDEA budgets, State 

required Federal expenditure reports, single audit findings, and general ledger summaries. This 

level of fiscal monitoring also involves ISDs completing a questionnaire20 describing its 

processes for addressing Federal requirements including cash management, payroll, 

procurement, equipment/property management, proportionate share, maintenance of effort

(MOE), coordinated early intervening services, and charter school allocations. We note that 

MDE also uses the TA Targeted Training process to review its State Aid Special Education Cost 

Reports (SE-4096)21 and monitor the use of State general funds used for special education 

program activities. Finally, MDE uses this process to identify TA needs within the ISD and to 

provide appropriate fiscal supports to meet those needs. The documentation MDE provided to 

illustrate this process included an example of a notification letter, and State created forms titled,

TA Targeted Training Process Questionnaire IDEA Federal Grants and SE-4096 for an ISD 

receiving this level of monitoring.

Universal supports: MDE provided OSEP with documentation illustrating the types of universal 

supports made available to its subrecipients. Those supports include Special Education Finance 

Workshops for ISDs addressing topics including PFRs, LEA MOE, excess cost requirements, and 

proportionate share for Business Officials and Special Education Directors. MDE provided 

training on special education fiscal requirements to charter schools. MDE also provided OSEP 

with a copy of a presentation given to subrecipients that includes information related to each 

component of its fiscal monitoring system, and contained information about specific Federal 

fiscal requirements, supporting documentation generally associated with each requirement, and 

common findings for each requirement.

Data and application review processes: MDE provides fiscal oversight through the collection and 

review of subrecipient data using its special education data system.22 Information in that system 

relates to IDEA and Michigan Administrative Rules for Special Education fiscal requirements, 

including LEA MOE eligibility and compliance requirements, data required for reporting on 

CEIS, and quarterly cost reports providing expenditure data for ISDs and school districts. 

Additionally, MDE reported that it is testing enhancements that will allow it to collect data to 

determine ISD’s compliance with IDEA excess cost requirements. The system’s data is also used 

during MDE’s application review process for IDEA subgrants in the Michigan Electronic Grants 

System (MEGS+) system. Specifically, MDE uses budget data from Catamaran in determining 

whether subrecipients have met the LEA MOE eligibility standard in order to receive a subgrant. 

MDE’s application review process further includes an examination of each subrecipient’s budget 

19 MDE’s submissions included a tracking chart used to monitor the resolution of findings for the ISD, districts, and charter 

schools.

20 MDE’s TA Targeted Training Process Questionnaire IDEA Federal Grants.

21 All ISDs and member local school districts complete the SE 4096 to report on Michigan State School Aid Act funds used to 

support students with disabilities. These reports are submitted in MDE’s Financial Information Database.

22 Catamaran is MDE OSE’s special education data system
OSEP DMS REPORT MICHIGAN | 2019 PAGE 17

in MEGS+, allowing MDE to identify potential use of funds issues and prevent unallowable 

expenditures.

Single audit review process: MDE’s Office of Special Education (OSE) Program Finance 

division, and Office of Audits work collaboratively to resolve single audit findings for the IDEA 

Part B programs.23 In that process, OSE’s Program Finance division contacts ISDs or school 

districts for additional information, develops management decisions related to findings for the 

program, and provides the Office of Audits with the supporting documentation gathered and a 

copy of its management decision. MDE tracks audit resolution through its Grants Electronic 

Management System and provided OSEP with screenshots from the system demonstrating its

capacity to filter audits by Federal program, retain supporting documentation, and the ability to 

track levels of review and approval within MDE.

OSEP Analysis

In fulfilling its general supervisory responsibilities, MDE is required to evaluate each 

subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and 

conditions of the subaward for purposes of determining the appropriate subrecipient monitoring 

activities under 2 C.F.R. § 200.331(b). MDE must also monitor the activities its subrecipients as 

necessary to ensure that IDEA subawards are used for authorized purposes, in compliance with 

Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward 

performance goals are achieved as required under both the Uniform Guidance in 2 C.F.R.

