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General

Comment: None.

Discussion: As a part of our review of documents in response to 

comments, we determined that the instructions required revisions 

to remove references to hard copy forms and hard copy 

submissions. Beginning with the February 2015 submission, 

States will submit the State Performance Plan/Annual Performance 

Report (SPP/APR) for Federal fiscal year (FFY) 2013 through the 

online GRADS 360 system; therefore there are no paper forms and

States do not have the option of submitting a hard copy of the 

SPP/APR for the six-year cycle that will cover FFYs 2013 through 

2018.

Changes: We have removed the reference to the SPP/APR template 

in the SPP/APR materials section. We have removed the option 

for a State to submit a hard copy of the SPP/APR through the 

mail.

Comment: None.

Discussion: As a part of our review of documents in response to 

comments, we determined that remaining references to 

“improvement activities” might be confusing since State’s are no 

longer required to report on Improvement Activities. We have 

revised the measurement table for Indicators 1, 7, and 8 

accordingly.
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Changes: References to “improvement activities” in Indicators 

1, 7, and 8 was replaced with “methods to ensure correction.”

Comment: One commenter asked if a State must submit a new 

sampling plan for indicators under which a sampling plan was 

previously approved by the Department.

Discussion: The Department must ensure that each State using a 

sampling methodology to collect data for an indicator has a 

sampling plan that yields valid and reliable representative 

data. If a State will use its currently-approved sampling plan 

and only change the years for which it is used, the State can 

provide an assurance to this effect. If a State proposes to use 

a sampling plan that was not previously used and approved or 

will revise its current sampling plan, the State will need to 

submit the sampling plan for approval. 

Changes: None.

Comment: A few commenters recommended eliminating various 

indicators, e.g., Indicators 2 (Natural Environments), 5 (Child 

Find, Birth to 1), 6 (Child Find, Birth to 3), 9 (Resolution 

Sessions), and 10 (Mediations), where the data are already 

collected through another Department collection.

Discussion: As we clarified in the Explanation and Rationale 

document that was published as a part of the proposed 

Information Collection for the FFY 2013 APR, some IDEA Part C 

indicators are specifically required by IDEA sections 616, as 
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modified by IDEA section 642, and we continue to include those 

indicators. Indicator 2 provides information on program setting 

that is responsive to the comparable statutory requirement 

regarding least restrictive environment and would ensure that 

the SPP/APR includes a quantifiable indicator that measures the 

extent to which early intervention services are provided in the 

natural environment. IDEA sections 616(a)(3)(A) and 642. 

Indicators 5, 6, 9, and 10 address the statutory requirements 

that the SPP/APR include quantifiable indicators that measure 

the State’s exercise of its general supervisory authority 

respectively in the areas of child find, and the use of 

resolution sessions and mediations. IDEA sections 616(a)(3)(B)

and 642.

Changes: None.

Comment: A few commenters asked if the lead agency must reestablish baseline for each indicator and set new targets.

Discussion: There is no requirement that lead agencies reestablish baseline data for FFY 2013 for each of the results

indicators for its FFY 2013 APR submission, due in February 

2015, but the State must make clear for each results indicator 

the FFY data that it had previously identified as its baseline 

data for that indicator. With the exception of Indicator 11, 

the data source and measurement for each IDEA Part C results 

indicator is consistent with the previously approved SPP/APR. A 
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State will also need to establish measurable and rigorous

targets for each results indicator -- for each reporting year 

through the end of the six-year cycle (for FFY 2013, due in 

February 2015 through FFY 2018, due in February 2020) -- and

must describe how it included the participation of stakeholders, 

such as parents and families of infants, toddlers, and children 

with disabilities, the State Interagency Coordinating Council, 

EIS programs and providers, and others, when establishing those 

targets. Targets for these results indicators (Indicators 2, 3, 

4, 5, 6, 9, and 10) may remain flat over a period of reporting 

years, but the State’s FFY 2018 target for each results

indicator must demonstrate improvement over the State’s 

established baseline data for that indicator, which in most 

cases will have been established in the previous SPP that 

covered FFYs 2005-2012. 

