Standards Alignment Project Focused Checklist Compl Approach
Transcript of Standards Alignment Project Focused Checklist Compl Approach
Standards Alignment Project
Focused Checklist
&
Compl Approach
Early Start Act, Alignment Goals
…The Early Achievers program must establish a common set of expectations and standards that define, measure, and improve the quality of early learning and child care settings.
... implement a single set of licensing standards for child care and the early childhood education and assistance program.
The new licensing standards must:• Provide minimum health and safety standards for
child care and preschool programs;• Rely on the standards established in the early
achievers program to address quality issues in participating early childhood programs;
• Take into account the separate needs of family care providers and child care centers; and
• Promote the continued safety of child care settings.
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LicensingFoundation of quality
for all licensed programs to meet
demonstrating health, safety and child
development requirements for
children of all ages.
ECEAPHigh-quality
comprehensive PreKprogram for low-
income children and families
Early Achievers Resources to support and
demonstrate high-quality for infants,
toddlers, and preschoolers.
Duplication
Standard is repeated in licensing and/or Early Achievers and/or ECEAP
Language Inconsistences
Different words are used in licensing and/or Early Achievers and/or ECEAP even though the concepts are the same
Progression
Standards logically build on one another between & across licensing, Early Achievers and ECEAP
Dual Language Learners
Children who acquire two or more languages simultaneously, who learn a second language while continuing to develop their first language, or who are unable to communicate effectively in English because their primary language is not English and they have not developed fluency in the English language yet
Standards Alignment Focus
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Standards Alignment – Creating a Progression
WAC AlignmentChanges in the federal child care law, increased knowledge and research,
and DEL policy priorities all inform this revision.
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Aug, 2020Weights implementation begins
Standards Alignment Timeline
Inter-Rater Reliability
Standards Alignment, Change Management Map
Early Start Act
Standards Alignment
Aligned Rules
WA COMPASSBlended Caseload
Rules Weights
ENFORCEMENT PROCESSMONITORING PROCESS
Checklist
Checklist Design
The focused monitoring
checklist approach for
licensing rules
Monitoring TheoryResearch Based Methodology – WA Approach
Differential Monitoring: A regulatory method for determining the frequency or depth of monitoring based on an assessment of a facility’s history of compliance with rules
Key Indicators: An approach that focuses on identifying and monitoring those rules that statistically predict compliance with all the rules.
Risk Assessment: An approach that focuses on identifying and monitoring those rules that place children at greater risk of mortality or morbidity if violations or citations occur
Dr. Richard Fiene Research
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Improved Health and Safety
Consistent
Usable
ValueFor the checklist to be reliable, it must be consistent
For the checklist to be effective, it must be usable
For the checklist to be trusted, value must be placed in the outcomes
Why – Changing the Checklist
Why - Identified Challenges
Rater-drift:
Checklist are always the same
Compliance blindness:
Ignores individual needs of provider
Inter-rater reliability:
Licensor inconsistency
Risk-assessment:
Regulations are all treated equally
Focused Monitoring Checklist
Rater-drift:
Individualized checklist for each provider
Compliance blindness:
Focus on where providers need support
Inter-rater reliability:
Consistent focus on checklist items
Risk-assessment:
Provides a greater level of protection for children by creating a common understanding of risk
The focused Checklist Content Areas
9 sections
Intent & Authority
Child Outcomes/Family Engagement
Interactions/Curriculum
Program Oversight
Environment - Indoor
Environment - Outdoor/General
Food and Nutrition
Infant Toddler
Professional Development
The Baseline
Each section will always have:– Fiene Key Indicators
–Regulations most critical to children's immediate health and safety (weights #7 and #8)
–Rotating regulations of the remaining weight values
–No more than 3 (possible) historical “findings” per section
Rule Rotation
Findings that are not on the checklist
– DEL will still provide and document Technical Assistance
Rules that will not be placed on the baseline checklist:– Any regulation with Weight N/A
– Regulations that do not impose a duty on the provider
– Regulations that do not apply to the provider
* Example – Rotation will be determined based on NRM weight results
8 7 6 5 4 3 2 1
Always on Baseline
2 Years 3 Years 4 years
Weight
Rotation
• Checklist expansion only happens if a Fiene Indicatoror heavy weighted regulation is found non-compliant.
• Checklist expansion only of the section within which a “risky” violation is found (not the entire checklist).
A provider’s strengths are rewarded with lower oversight in those areas and support is focused where providers need it the most!
Checklist Expansion
The Pilot
Why - Pilot Before Implementation
Validation ensures fair and consistent oversight:• Standards – Measures – Outputs – Outcomes
Reliability addresses the issues of shared knowledge and understanding
Testing ensures a seamless transition
Types of Validation
Validation Approach What does it mean?
1 Standards Approach Does the WAC align with National Best Practices?
2 Measure Approach Do highly-non compliant programs have higher risk
scores while compliant programs have lower risk
scores?