§ 200.331(d), and IDEA in 34 C.F.R. §§ 300.149 and 300.600; and consider enforcement actions 

against noncompliant subrecipients as required under 2 C.F.R. §§ 200.338 and 200.331(h); 

34 C.F.R. §§ 300.149, 300.222, 300.600, and 300.604.

Further, MDE must establish and maintain effective internal controls that provide reasonable 

assurance that MDE is managing the IDEA grant awards in compliance with Federal statutes, 

regulations, and the terms and conditions of those awards pursuant to 2 C.F.R. § 200.303. These 

requirements specify that MDE must evaluate and monitor its compliance with statutes, 

regulations, and the terms and conditions of Federal awards, and must take prompt action when 

instances of noncompliance are identified, including noncompliance identified in audit findings.

2 C.F.R. §§ 200.303(c) and 200.303(d).

Based on review of the documents submitted, and interviews with the MDE staff, OSEP has 

concluded that, when utilized, the MDE’s PFR on-site monitoring process appears to be

reasonably designed to provide fiscal oversight and ensure that IDEA subawards are used for 

authorized purposes, in compliance with Federal statutes, regulations, and the terms of and 

conditions of the subaward. However, as reported above, the MDE did not carry out the tiered 

monitoring activities directed by MDE’s risk assessment, in FY 2019. Further, MDE does not 

have internal controls, including comprehensive policies and procedures guiding its risk 

assessment and related tiered fiscal monitoring. Without policies and procedures, and associated 

internal controls, MDE does not have an established methodology for determining risk factors 

and thresholds, or have timelines for data collection and review, notification of subrecipients, and 

23 Those single audit findings made specifically related to Catalog of Federal Domestic Assistance 84.027 and 84.173.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 18

performance of tiered monitoring activities. The absence of written procedures also hinders OSE 

Program Finance staff’s ability to establish roles and responsibilities which can prevent 

disruptions in fiscal monitoring in the event of future staff turnover. Because of these conditions, 

OSEP has determined that MDE is in noncompliance with the requirements in 

2 C.F.R. §§ 200.303(c) and 200.303(d). Related required actions are included in the required 

actions section below.

During its review of MDE’s fiscal subrecipient monitoring and oversight, OSEP additionally 

identified issues related to MDE’s subgrants to LEAs. As noted above, MDE’s subrecipients 

include three other State agencies that receive IDEA Part B subawards. During discussions 

related to fiscal monitoring of its subrecipients MDE disclosed that, since initially providing 

those subrecipients with IDEA subgrants using the formula described in 34 C.F.R. § 300.705 for 

base, population, and poverty, MDE has not consistently allocated remaining funds in 

accordance with the requirements in 34 C.F.R. § 300.705(b)(3). MDE reported that the cause of 

this condition is that it did not have reliable population and poverty data for the State agencies. 

As a result, MDE stated that the State agencies have consistently received the base portion of 

their allocations, but not necessarily appropriate amounts for remaining funds based on their 

population and poverty. MDE reported that it is working with an OSEP-funded technical 

assistance provider to improve its data collection related to population and poverty to allow 

MDE to allocate accurate amounts to all its subrecipients. OSEP has determined that MDE is in 

noncompliance with the requirements above and has included findings and related required 

actions in the section below. Because of these conditions, OSEP has determined that MDE is in 

noncompliance with the requirements in 34 C.F.R. § 300.705(b)(3).

Required Actions/Next Steps 

Within 120 days of the date of the letter accompanying this enclosure, MDE must submit: 

1. Documentation supporting the implementation of MDE’s FFY 2020 tiered monitoring 

activities, as determined by the risk assessment MDE utilized for its FFY 2019 subgrants. 