Changes: None.

Comment: A few commenters requested clarification on when a 

State must report on slippage. Another commenter asked if a 

State must report on progress in situations where the data show 

improvement but the State does not meet its target.

Discussion: As stated in the SPP/APR instructions, a State must 

only report on slippage for those indicators where the data do 

not demonstrate progress from the previous year’s data and where 

the State did not meet its target. There is currently no 
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requirement for the State to report on slippage for those 

indicators where the data do not demonstrate progress from the 

previous year’s data, but the State has met its target, although 

a State may choose to do so. Additionally, there is currently 

no requirement to report on progress, although a State may 

choose to do so.

Changes: None.

Comment: One commenter noted that the references to OSEP’s 

September 2008 FAQs and the October 17, 2008 Dear Colleague memo 

on reporting on the correction of noncompliance in the APR have 

been removed from the indicator measurement table. The 

commenter inquired if States must continue to report on timely 

correction of noncompliance at both the child-specific and 

systemic levels.

Discussion: When reporting on correction of noncompliance under 

the individual compliance indicators, States must continue to 

report on timely correction of noncompliance at both the childspecific and systemic levels. The final Part C regulations in 

34 CFR §303.700(e) codified the longstanding standard that all 

identified noncompliance must be corrected as soon as possible 

and in no case later than one year after the State’s 

identification of the noncompliance. The Analysis of Comments 

and Changes to the final Part C regulations further clarified

that the correction of noncompliance must also be verified by 
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the lead agency within that timeframe. 76 FR 60140, 60233 

(September 28, 2011). OSEP’s September 2008 FAQs and the 

October 17, 2008 Dear Colleague Memo continue to provide States 

with guidance on how States should verify, and report on, the 

timely correction of findings of State-identified noncompliance 

in their APRs. Given that these are now longstanding 

requirements that still apply when a State reports on 

verification of timely correction of noncompliance, we removed,

as unnecessarily repetitive, the references to the guidance 

documents in the indicator measurement table.

Changes: None.

Comment: One commenter requested clarification on why States 

are no longer required to report on State complaint timelines 

and due process hearing timelines in the APR.

Discussion: As explained on page 2 of “Proposed FFY 2013-FFY 

2018 Part C SPP/APR: Explanation and Rationale,” in 2012, as a 

part of a regulatory approval, OSEP proposed to reduce State 

burden by eliminating two indicators where OSEP determined that 

the information States submitted was duplicative of data 

submitted by States through another OMB-approved information 

collection (EDFacts). Additionally, these two indicators are 

not expressly referenced in IDEA section 616, and, because the 

data are available to OSEP through the other data collection, 

OSEP can and will continue to use these data as other publicly 
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available information when OSEP evaluates a State’s performance 

as part of OSEP’s determination process. As a result, States 

were no longer required to report on Indicators 10 (State 

Complaint Timelines) and 11 (Due Process Hearing Timelines). 

Therefore, this proposal did not include reporting on those 

former indicators.

Changes: None.

Comment: One commenter requested that the SPP/APR retain the 

current numbering system, as those numbers have become part of 

the vernacular.

Discussion: We gave strong consideration to retaining the 

current numbering structure for the reason that the commenter 

cites. However, we determined it was appropriate to renumber 

given that this is a new SPP/APR for the next six-year cycle,

four of the previous SPP/APR indicators were removed (former 

SPP/APR Indicators 9, 10, 11, and 14), and the renumbering only 

impacts two indicators: Indicators 9 and 10, which were 

formerly SPP/APR Indicators 12 and 13. Given that there are now 

11 instead of 14 SPP/APR IDEA Part C indicators, on balance, it 

is less confusing to renumber the two former SPP/APR Indicators 

12 and 13 as the new SPP/APR Indicators 9 and 10. Therefore, we 

renumbered the indicators to avoid confusion.

Changes: None.

Indicator 1: Timely Services
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Comment: None.

