Family & Community Special Communities
Special Education

OSEP’s Report on the Monitoring of Massachusetts

I. Part C: General Supervision

The State lead agency, DPH, is responsible for developing and maintaining a statewide, comprehensive, coordinated, multidisciplinary, interagency early intervention system. Administration, supervision and monitoring of the early intervention system are essential to ensure that each eligible child and family receives the services needed to enhance the development of infants and toddlers with disabilities and to minimize their potential for developmental delay. Early intervention services are provided by a variety of public and private entities. Through supervision and monitoring, the State assures that all agencies and individuals providing early intervention services meet the requirements of IDEA, whether or not they receive funds under Part C.

While each State must meet its general supervision and administration responsibilities, the State may determine how that will be accomplished. Mechanisms such as interagency agreements and/or contracts with other State-level or private agencies can serve as the vehicle for the lead agency's implementation of its monitoring responsibilities. The State's role in supervision and monitoring includes:

1. identifying areas in which implementation does not comply with Federal requirements;
2. providing assistance in correcting identified problems, and
3. as needed, using enforcement mechanisms to ensure correction of identified problems.

Validation Planning and Data Collection

The Massachusetts Part C Self-Assessment document identified several issues regarding the State's oversight of the provision of early intervention services. DPH's analysis of respondents' comments clustered in the following areas: system administration, service delivery, reimbursement and funding staff training and certification. The concerns identified included:

1. the effectiveness of the lead agency's current monitoring system to evaluate quality early intervention services and
2. implementation of State policy regarding natural environments and a lack of statewide training and support for effective service models.

At each of the public input meetings that OSEP conducted during the Validation Planning visit, the following question was asked: "does the State effectively supervise the implementation of the early intervention system?" Responses identified concern for the State's capacity to provide effective monitoring and supervision of early intervention services. Several local program administrators and providers stated that with the growth of the early intervention system to 65 certified providers, the administrative infrastructure of the DPH consisting of the Part C Coordinator and five regional specialists who are directly responsible to implement Part C may be compromised. Providers stated that staff resources at the State level have remained the same, while the needs of providers for guidance have increased.

Local program administrators indicated that there is inconsistency among the State's regional specialists who provide technical assistance and conduct program certification visits (Massachusetts' term for monitoring) as to the manner and depth of their investigations and follow-up activities. Other providers emphasized that service provision is more difficult than it was ten years ago because of the challenges of implementing current regulatory requirements, increased staff training and supervision needs, and the service needs of a large population of children who are at risk. Many participants at the meetings, including family members, praised the lead agency staff stating that "DPH is their favorite State agency" and that "they want us to be successful" in our work with children and families.

In order to investigate the issues identified during the Validation Planning process, OSEP collected information from the review of children's records, examined State and local policies and procedures, reviewed monitoring reports, and conducted interviews with State personnel, local program directors, service coordinators/providers, parents and interagency collaborators.

OSEP also reviewed and analyzed the data and identified the following area of strength and suggestion for improved results for infants and toddlers and their families.

A. Strengths

Effective Use of Funding to Provide Expanded Services to Infants and Toddlers Who Are At-Risk for Developmental Disabilities

DPH has ensured the availability of payments that support the statewide system of Part C services for 18,322 infants and toddlers and their families (cumulative total of children served over the course of a year). DPH has been successful under 1990 legislation in making available private insurance funding which provides 25 percent of the State's early intervention budget. The legislation includes coverage for medically necessary early intervention services namely, occupational, physical and speech therapy, nursing care and psychological counseling. Of the total third party funds, Medicaid contributes 23 percent of the funding needed to expand services to all children who have developmental disabilities or developmental delay (State's FY 1998 Annual Performance Report).

B. Suggestion For Improved Results For Infants, Toddlers, and Their Families

Monitoring to Ensure Consistent Implementation of Part C Requirements across the State

The DPH's monitoring process for Part C includes a program certification/recertification process, which is required for all 65 provider agencies. Regional specialists complete the certification process, which includes parent and staff interviews, child evaluation and assessment observations, family home visits, and completion of family and community resource questionnaires, in addition to reviewing staff credentials, early intervention records, a facility checklist, and a program standards checklist. The regional specialist also completes a Paper Trail Billing Audit. Program recertification visits are conducted every two years or more frequently, if deemed appropriate by the regional specialist. Regional specialists also provide technical assistance and training activities to the 65 providers.

Service providers, administrators and parents stated that it would be beneficial to increase the present level of State Interagency Coordinating Council members, parent and provider involvement in local monitoring activities, including the dissemination of monitoring reports to participants, and to conduct consistent follow up to improve identified program issues and ensure correction action. The State may want to want to develop additional strategies to monitor implementation of Part C natural environments policy across agencies, to build community resources such as childcare, and to meet child and family needs.