3 Output Approach Are the enforcement actions taken appropriate?
4 Outcome Approach What does the data say? Are children in low risk
programs less likely to get injured?
Implement the content on our current timeline (Aug, 2019) and implement all of the weighted enforcement approach a year later, beginning Aug., 2020.
April–Dec 2018
“Pilot” Checklist training/testing
Jan-July 2019 170-300 and
checklist Training
(re-test)
Aug 2019- Aug 2020
Data collection and validation
(on-going)
May–July 2020
Weight Analysis and
enforcement training.
Aug. 2019 CONTENT LAUNCH
Aug. 2020 WEIGHT LAUNCH
Proposed Timeline
Enforcement Approach
Project Background and Introduction
DEL Policies and Procedures
Steps to issue DEL enforcement actions
Licensor policies 10.2.1 to 10.4.1
Washington Administrative Code
Deny, suspend, revoke license; FLCAs, Non-referral, and civil fines
WAC 170-295-0100 to 0140
WAC 170-296A-8000 to 8400
Revised Code of Washington
Grants Director authority to take administrative actions
RCW 43.215.300(1) and (3)
Rules and Enforcement for DEL - Examples
Current Challenges
Current WAC language is unclear
WACs do not “fill in gaps” of RCWs
Inconsistent enforcement throughout state
Unwritten rules → a lack of transparency in enforcement
Two Prong Approach
P1. Single Finding Score
Any Current Site Visit
Single WAC Weight → Action
P2. Overall Licensing ScoreInclusive of Licensing History
Overall Score = Possible Action
Single Finding Scores/Enforcement Actions
• Denial
• Suspension
• Revocation
• Technical
Assistance
• On 1+
violation:
Civil Penalty
• Pre-probation
• License
Modification
• Suspension
• Technical
Assistance
• On 2+ Repeat
violations:
Civil Penalty
• Safety Plan
• Office
Conference
• Technical
Assistance
• On 3+ Repeat
violations:
Civil Penalty
• Technical
Assistance
• On 4+ Repeat
violations: Civil
Penalty
• Technical
Assistance
P11-3 4 5 6 7 8
2 mph over → small fine
60 mph vs 100 mph on 55 mph freeway
Lower speed limit = higher risk (school zone)
Snapshot Enforcement AnalogyP1
0-50 (Tier1)
Consideration for• Continued Licensing
Technical Assistance
50-100 (Tier 2)
Consideration for• Office Conference
• Civil Penalties
100-150 (Tier 3)
Consideration for• Civil Penalties• Probationary
• License Amendment• License Modification• Suspension
150 plus (Tier 4)
Consideration for
• Denial• Suspension• Revocation
Overall License Score/Adverse and Compliance Actions
P2
Multiple data points over 3 year history
Data points → equation to calculate ‘licensing score’
Lower licensing scores = higher compliance
Clean licensing history = no points
Points fall off after 3 years
Rewards more recent compliance (older infractions count less)
Aggregate Enforcement AnalogyP2
The calculation will consider only the 3 most recent annual monitoring visits.
The calculation will consider only 36 months of history.
Calculating the Overall License Score
Most Recent Monitor
Visit
Previous 12 month FLCAs
Prior 2 Monitoring
Visits
Current MV Score + 12 Month Non-MV scores + (Prior 2 MV Score ÷ 2) + (Prior 24 Month Non-MV scores ÷ 2)
˖ ˖1. All non-compliant
items on the
checklist are added
together by weight
value.
2. This score will
always be total value
1. All non-monitoring
visit non-compliant
items found during
previous 12 month
added together by
weight value
2. This score will always
be total value
1. All non-compliant
items found during
prior 2 monitoring
visits added together
by weight value
2. This score will be
divided by 2 as this is
historical
Prior 24 month FLCAs
1̟. All non-compliant
items found during
the 24 month
timeframe previous
to the prior 12 month
FLCA score
2. This score will be
divided by 2 as this is
historical
1. Scores will be calculated by the system once the FLCA is complete and uploaded into the system.
2. Recommendations for further actions will be sent to the licensing team.
3. Decisions for further action will be made by the licensing team.
4. Scores falling in Tier 3 and above will include the RA in decision making; scores in Tier 4 will include the SLA in decision making.
1. WAC violations will automatically be linked to licensing actions by WA Compass according to weight values once a licensor uploads the checklist and FLCA into the system.
2. Individual non-compliant WACs that qualify, will automatically be flagged for civil penalties by the system.
3. Recommendations for enforcement actions falling within each of the levels would be sent to the licensor and supervisor.
4. Decisions for further action will be made by the licensing team.
5. Weights falling in Level 6 and above will include the RA; scores in Level 7 and above will also include the SLA in decision making.
Single
FindingsScore
Overall
Licensing Score
Licensing staff
will NOT do the calculations
P2
P1
Ensuring Fair and Reasonable Scoring
Questions?