Discussion: As part of our review of the measurement and 

instructions in Indicator 1, we determined that the instructions 

did not precisely reflect the data States have submitted under 

this indicator. Specifically, States have long reported in 

their SPP/APRs in both the numerator and denominator under 

Indicator 1 on the number of children whose early intervention 

services were timely initiated for the early intervention 

services that were newly identified on their initial or 

subsequent IFSPs and not on the provision of all early 

intervention services on their IFSPs. We have added the 

clarifying instruction to make clear that in both the numerator 

and the denominator the State should report on the number of 

children for whom the State has ensured the timely initiation of 

new services identified on the IFSP. Existing instructions make 

clear that States should report on both the initiation of new 

services identified on the initial IFSP as well as new services 

identified on existing or subsequent IFSPs.

Changes: We have clarified the instructions for Indicator 1 by 

adding the language that States report in both the numerator and 

denominator under Indicator 1 on the number of children for whom 

the State ensured the timely initiation of new services 

identified on the IFSP. 
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Comment: One commenter requested that the State be required to 

provide more detailed information in this indicator regarding 

the use of exceptional family circumstances and the nature of 

those circumstances. The commenter indicated that this 

information is critical in identifying States with a high level 

of delay due to exceptional family circumstances and to 

determine whether the State is in need of assistance in securing 

parent availability and consent or whether the State is applying 

the exceptional family circumstances label too broadly.

Discussion: We agree with the commenter that it is important

for the State and the Department to monitor the reporting and

use of exceptional family circumstances. However, we do not 

believe that the Department’s collecting this information 

through the SPP/APR is the most appropriate way to gather this 

level of detail. Under Results Driven Accountability, we will 

implement a differentiated monitoring system through which we 

will monitor all States, and provide individualized support to a 

State that needs it. That support may include technical 

assistance on the appropriate reporting, tracking, and use of 

exceptional family circumstances under IDEA Part C, should we 

determine through our monitoring that a State requires such 

support.

Changes: None.
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Comment: One commenter requested that OSEP provide guidance on 

how soon early intervention service provision should commence 

after a parent provides consent to service provision in order to 

meet the definition of “timely manner.”

Discussion: The IDEA Part C regulations in 34 CFR 

§303.344(f)(1) require that the individualized family service 

plan (IFSP) must include the projected date for the initiation 

of each early intervention service identified on the IFSP under 

34 CFR §303.344(d)(1). The regulations further note that the 

date must be as soon as possible after the parent consents to 

the service, as required in 34 CFR §§303.342(e) and 

303.420(a)(3). Currently, most States have adopted a 30-day 

timeline that commences from the date of parental consent and 

runs until the date the services in the IFSP are provided with 

some States adopting a shorter timeline and only a few States 

adopting a slightly longer timeline (e.g., 45 days), which 

timeline also commences from the date of parental consent to the

date the services in the IFSP are provided. We do not believe 

it is appropriate to adopt a time period more specific than “as 

soon as possible” for the provision of all early intervention 

services identified in an IFSP. While each State must ensure 

that services in an IFSP are provided as soon as possible after 

receiving parental consent, we believe that “as soon as 

possible” may vary depending on a number of factors, such as the 
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availability of qualified personnel in a State, the number of 

children to be served, and the location of those children. See, 

Analysis of Comments and Changes to the final Part C 

regulations, 76 FR 60140, 60202 (September 28, 2011). 

Therefore, States have flexibility to determine reasonable 

criteria for the “timely” receipt of early intervention 

services, i.e., the time period from parent consent to when IFSP 

services are actually initiated. The State must include those 

criteria in Indicator 1 of its SPP/APR.

Changes: None.

Comment: One commenter requested clarification on how many 

services must be implemented within the State’s timeline in 

order to be considered “timely.” For example, an infant or 

toddler may have three services included on his or her IFSP. 

Must all services be implemented in a “timely” manner in order 

for the State to include that infant or toddler in the numerator 

for Indicator 1, or would it be acceptable to include an infant 

or toddler in the numerator if only two of the three services 

were “timely”?

