UTAH PROGRAM

IMPROVEMENT
PLANNING SYSTEM
(UPIPS) MANUAL
2021–2022

ADA Compliant: July 2021

TABLE OF CONTENTS
Utah State Board Of Education Strategic Plan.........................................................4
Vision ................................................................................................................................................ 4
Mission ............................................................................................................................................. 4
Goals................................................................................................................................................. 4
Overview of Utah’s General Supervision .................................................................5
Six Principles of Idea ...............................................................................................6
I. Free Appropriate Public Education (FAPE)............................................................................... 6
II. Appropriate Evaluation ............................................................................................................ 6
III. Individualized Education Program ........................................................................................... 6
IV. Least Restrictive Environment (LRE) ........................................................................................ 6
V. Parent and Student Participation in Decision Making ............................................................. 6
VI. Procedural Safeguards ............................................................................................................. 6
Utah Program Improvement Planning System (UPIPS)............................................7
UPIPS Objectives .............................................................................................................................. 7
UPIPS Themes................................................................................................................................... 7
UPIPS Program Areas..............................................................................................8
Program Area I—General Supervision (Rules VI.H.2.)...................................................................... 8
Program Area II—Parent Involvement (Rules III.G.) ........................................................................ 8
Program Area III—FAPE in the LRE (Rules I.E.18.)............................................................................ 8
Program Area IV—Transition (Rules VII.) ......................................................................................... 8
Program Area V—Disproportionality (Rules VIII.B.12.).................................................................... 8
Program Area Components.............................................................................................................. 9
UTAH SPP/APR/SSIP ............................................................................................. 10
Relevant Documents ...................................................................................................................... 10
Indicators in the Annual Performance Report (APR) ..................................................................... 10
APR Determination: Framework for Recognition, Assistance, and Intervention .......................... 11
USBE SES Tiered Support and Activities Structure .................................................. 11
Supporting Tier (Risk Level 1) ......................................................................................................... 11
Guiding Tier (Risk Level 2) .............................................................................................................. 12
Assisting Tier (Risk Level 3)............................................................................................................. 13

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 Coaching Tier (Risk Level 4) ............................................................................................................ 13
Directing Tier (Risk Level 5) ............................................................................................................ 14
USBE SES Monitoring Visit Process ........................................................................ 15
Selecting LEAs for Monitoring Visits............................................................................................... 15
Full Monitoring Visit Components ................................................................................................. 15
Identification and Correction of Noncompliance ................................................... 17
Compliance Identification .............................................................................................................. 17
Correction of Noncompliance ........................................................................................................ 17
Enforcement ................................................................................................................................... 19
Policies and Procedures Manuals .......................................................................... 19
Program Improvement Plan (PIP).......................................................................... 20
Definition ........................................................................................................................................ 20
Purpose........................................................................................................................................... 20
LEA Program Improvement Process............................................................................................... 20
Internal Student File Review Guidelines ................................................................ 26
Technical Assistance and Resources for Compliance .............................................. 27
Strong Start..................................................................................................................................... 27
Utah Institute on Special Education Law ....................................................................................... 27
Utah Systems Conference .............................................................................................................. 27
Transition Institute ......................................................................................................................... 27
Targeted Trainings .......................................................................................................................... 28
Newsletters .................................................................................................................................... 28
Utah Special Educator Administrators’ Meeting (USEAM) ............................................................ 28
Office of Special Education and Rehabilitative Services (OSERS), Office of Special Education
Programs (OSEP), Office of Civil Rights (OCR) ................................................................................ 28
Special Education Connection (LRP)............................................................................................... 29
Fiscal Compliance and Accountability Monitoring......................................................................... 29