MDE’s monitoring activities should ensure that IDEA subawards are used for authorized 

purposes, in compliance with Federal statutes, regulations, and the terms and conditions 

of the subaward; and that subaward performance goals are achieved as required by 

2 C.F.R. § 200.331(d), and 34 C.F.R. §§ 300.149 and 300.600. 

2. Policies and procedures directing MDE’s risk assessment and related tiered approach to 

fiscal monitoring (including annual process). Those policies and procedures should 

contain sufficient detail to address the requirements for internal controls in 

2 C.F.R. § 200.303.

3. Documentation demonstrating that any subrecipient that received less than the amount of 

IDEA Section 611 funds to which it was entitled in FFY 2018 and/or FFY 2019 was made 

whole, or a plan outlining how MDE will make these subrecipients whole during FFY 

2020, in accordance with 34 C.F.R. § 300.705. MDE may use any remaining FFY 2018 

and/or FFY 2019 Section 611 State set-aside funds for this purpose. 
OSEP DMS REPORT MICHIGAN | 2019 PAGE 19

4. Revised policies and procedures ensuring that, prospectively MDE will allocate IDEA 

Part B Section 611 subgrants to all eligible subrecipients in accordance with 

34 C.F.R. § 300.705. 

State Complaint Procedures

Overview

OSEP received a complaint from a constituent alleging that MDE’s complaint investigators were 

ordering too much or too little time for compensatory services. In addition, the Michigan 

Protection and Advocacy Service submitted a report that corroborated the allegation.

34 C.F.R. § 300.151(b) requires remedies for denial of appropriate services, as follows.

In resolving a complaint in which the SEA has found a failure to provide appropriate 

services, a SEA, pursuant to its general supervisory authority under Part B of the Act, 

must address—

(1) The failure to provide appropriate services, including corrective action appropriate to 

address the needs of the child (such as compensatory services or monetary 

reimbursement); and

(2) Appropriate future provision of services for all children with disabilities.

To determine if MDE’s implementation of its State complaint procedures resulted in a failure to 

provide appropriate services, OSEP reviewed five complaint files where MDE ordered 

compensatory services, and interviewed MDE complaint management staff about the process 

used to determine the type, amount, and frequency of compensatory services. OSEP also 

reviewed MDE’s Guidance for determining the need and amount of compensatory education.

Through interviews with MDE’s complaint management staff, OSEP learned that in determining 

compensatory services for each case, the staff talk through the details of what the student 

received and what the student should receive, and considered additional factors such as a 

student’s tolerance to make up a certain number of hours due to medical issues, behavioral 

resistance, etc. The staff walked through the five complaints and explained the decisions in each 

one. In one case there was a 1:1 correspondence to the social work sessions missed and the 

number of compensatory sessions offered. In another case, compensatory services were 

calculated based on when a student should have been found eligible for special education and 

related services, and which services should have been provided. Further, MDE’s Guidance for 

determining the need and amount of compensatory education details the decision-making process

which appeared consistent with the decisions reached in the five complaint files that OSEP 

reviewed.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 20

OSEP Analysis

The State implements complaint procedures that address districts’ failure to provide appropriate 

services, including reasonable guidelines for corrective actions appropriate to address the needs 

of the child such as compensatory education services, consistent with 34 C.F.R. § 300.151.

Required Actions/Next Steps

No further action is required.
DMS NOTICE

Differentiated Monitoring and Support Engagement Decisions: 

Michigan

2019–2020

OSEP’s Differentiated Monitoring and Support (DMS) system is a component of Results Driven 

Accountability. DMS is designed to identify potential grantee risk to the Department and to assist 

OSEP in effectively using its resources to monitor grantees. DMS addresses State-specific needs 

in the areas of results, compliance, State Systemic Improvement Plan (SSIP), and fiscal by 

differentiating levels and types of monitoring and support based on each State’s unique strengths, 

progress, and challenges in each area.

DMS is a multi-tiered model for monitoring and providing support based on the principle that 

supports are first provided at a core or universal level to effectively address the needs of all 

States. Targeted monitoring and support is generally based on OSEP’s identification of common 

needs among multiple States. Intensive monitoring and support is reserved for those States with 

the most intense or complex challenges to implementation. 