Discussion: The commenter’s concern is raised in part due to 

the Part C regulations in 34 CFR §303.344(f)(1), which require 

that the IFSP include the projected date for the initiation of 

each early intervention service. Therefore, in the commenter’s 

example of an IFSP with three services, each service may have a 
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different service initiation date. The State must evaluate each 

service initiation date to determine if all services on the IFSP 

were delivered in a timely manner as of the date of monitoring

or data collection when monitoring or collecting data. 

A child with an IFSP with all services that should have been 

delivered in a “timely” manner must be included in the 

numerator, while a child with an IFSP where at least one service 

that should have been but was not delivered in a “timely” manner 

would not be included in the numerator for Indicator 1. 

However, in situations where an initial service delivery date 

occurs after the monitoring or data collection occurs, it would 

be reasonable for the State to not include that service in its 

determination of whether or not a service was delivered in a 

timely manner.

Changes: None.

Indicator 4: Family Involvement

Comment: A few commenters requested that Indicator 4 regarding 

family involvement be eliminated as a separate reporting 

requirement and that the measurement of family involvement be 

folded into Indicator 11, the State Systemic Improvement Plan

(SSIP).

Discussion: Collecting and analyzing data on family involvement 

and then using those data to guide program improvement is a 

critical element in improving outcomes for infants and toddlers 
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with disabilities. However, we decline to fold Indicator 4 into 

Indicator 11. Indicator 11 requires the State to develop an 

SSIP that is a comprehensive, ambitious yet achievable plan for 

improving results for infants and toddlers with disabilities. 

The basis for the plan is a detailed data and infrastructure 

analysis that will guide the development of the strategies to 

increase the State’s capacity to structure, and lead meaningful 

change in, early intervention service (EIS) programs and 

providers as they improve results for infants and toddlers with 

disabilities. Data on family involvement could be one of the 

elements of analysis, but the State is not required to include 

it in its analyses. Requiring any particular single data 

source, such as family involvement data, in Indicator 11 might 

lead a State to believe that it could analyze only that 

particular data source to meet the requirements of Indicator 11. 

Changes: None.

Indicator 8: Early Childhood Transition

Comment: One commenter requested that OSEP remove the 

requirement to provide OSEP with a copy of any checklist, 

questions, or criteria used to collect monitoring data for this 

indicator. The commenter states that the requirement is overly 

burdensome and does not provide information that is needed to 

make the determination that the lead agency is identifying 

noncompliance.
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Discussion: We agree with the commenter that it is not 

necessary that OSEP collect the State’s monitoring tools through 

Indicator 8 in order to determine if the State’s monitoring tool 

or instruments are resulting in the collection and reporting of 

valid and reliable data for Indicator 8 when the State is using 

monitoring data (as opposed to database data). Therefore, we 

will remove the requirement. However, States should maintain 

documentation that demonstrates how its monitoring data for 

Indicator 8 are valid and reliable and representative of State 

data when the State does not use database data for this 

indicator. 

Changes: We have removed the requirement that the State submit 

with its APR a copy of any checklists, questions, or criteria 

used by the State to collect data for Indicator 8 if the State 

uses monitoring to collect these data.

New Indicators 9 and 10: Resolution Sessions and Mediations

Comment: One commenter recommended that Indicators 9 and 10 

measure the timeliness of resolution sessions and mediations, as 

lead agencies have no control over resolution through resolution 

sessions or mediations. 

Discussion: As previously stated, IDEA section 616(a)(3)(B)

requires that resolution sessions and mediations be measured

using quantifiable indicators and expressly specifies that the 

indicators in these two priority areas must measure the use of 
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these dispute resolution methods. Therefore, while we agree 

that lead agencies might have more control over the timeliness

of conducting these meetings rather than the outcome of these 

meetings, we believe that Indicators 9 and 10 measure the “use” 

of these dispute resolution options and, thus, the measurement 

for both of these indicators is consistent with the statute. 

Changes: None.

New Indicator 11: State Systemic Improvement Plan (SSIP)

Comment: We received multiple comments regarding proposed 

Indicator 11. Some commenters applauded the proposal as a true 

step towards results driven accountability. These same 

commenters expressed that the proposal was well-developed and 

detailed, and offered enough room for each State to craft and 

implement an SSIP that will help each State focus on systemic 

improvement. Other commenters were concerned that new Indicator 

11 is duplicative of other improvement efforts already underway 

in a State and that the burden associated with developing, 

implementing, and reporting on the SSIP far outweighs any 

associated benefit. 