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UTAH STATE BOARD OF EDUCATION STRATEGIC PLAN
Vision
Upon completion, all Utah students are prepared to succeed and lead by having the knowledge
and skills to learn, engage civically, and lead meaningful lives.
Mission
The Utah State Board of Education leads by creating equitable conditions for student success:
advocating for necessary resources, developing policy, and providing effective oversight and
support.
Goals
I. Early Learning
Each student starts strong through early grades with a foundation in literacy and numeracy.
II. Personalized Teaching and Learning
Each student and educator has access to personalized teaching and learning experiences.
III. Safe and Healthy Schools
Each student learns in a safe and healthy school environment.
IV. Effective Educators and Leaders
Each student is taught by effective educators who are supported by effective school leaders.
For more details about the Utah State Board of Education Strategic Plan, visit the webpage
(https://schools.utah.gov/board/utah/strategicplan).

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OVERVIEW OF UTAH’S GENERAL SUPERVISION
The Individuals with Disabilities Education Improvement Act of 2004 (IDEA) and the Utah State
Board of Education Special Education Rules (Rules) state Utah State Board of Education Special
Education Section (USBE SES) staff have the responsibility of monitoring compliance with federal
and state requirements (20 U.S.C. §1400; Rules VIII.C-D). The primary focus is improving
educational results and functional outcomes for all students with disabilities (Rules VIII.C.3.).
The USBE SES uses the Utah Program Improvement Planning System (UPIPS) to monitor and
support compliance with federal and state requirements in Local Education Agencies (LEAs) across
the state of Utah. This system was developed and designed to mirror the system used by the
federal Office of Special Education Programs (OSEP) to monitor each state. UPIPS encompasses
both external monitoring by the USBE SES and internal monitoring by the LEA. The purpose of
UPIPS is to use continuous monitoring to improve procedural compliance and outcomes for
students with disabilities. This data-driven approach to monitoring provides a systematic way for
the USBE SES and the LEA to evaluate the impact special education services are having on student
achievement and outcomes.
UPIPS monitoring also helps generate data the USBE SES is required to report to OSEP regarding
the indicators on the Annual Performance Report (APR). The APR indicators were established to
provide OSEP with the ability to monitor state compliance with federal requirements. Each year,
the USBE SES compiles the data for each indicator for the entire state to determine whether
targets were met and submits the APR for OSEP review. OSEP uses the Report to determine a level
of risk for each state and provides tiered support for program improvement and risk reduction
based on the State’s level of risk. States must develop state program improvement plans based on
OSEP’s risk determination.
Data used for the APR indicators are also used by the USBE SES for the Results Driven
Accountability (RDA) process. The USBE SES annually sends a letter to each LEA reporting the LEA’s
performance on each APR indicator in relation to the state targets along with additional data
points. The USBE SES determines a level of risk for each LEA as well as a Program Implementation
Monitoring Tier. The USBE SES provides tiered supports and activities for program improvement
and risk mitigation based on the LEA’s level of identified risk. LEAs must develop an annual
Program Improvement Plan (PIP) to use as a tool in reducing their individual high-risk indicators
and improve outcomes for students with disabilities.

