2021 SPP/APR and State Determination Letters PART C – Northern Mariana Islands
OSEP Response to SPP/APR
PDF2021 SPP/APR Submission PART C – Northern Mariana Islands
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OSEP Response to SPP/APR
400 MARYLAND AVE. S.W., WASHINGTON DC 20202 - 2600
www.ed.gov
The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by
fostering educational excellence and ensuring equal access. U
NITE D STATE S D EPARTMENT OF EDUC ATION
O FFICE OF SPECIAL EDUC ATIO N AND REHABILIT ATIVE SERVICES
June 22, 2021
Honorable Alfre d Ada
Commissioner of Education
Commonwealth of the Northern Mariana Islands Public School System
P.O. Box 501370 CK
Saipan, Northern Mariana Islands 96950
Dea r Commissioner Ada:
I am writing to advise you of the U.S. Department of Education’s (Department) 2021
determination under sections 616 and 642 of the Individuals with Disabilities Educati on Act
(IDEA). The Department has determined that Commonwealth of the Northern Mariana Islands
(CNMI) needs assistance in meeting the requirements of Part C of the IDEA. This determination
is based on the totality of the CNMI’s data and information, including the Federa l fiscal year
(FFY) 2019 State Performance Plan/Annual Performance Report (SPP/APR), other State-
reported data, and other publicly available information.
With the FFY 2019 SPP/APR submission,
the Office of Special Education Programs ( OSEP)
requested that States and Entities report whether and how the data collection for any indicator
was impacted by the COVID-19 pandemic. Specifically , OSEP requested that States and Entities
include in the narrative for each impacted indicator: (1) the impact on data completeness,
validity, and/or reliability for the indicator; (2) an explanation of how COVID-19 specifically
impacted the State’s or Entity’s ability to collect and verify the data for the indicator; and (3) any
steps the State or Entity took to mitigate the impact of COVID-19 on the data collection and
verification. OSEP appreciates States’ and Entities’ level of transparency regarding the impact of
COVID-19 on the data reported in the FFY 2019
SPP/APR. When making determination decisions for 2021, OSEP considered all information
submitted that related to the impact of the COVID-19 pandemic. For 2021 determinations, no
State or Entity received a determination of “Needs Intervention” due solely to data impacted by
COVID-19.
The CNMI’s 2021 determination is based on the data reflected in the CNMI’s “2021 Part C
Results-Driven Accountability Matrix” (RDA Matrix). The RDA Matrix is individualized for
each State and consists of: (1) a Compliance Matrix that includes scoring on Compliance Indicators and other
compliance factors;
(2F Results Components and Appendices that include scoring on Results Elements;
(3F a Compliance Score a nd a Results Score;
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(4) an RDA Percentage based on both the Compliance Score and the Results Score; and
(5) the CNMI ’s Determination.
The
RDA Matrix is further explained in a document, entitled “How the Department Made
Determinations under Sections 616(d) and 642 of the Individuals with Disabilities Educati on Act
in 2021: Part C” (HTDMD).
OSEP is continuing to use both results data and compliance data in making the Department’s
determinations in 2021, as it did for the Part C determinations in 2015-2020. (The specifics of
the determination procedures and criteria are set forth in the HTDMD and reflected in the RDA
Matrix for the CNMI.) For 2021, the Department’s IDEA Part C determinations continue to
include consideration of each State’s Child Outcomes data, which measure how children who
receive Part C services are improving functioning in three outcome areas that are critical to
school readiness: • p ositive social - emotional skills;
• acquisition and use of knowledge and skills (including early language/communication);
and
• use of appropriate behaviors to meet their needs .
Specifically, the Department considered the data quality and the child performance levels in each
State’s Child Outcomes FFY 2019 data .
You may access the results of OSEP’s review of CNMI ’s SPP/APR and other relevant data by
accessing the EMAPS SPP/APR reporting tool using your specific log - on information at
https: / / emaps.ed.gov/suite/ . When you access the CNMI ’s SPP/APR on the site, you will find, in
Indicators 1 through 10, the OSEP Response to the indicator and any actions that the CNMI is
required to take. The actions that the CNMI is required to take are in the “Required Actions”
section of the indicator.
It is important for you to review the Introduction to the SPP/APR, which may also include
language in the “OSEP Response” and/or “Required Actions” sections.