Discussion: New Indicator 11 is each State’s opportunity to 

develop and implement a comprehensive, ambitious, yet achievable 

plan focused on improving results for infants and toddlers with 

disabilities. OSEP strongly encourages alignment between 

Indicator 11 and other improvement activities or plans that are
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already being implemented in the State, as long as the existing 

plan is based on recent data and infrastructure analyses. 

Additionally, in order to use an existing plan to meet the 

requirements of Indicator 11, that plan must have a direct 

impact on infants and toddlers with disabilities and align with 

the State-identified Measurable Result for Infants and Toddlers 

with Disabilities. We do not agree that Indicator 11 presents 

an increase in the reporting burden because a State is no longer 

required to develop and report in the SPP/APR on a separate set 

of improvement activities for each indicator. In addition, a 

State is encouraged to align and integrate existing State-level 

improvement efforts on which data are already collected and 

reported. This alignment, when used to meet the requirements of 

Indicator 11, if appropriate, will reduce the reporting burden.

Changes: None.

Comment: Many commenters requested that OSEP further clarify 

and define the terms used throughout Indicator 11 and provide 

more guidance on the proposed process for developing the SSIP.

Discussion: We agree with the commenters that some of the terms 

require additional explanation and that the process for 

developing and implementing the SSIP should be further 

clarified. In response, we made several structural and 

definitional revisions to Indicator 11 –
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 We labeled the two sections in the indicator to make clear 

that the first section is “Overview of The Three Phases of 

the SSIP” and the second section is the “Specific Content 

of Each Phase of the SSIP.” Below we discuss the revisions 

by section.

 Measurement – The measurement, while not substantively 

changed, was reworded for clarity. We added a section 

labeled “Instructions for the Indicator/Measurement” to 

clarify that the State must include in its FFY 2013 SPP/APR 

due February 1, 2015 the State’s baseline data for FFY 2013 

and its targets for FFYs 2014 through 2018 for its “Stateidentified Measurable Result for Infants and Toddlers with 

Disabilities.” We also clarified that the State must 

include updated data for FFY 2014 through FFY 2018 for its 

“State-identified Measurable Result for Infants and 

Toddlers with Disabilities” in its respective SPP/APRs for 

FFYs 2014 through 2018. 

Overview of the Three Phases of the SSIP

 Stakeholder Involvement – We added a section to clarify 

that stakeholders must be included throughout the 

process of developing, implementing, evaluating, and 

revising the SSIP, and included in establishing the 

State’s targets under Indicator 11. The SSIP should 
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include information about stakeholder involvement in all 

three phases.

 Phase I – We labeled this is the “Analysis” phase. 

Phase I has five components and is due with the FFY 2013 

SPP/APR submitted on February 2, 2015.

o Data Analysis. This component has not been 

substantively revised.

o Analysis of State Infrastructure to Support 

Improvement and Build Capacity. The title of this 

component was revised to clarify that the State 

must provide an analysis, and not just a list, of 

the State infrastructure that supports improvement 

and build capacity.

o In response to commenters, the proposed 

“Identification of the Focus of Improvement” was 

retitled “State-identified Measurable Result for 

Infants and Toddlers with Disabilities” to clarify 

that the focus for improvement must be an infant 

and toddler-level outcome, in contrast to a process 

outcome.

o “Selection of Coherent Improvement Strategies” was 

added to focus States on identifying a few 

strategies that are sound, logical, aligned, and 
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projected to lead to improvement in the results for 

infants and toddlers with disabilities. 

o Theory of Action. This component has not been 

revised in the description of Phase I.

 Phase II – We labelled this as the “Plan” phase and made 

changes as described below to the section titled “Support 

for EIS program Implementation of Evidence-Based Practices 

and the section titled, “Evaluation.” 