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SIX PRINCIPLES OF IDEA
I. Free Appropriate Public Education (FAPE)
Free appropriate public education (FAPE) means special education and related services that—
(a) Are provided at public expense, under public supervision and direction, and without
charge; (b) Meet the standards of the USBE and Part B of the IDEA; (c) Include preschool,
elementary school, and secondary school education in Utah; and (d) Are provided in
conformity with an individualized education program (IEP) that meets the requirements of
Part B of the IDEA and these Rules (Rules I.E.18.).
II. Appropriate Evaluation
A team of qualified professionals must use a variety of formal and informal assessments,
existing academic achievement data, performance data, and information provided by the
parent(s) in order to determine eligibility and the content of the student’s IEP. Evaluation
activities include gathering information related to enabling the student to be involved in and
progress in the general curriculum or, for preschool students, to participate in appropriate
activities (Rules II.F.).
III. Individualized Education Program
Individualized education program (IEP) means a written statement for a student with a
disability that is developed, reviewed, and revised in accordance with Part B of the IDEA and
these Rules (Rules I.E.24.).
IV. Least Restrictive Environment (LRE)
Least restrictive environment (LRE) means that, to the maximum extent appropriate, students
with disabilities, including students in public or private institutions or other care facilities, are
educated with students who are not disabled. Special classes, separate schooling, or other
removal of students with disabilities from the regular education environment occurs only if
the nature or severity of the disability is such that education in regular classes with the use of
supplementary aids and services cannot be achieved satisfactorily (Rules I.E.27.).
V. Parent and Student Participation in Decision Making
One of the essential purposes of special education is “to ensure the rights of students with
disabilities and parents are protected” (Rules I.A.2.).
The intent of IDEA is to strengthen the role and responsibility of parents and ensure that
families of such children have meaningful opportunities to participate in the education of
their children at school and at home (20 U.S.C. § 1400(c)(5)(B)).
VI. Procedural Safeguards
Safeguards ensure the rights of students with disabilities and their parents are protected,
students with disabilities and their parents are provided with the information they need to
make decisions about the provision of FAPE, and procedures and mechanisms are in place to
resolve disagreements between parties (Rules IV.).

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UTAH PROGRAM IMPROVEMENT PLANNING SYSTEM (UPIPS)
UPIPS is based on the concept that monitoring and improvement are ongoing processes and
include an annual USBE review of state and individual LEA performance in pre-identified areas and
APR Indicators. The review is part of the Results Driven Accountability (RDA) process. Based on
performance, LEAs receive a risk score in each area and Indicator as well as an overall risk score
determination. Methods and procedures used to implement UPIPS are consistent but flexible in
order to adapt to the individual needs of students, educational settings, and administrative
realities.
UPIPS Objectives
The monitoring system has five major objectives:
1. Ensure a meaningful and continuous process that focuses on improving academic and social
outcomes for students with disabilities by linking LEA data to improvement efforts.
2. Ensure compliance with IDEA federal regulations and the Rules.
3. Connect LEA improvement efforts with IDEA and USBE requirements.
4. Support each LEA in the UPIPS process of self-assessment, program planning, and
improvement of compliance and program effectiveness.
5. Link program improvement activities with multi-year professional learning for LEA staff.
UPIPS Themes
UPIPS is founded on the following underlying principles:
• Continuity: The monitoring process is continuous rather than episodic, is linked to systemic
change, and is integrated with self-assessment, continuous feedback, and response.
• Partnership with Stakeholders: The USBE SES and LEA collaborate with diverse stakeholders
in the following areas: collection and analysis of self-assessment data; identification of critical
issues and solutions to problems; and development, implementation, and oversight of
improvement strategies to ensure compliance and improved results for students with
disabilities (SWD).
• LEA Accountability: LEAs are accountable for identifying strengths and areas of concern
based upon data analysis; identifying, implementing, and revising strategies for program
improvement; and submitting annual measurement and progress reports through their
Program Improvement Plans (PIPs).
• Data Driven Self-Assessment Process: Each LEA works with stakeholders to design and
implement a self-assessment process to review and improve outcomes for SWD using data
that align with both the USBE’s and the LEA’s performance goals and the APR Indicators. Data
that are available and can be critical to the self-assessment process may include, but are not
limited to, the Utah State Systemic Improvement Plan (SSIP), areas and APR Indicators that
make up the RDA score, personnel needs, and other LEA improvement efforts and initiatives.
• Technical Assistance: Since the UPIPS process is continuous, technical assistance is a critical
component of program improvement. USBE provides technical assistance such as
professional learning opportunities in each of the five program areas below. LEAs are
encouraged to evaluate and include these components as part of their PIPs.