You will also find all of the following importa nt documents saved as attachments to the Progress
Page:
(1F the CNMI ’s RDA Matrix;
(2F the HTDMD document;
(3F a spreadsheet entitled “ 2021 Data Rubric Part C,” which shows how OSEP calculated the
CNMI ’s “Timely and Accurate State - Reported Data” score in the Comp liance Matrix;
and
(4F a document entitled “Dispute Resolution 201 9 - 2020 ,” which includes the IDEA section
618 data that OSEP used to calculate the CNMI ’s “Timely State Complaint Decisions”
and “Timely Due Process Hearing Decisions” scores in the Compliance M atrix.
As noted above, the CNMI ’s 2021 determination is Needs Assistance. A State’s 2021 RDA
Determination is Needs Assistance if the RDA Percentage is at least 60% but less than 80%. A
State would also be Needs Assistance if its RDA Determination percentage is 80% or above, but
the Department has imposed Specific Conditions on the State’s la st three IDEA Part C grant
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awards (for FFYs 201 8, 201 9, and 2020 ), and those Specific Conditions are in effect at the time
of the 20 21 determination.
The CNMI ’s determination for 2020 was also Needs Assistance. In accordance with section
616(e)(1) of the IDEA and 34 C.F.R. § 303.704(a), if a State is determined to need assistance for
two consecutive years, the Secretary must take one or more of the following actions:
(1) advise the State of available sources of technical assistance that may help the State
address the areas in which the State needs assistance and require the State to work with
appropriate entities; and/or
(2) identify the State as a high -risk grantee and impose Specific Conditions on the State’s
IDEA Part C grant award.
Pursuant to these requirements, the Secretary is advising the CNMI of available sources of
technical assistance, including OSEP -funded technical assistance centers and resources at the
following website: https://osep.communities.ed.gov/ , and requiring the CNMI to work with
appropriate entities. In addition, the CNMI should consider accessing technical assistance from
other Department -funded cente rs such as the Comprehensive Centers with resources at the
following link: https://compcenternetwork.org/states . The Secretary directs the CNMI to
determine the results elements and/or compliance indicators, and improvement strategies, on
which it will focus its use of available technical assistance, in order to improve its performance.
We strongly encourage the CNMI to access technical ass istance related to those results elements
and compliance indicators for which the CNMI received a score of zero. The CNMI must report
with its FFY 2020 SPP/APR submission, due February 1, 2 022 , on:
(1) the technical assistance sources from which the CNMI received assistance; and
(2) the actions the CNMI took as a result of that technical assistance.
As required by IDEA section 616(e)(7) and 34 C .F.R. § 303.706, the CNMI must notify the
public that the Secretary of Education has taken the above enforcement action, including, at a
minimum, by posting a public notice on its website and distributing the notice to the media and
to early intervention service ( EIS ) programs.
States were required to submit Phase III Year Five of the SSIP by April 1, 20 21 . OSEP
appr eciates the CNMI ’s ongoing work on its SSIP and its efforts to improve results for infants
and toddlers with disabilities and their families. We have carefully reviewed and responded to
your submission and will provide additional feedback in the upcoming weeks. Additionally,
OSEP will continue to provide technical assistance to the CNMI as it implements the SSIP,
which is due on February 1, 2022 .
As a reminder, the CNMI must report annually to the public, by posting on the State lead
agency’s website, on the performance of each EIS program located in the CNMI on the targets in
the SPP/APR as soon as practicable, but no later than 120 days after the CNMI ’s submission of
its FFY 2019 SPP/APR. In addition, the CNMI must:
(1) review EIS program performanc e against targets in the CNMI ’s SPP/APR;
(2) determine if each EIS program “meets the requirements” of Part C, or “needs assistance,”
“needs intervention,” or “needs substantial intervention” in implementing Part C of the
IDEA ;
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(3) take appropriate enforcement action; and
(4) inform each EIS program of its determination.
Further, the CNMI must make its SPP/APR available to the public by posting it on the State lead
agency’s website. Within the upcoming weeks , OSEP will be finalizing a State Profile that:
(1) includ es the CNMI ’s determination letter and SPP/APR, OSEP attachments , and all
CNMI attachments that are a ccessible in accordance with Section 508 of the
Rehabilitation Act of 1973 ; and
(2) will be accessible to the public via the ed.gov website.
OSEP appreciates the CNMI ’s efforts to improve results for infants and toddlers with disabilities
and their families and looks forward to working with the CNMI over the next year as we
continue our important work of improving the lives of children with disab ilities and their
families. Please contact your OSEP State Lead if you have any questions, would like to discuss
this further, or want to request technical assistance.
Sincerely,
David Cantrell, PhD
Acting Director
Office of Special Education Programs
cc: State Part C Coordinator
(Grant Year 2019–2020 — Issued June 24, 2021)
How the department made determinations
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Last modified on August 11, 2021