 Phase III – We labeled this Phase III as the 

“Implementation and Evaluation” phase. We clarified that a

State will provide descriptions of its ongoing evaluation 

and revisions to the SSIP during this phase.

Specific Content of Each Phase of the SSIP

This section provides comprehensive definitions and explanations 

of all of the terms and concepts used in the Overview section.

Phase I

 Data analysis is defined as a description of how the State 

identified and analyzed key data, including data from 

SPP/APR indicators, 618 data collections, and other 

available data as applicable, to: (1) select the Stateidentified Measureable Result for Infants and Toddlers with 

Disabilities, and (2) identify root causes contributing to 

low performance. The description must include information 

about how the data were disaggregated by multiple variables 
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(e.g., EIS program and/or EIS provider, geographic region, 

race/ethnicity, socioeconomic status, gender, etc.) As 

part of its data analysis, the State should also consider 

compliance data and whether those data present potential 

barriers to improvement. In addition, if the State 

identifies any concerns about the quality of the data, the 

description must include how the State will address these 

concerns. Finally, if additional data are needed, the 

description should include the methods and timelines to 

collect and analyze the additional data.

 Analysis of State Infrastructure to Support Improvement and 

Build Capacity is defined as a description of how the State 

analyzed the capacity of its current infrastructure to 

support improvement and build capacity in EIS programs 

and/or EIS providers to implement, scale up, and sustain 

the use of evidence-based practices to improve results for 

infants and toddlers with disabilities. State systems that 

make up its infrastructure include, at a minimum: 

governance, fiscal, quality standards, professional 

development, data, technical assistance, and 

accountability/monitoring. The description must include 

current strengths of the systems, the extent the systems 

are coordinated, and areas for improvement of functioning 

within and across the systems. The State must also 
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identify current State-level improvement plans and other 

early learning initiatives, such as Race to the Top-Early 

Learning Challenge and the Home Visiting program, and 

describe the extent that these new initiatives are aligned, 

and how they are, or could be, integrated with, the SSIP. 

Finally, the State should identify representatives (e.g., 

offices, agencies, positions, individuals, and other 

stakeholders) that were involved in developing Phase I of 

the SSIP and that will be involved in developing and 

implementing Phase II of the SSIP.

 State-identified Measureable Result for Infants and 

Toddlers with Disabilities is defined a statement of the 

result(s) the State intends to achieve through the 

implementation of the SSIP. The State-identified result(s) 

may, but need not, be an SPP/APR indicator or a component 

of an SPP/APR indicator. The State-identified result(s) 

must be clearly based on the Data and State Infrastructure 

Analyses and must be a child-level outcome in contrast to a 

process outcome. The State may select a single result 

(e.g., increase the rate of growth in infants and toddlers 

demonstrating positive social-emotional skills) or a 

cluster of related results (e.g., increase the percentage 

reported under child outcome B under Indicator 3 of the 

SPP/APR (knowledge and skills) and increase the percentage 
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trend reported for families under Indicator 4 (helping 

their child develop and learn)).

 Selection of Coherent Improvement Strategies is defined as 

a description that demonstrates how the improvement 

strategies were selected; are sound, logical, and aligned, 

and will lead to a measurable improvement in Stateidentified result(s). The improvement strategies should 

include the strategies, identified through the Data and 

State Infrastructure Analyses, needed to improve the State 

infrastructure and to support EIS program and/or EIS 

provider implementation of evidence-based practices to 

improve results for infants and toddlers with disabilities. 

The State must describe how implementation of the 

improvement strategies will address identified root causes 

for low performance and ultimately build EIS program and/or 

EIS provider capacity to achieve the State-identified 

Measureable Result for Infants and Toddlers with 

Disabilities. This description should include an 

explanation of how the improvement strategies were 

selected, and why they are sound, logical and aligned, and 

will lead to a measurable improvement in the Stateidentified result(s). The improvement strategies should 

include the strategies, identified through the Data and 

State Infrastructure Analyses, that are needed to improve 
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the State infrastructure and to support EIS program and/or 

EIS provider implementation of evidence-based practices to 

improve the State-identified result(s) for infants and 

toddlers with disabilities. The State must describe how 

implementation of the improvement strategies will address 

identified root causes for low performance and ultimately 

build EIS program and/or EIS provider capacity to achieve 

the State-identified Measureable Result(s) for Infants and 

Toddlers with Disabilities.