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UPIPS PROGRAM AREAS
Program Area I—General Supervision (Rules VI.H.2.)
The state and LEA monitoring systems and other mechanisms for ensuring compliance and parent
and student protections are systematic and utilize data to develop corrective action plans and
activities.
All members of the IEP team have access to professional learning and support activities that
facilitate improved educational results for SWD and the implementation of the IDEA.
Evaluation and eligibility procedures focus on needs of SWD and are determined based upon state
definitions, eligibility criteria, and appropriate evaluation procedures.
SWD are making continuous progress within the state and LEA systems for educational
accountability under Utah’s Accountability System (https://schools.utah.gov/assessment/
resources).
Program Area II—Parent Involvement (Rules III.G.)
Programs and services for SWD improve because parents are actively involved in program
improvement activities. Parents of an eligible SWD are aware of and have access to their rights
and responsibilities within the Procedural Safeguards (https://schools.utah.gov/specialeducation/
resources/lawsrulesregulations?mid=942&tid=3).
Program Area III—FAPE in the LRE (Rules I.E.18.)
All SWD receive FAPE in the LRE that promotes a high-quality education and prepares them for
post-school education, employment, and independent living.
Program Area IV—Transition (Rules VII.)
Children exiting Part C of IDEA (Birth–age 2) who are eligible for Part B of the IDEA (ages 3–21),
have IEPs developed and implemented by their third birthdays.
All SWD, beginning at age 14, or earlier if appropriate, receive individualized, coordinated
transition services, designed within an outcome-oriented process that promotes movement from
school to post-school activities.
Program Area V—Disproportionality (Rules VIII.B.12.)
Students are identified as eligible under the IDEA following state and LEA policies and procedures
that ensure those from ethnic and racial minority backgrounds are not inappropriately identified.

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Program Area Components
General Supervision FAPE in the LRE Parental Transitions Disproportionality
APR Indicators APR Indicators Involvement APR Indicators APR Indicators
3, 11, 15 1, 2, 4, 5, 6 APR Indicator 8 7, 12, 13, 14 9, 10
• Child Find • Individualized Education • Evidence of parent • Part C to Part B • Prevalence and
• Forms Programs (IEP) participation o Transition Categories of
• Surrogate Parents o Present Levels of Academic • Written Prior Planning with Disabilities, Race,
• Evaluation/Eligibility/IEE Achievement and Notice Students Learning and Ethnicity
procedures Functional Performance • Notice of Meeting English
• Timelines (Evaluation and (PLAAFP) and Goals • Progress Reports o Utah Preschool
Reevaluation) o Service Delivery, including • Procedural Outcomes Data
• English Proficiency Related Services Safeguards Notice (UPOD)
Assessments o Special Factors • Parental Consent o IEP in Place by 3rd
• Qualified Staff o Statewide Assessment • Communication in Birthday
• Confidentiality o Extended School Year (ESY) a Variety of • School to Post-
• Statewide Assessment o Behavior Intervention Plan Languages School
• Policies and Procedures (BIP) and Health Care Plan • Disciplinary o Transition Plans,
• Fiscal Management o Accommodations Procedures (LRBI) Age 14+
• Evaluation Materials • Timelines (IEP and • Translator/ o Post-secondary
• Referral Process Placement) interpreter Goals
• Professional Learning • Physical Education o Age-Appropriate
• Access to the General Transition
Curriculum Assessments
• team Membership o Course of Study
• Least Restrictive o Summary of
Environment/Placement Performance
• Request for IEP meetings o Age of Majority
• Discipline • Notice to Adult
• Graduation/Dropout Rates Students
• Modifications and supports