OSEP has assessed States’ and Entities’ progress in meeting performance standards and 

compliance with the legal requirements of the Individuals with Disabilities Education Act, the 

Education Department General Administrative Regulations and the Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards. This information 

was used to help OSEP make decisions about a State’s or Entities’ levels of engagement for 

monitoring and support. 

The charts below specify your State’s level of engagement in each area — results, compliance, 

fiscal and SSIP.
OSEP DMS REPORT MICHIGAN | 2019 PAGE 22

Results | Level of Engagement: Intensive

Factors Existing/Current Engagement

Reading

• Percentage of 4th Grade Children with 

Disabilities Scoring at Basic or Above on the 

National Assessment of Educational Progress 

– 22%.

Math

• Percentage of 8th Grade Children with 

Disabilities Scoring at Basic or Above on the 

National Assessment of Educational Progress 

– 19%.

OSEP continues to make information and 

technical assistance (TA) resources available and 

provide universal support to all States. 

New Engagement

OSEP will offer to provide the State, in collaboration with OSEP’s technical assistance providers, 

intensive technical assistance and support in its work to improve the State’s data quality and child 

performance outcomes related to positive social relationships, skills, and knowledge. OSEP’s support may 

include establishing a schedule of regular contact, engaging in conversations to explore improvement 

activities, and discussing the progress and effectiveness of activities currently underway in the State to 

improve outcomes for students with disabilities. OSEP may also work with the State to conduct a root 

cause analysis of the factors that contribute to low results outcomes for infants, toddlers, and their 

families.

Fiscal | Level of Engagement: Intensive

Factors Existing/Current Engagement

• The State has required actions from a single 

or OIG audit that are within timelines. State 

has submitted, or still has time to submit, 

information.

• The State's IDEA 611 award exceeds 

$200,000,000.

• The State has overdue corrective actions 

related to fiscal monitoring findings (no 

submission, past due date).

• 32% or more of State’s LEAs are charter 

school LEAs.

OSEP continues to make information and TA 

resources available and provide universal support 

to all States. 

New Engagement

OSEP will contact the State and discuss the level of engagement. OSEP may also request additional 

documentation from the State and collect additional publicly available information. Based upon 

discussions with the State, technical assistance or additional data collection may be conducted on-site or 

virtually. 
OSEP DMS REPORT MICHIGAN | 2019 PAGE 23

Compliance | Level of Engagement: Targeted

Factors Existing/Current Engagement

• Indicator 12: IEP developed and implemented 

by third birthday – 93.52%.

• Indicator 13: Secondary transition- 81%.

OSEP continues to make information and TA 

resources available and provide universal support 

to all States. 

New Engagement

OSEP will gather additional information to determine the scope of engagement necessary to assist the 

State in improving IDEA compliance. This may include discussions with the State to determine the 

factors impacting the State’s specific area of low compliance and collaboratively working with the State 

to develop a plan to bring the State into IDEA compliance as soon as possible.

SSIP | Level of Engagement: Intensive

Factors Existing/Current Engagement

• Coherent improvement strategies are not 

clearly defined, the state has not reported on 

progress, or the activities reported on are not 

aligned with the Theory of Action / SIMR.

• Evidence-based practices are not yet 

identified or activities are limited to 

professional development to build 

teacher/provider knowledge and use of 

practices.

• The State did not meet its FFY 2017 SIMR 

target, nor is it collecting progress monitoring 

data/interim measures of progress that suggest 

progress toward the SIMR throughout the 

year.

OSEP continues to make information and TA 

resources available and provide universal support 

to all States. 

New Engagement

OSEP will offer to provide the State intensive technical assistance and support in its work to improve the 

SSIP in areas such as evidence-based practices, evaluation planning, or stakeholder engagement. OSEP 

will offer to establish a schedule of regular contact with the State, explore improvement activities, and 

discuss the progress and effectiveness of the activities currently underway in the State. OSEP will also 

work collaboratively with OSEP-funded TA providers and may, if necessary, explore opportunities for onsite technical assistance in the State.