 Theory of Action is defined as a graphic illustration that 

shows the rationale of how implementing the coherent set of 

improvement strategies selected will increase the State’s 

capacity to lead meaningful change in EIS programs and/or 

EIS providers, and achieve improvement in the Stateidentified result(s) for infants and toddlers with 

disabilities.

Phase II

Phase II was revised to provide additional guidance on 

developing the plan, based on the Phase I analysis, that will be 

implemented in the State to achieve the State-identified 

Measurable Result for Infants and Toddlers with disabilities. 

Phase II includes infrastructure development, support for EIS 

program and/or EIS provider implementation of evidence-based 

practices, and evaluation.
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 Infrastructure Development: The State must specify the 

improvements that will be made to the State infrastructure 

to better support EIS programs and/or EIS providers to 

implement and scale up evidence-based practices to improve 

the State-identified result(s) for infants and toddlers 

with disabilities. The State must identify the steps the 

State will take to further align and leverage current 

improvement plans and initiatives in the State, including 

other early learning initiatives such as Race to the TopEarly Learning Challenge and the Home Visiting program, 

which impacts infants and toddlers with disabilities. This 

section must also identify who will be in charge of 

implementing the changes to infrastructure, resources 

needed, expected outcomes, and timelines for completing 

improvement efforts. In addition, the State should specify 

how it will involve multiple offices within the State lead 

agency (LA), as well as other State agencies (such as the 

State educational agency or SEA if different from the LA), 

in the improvement of its infrastructure.

 Support for EIS program and/or EIS provider Implementation 

of Evidence-based Practices: Specify how the State will 

support EIS programs and/or EIS providers in implementing 

the evidence-based practices that will result in changes in 

LA, and the EIS program and/or EIS provider practices to 
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achieve the State-identified Measurable Result(s) for 

Infants and Toddlers with Disabilities. This section must 

identify steps and specific activities needed to implement 

the coherent improvement strategies, including 

communication strategies and stakeholder involvement; how 

identified barriers will be addressed; who will be in 

charge of implementing; how the activities will be 

implemented with fidelity; the resources that will be used 

to implement them; how the expected outcomes of the 

improvement strategies will be measured; and timelines for 

completion. In addition, the State should specify how it 

will involve multiple offices within the LA (or other State 

agencies including the SEA) to support EIS programs and/or 

EIS providers in scaling up and sustaining the 

implementation of the evidence-based practices once they 

have been implemented with fidelity.

 Evaluation: The evaluation must include short-term and 

long-term objectives to measure implementation of the SSIP 

and its impact on achieving measureable improvement in the 

State-identified result(s) for infants and toddlers with 

disabilities and long-term objectives as those children 

enter preschool and kindergarten. The evaluation must be 

aligned to the theory of action and other components of the 

SSIP, include how stakeholders will be involved, and 
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include the methods that the State will use to collect and 

analyze data to evaluate implementation and outcomes of the 

SSIP. The evaluation must specify: (1) how the State will 

use the information from the evaluation to examine the 

effectiveness of the implementation of the SSIP and the 

progress toward achieving intended improvements in the 

State-identified result(s) for infants and toddlers with 

disabilities, and to make modifications to the SSIP as 

necessary; and (2) how the information from the evaluation 

will be disseminated to stakeholders.

A State may also amend previously-submitted information from 

Phase I to update it and ensure its accuracy.

Phase III

Phase III was revised for clarity. In Phase III, the State 

must, consistent with the evaluation described in Phase II, 

assess and report on its progress in implementing the SSIP. 

This reporting will include data and analysis on the extent to 

which the State has made progress toward and/or met the Stateestablished short-term and long-term objectives for 

implementation of the SSIP and its progress in achieving the 

State-identified Measureable Result for Infants and Toddlers 

with Disabilities. If the State intends to continue 

implementing the SSIP without modifications, the State must 

describe how the data from the evaluation support this decision. 
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Also, the State must provide a rationale for any revisions that 

have been made, or revisions the State plans to make, in the 

SSIP in response to evaluation data, and describe how 

stakeholders were included in the decision-making process.

Changes: As described in the Discussion section directly above, 

Indicator 11 has been revised to address commenters’ questions 

and concerns regarding clarifying the components and phases of 

the State’s development and implementation of the SSIP.

Comment: A few commenters requested that the SSIP not be 

referred to as an indicator as the structure and content of 

Indicator 11 is inconsistent with the other SPP/APR indicators.

Discussion: We do not agree that the SSIP should not be 

included as an indicator because its structure and the content 

is not the same as the other SPP/APR indicators. By designating 

the SSIP as an indicator, OSEP requires each State to identify 

its baseline data in FFY 2013 and targets for FFY 2014 through 

FFY 2018 that reflect improvement over the baseline data.

Changes: None.

Comment: A few commenters asked whether a State must require an 

SSIP of its EIS programs and/or EIS providers.

Discussion: Indicator 11 is a State-wide indicator and there is 

no requirement that the State lead agency require its EIS 

programs to develop and implement an SSIP, but the State may 

choose to do so. 
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Changes: None.

Comment: Many commenters requested that OSEP provide the 

criteria by which OSEP will evaluate an SSIP.

Discussion: We are developing the criteria by which OSEP will 

evaluate an SSIP and will share those criteria with States as a 

part of the support we provide to States under Results Driven 

Accountability.

Changes: None. 

Comment: Several commenters requested that OSEP provide an SSIP 

model or template for States to follow.

Discussion: Indicator 11 outlines the specified content the 

State must include in each of the three phases of the SSIP. 

Additionally, GRADS 360, the online SPP/APR tool, will provide 

fields to report on each of the SSIP’s required components. 

OSEP has collaborated, and will continue to work, with technical 

assistance providers to provide States with further guidance 

regarding States’ reporting under each phase and step in the 

process. 

Changes: None.

Comment: A few commenters requested that OSEP provide guidance 

on how to establish targets for Indicator 11.

Discussion: The FFY 2013 SPP/APR, submitted in February 2015, 

must include FFY 2013 data as the baseline data and measurable 

and rigorous targets for FFYs 2014 through 2018 for Indicator 11 
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that are: expressed as percentages; and reflect a measurement 

that is aligned with the State-identified Measurable Result for 

Infants and Toddlers with Disabilities, i.e., the desired infant 

and toddler-level outcome that is clearly based on the State’s 

Data and State Infrastructure analyses. 

For example, a State might report that “after conducting its 

Data and State Infrastructure Analyses, the State has determined

that its State-identified Measurable Result for Infants and 

Toddlers with Disabilities will be how well it improves the 

acquisition and use of knowledge and skills (including early 

language/communication) for infants and toddlers with 

disabilities.” For Indicator 11, the State would provide 

baseline data for FFY 2013 (expressed as a percentage) on the 

acquisition and use of knowledge and skills (including early 

language/communication) as the State’s result area for infants 

and toddlers with disabilities. The State would provide annual 

targets for each of five years from FFY 2014 through FFY 2018 

(expressed as a percentage) and the State’s end target for FFY 

2018 under this SPP/APR would have to demonstrate improvement 

over the State’s FFY 2013 baseline data. 

Changes: We have added guidance to the Part C State Performance 

Plan (SPP)/Annual Performance Report (APR) Instruction Sheet on 

establishing measurable and rigorous targets for Indicator 11.
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Comment: A few commenters questioned how Indicator 11 would 

impact a State’s determination under IDEA sections 616(d) and 

642.

Discussion: Indicator 11 will not impact the Department’s 

determinations made under IDEA sections 616(d) and 642 in 2015 

based on the FFY 2013 SPP/APR. The Department will consider the 

State’s Indicator 11 and SSIP data in the data the Department 

considers for determinations made beginning with 2016 as part of 

Results-Driven Accountability.

Changes: None.