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UTAH SPP/APR/SSIP
The Annual Performance Report (APR) is a federal report submitted to OSEP on an annual basis
regarding state performance on 17 Indicators. Each LEA annually receives an individualized APR
that identifies if the LEA met state targets. The 17 Indicators are described below.
Relevant Documents
 Utah State Performance Plan (SPP), Annual Performance Report (APR), and State Systemic
Improvement Plan (SSIP)
(https://schools.utah.gov/specialeducation/resources/datareporting?mid=936&tid=1)
 Utah’s Plan to Ensure Equitable Access to Excellent Educators
(https://schools.utah.gov/curr/resources/educatorexcellence)
 Utah State Board of Education Strategic Plan
(https://schools.utah.gov/board/utah/strategicplan)
Indicators in the Annual Performance Report (APR)
Indicator 1 Improving graduation rates for students with disabilities.
Indicator 2 Decreasing dropout rates for students with disabilities.
Indicator 3 Ensuring all students with disabilities participate and are proficient in statewide or
alternate assessments.
Indicator 4 Reducing suspension and expulsion rates for students with disabilities.
Indicator 5 Providing services for students with disabilities in the least restrictive environment.
Indicator 6 Providing services for preschool students with disabilities in the least restrictive
environment.
Indicator 7 Improving cognitive and social outcomes for preschool students with disabilities.
Indicator 8 Improving parent involvement in their student’s special education program (parent
survey).
Indicator 9 Reducing disproportionality of cultural groups in special education overall.
Indicator 10 Reducing disproportionality of cultural groups in individual disability categories.
Indicator 11 Improving efforts to locate, evaluate, and serve students with disabilities (Child
Find) (initial evaluations completed within 45 school days).
Indicator 12 Ensuring a smoother transition from preschool programs to school-based programs
(IEP developed and implemented by eligible students’ third birthday).
Indicator 13 Improving transition services for students with disabilities at the secondary level
(complete transition plans for students age 14+).
Indicator 14 Improving the outcomes for students moving from secondary to postsecondary
activities (post-school outcomes survey).
Indicator 15 Increasing the use of resolution sessions to resolve due process hearings.
Indicator 16 Increasing the use of mediation to resolve differences between families and
schools.
Indicator 17 State Systemic Improvement Plan (SSIP).

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APR Determination: Framework for Recognition, Assistance, and Intervention
OSEP uses information from the SPP/APR, information obtained through monitoring visits, and any
other public information to annually determine if the state:
• Meets requirements and purposes of the IDEA
• Needs assistance in implementing the requirements of the IDEA
• Needs intervention in implementing the requirements of the IDEA
• Needs substantial intervention in implementing the requirements of the IDEA
The USBE SES compares each LEA’s scores for Indicators 1–14 to a group of cut scores to make a
determination for each LEA. LEAs are able to access their individual reports in UPIPS.

USBE SES TIERED SUPPORT AND ACTIVITIES STRUCTURE

The USBE SES provides differentiated levels of monitoring and support to LEAs based on the
assigned risk score given through the Results Driven Accountability (RDA) process. While the USBE
SES continually monitors IDEA compliance, a focus has also been placed on the systematic
evaluation of the impact of special education services on student outcomes. The USBE SES has
conceptualized its IDEA general supervision, monitoring, and accountability systems to more
effectively support LEAs in delivering compliant special education programs.
Levels of risk are determined by an annual data review conducted by the USBE SES. Data sources
used for this review are based on state and federal priorities. Data sources include, but are not
limited to, APR Indicators 1–14, internal monitoring, compliance data, fiscal data, timely and
accurate submission of data, scoring completeness of the PIP, findings, etc.
The initial RDA and APR determinations are provided in a letter annually to LEA special education
directors typically by the middle of February. LEAs then can appeal within three weeks of receiving
the letter to correct any data errors. A final letter is sent to LEA superintendents/directors and
special education directors following the appeals deadline, but no later than April 1, stating the
final determination of level of risk for RDA.
RDA risk is determined on a 1–5 tier basis with 1 being the lowest level of risk and 5 the highest.
The risk score received governs the level of support and guidance the USBE SES will provide an LEA
during the next school year. Risk scores are based on the data sources and do not measure the
implementation of special education services or the quality of an LEA’s special education program.
While the USBE SES monitoring and technical assistance efforts continue to address compliance
issues, most efforts focus on working collaboratively with LEAs. Together, the USBE SES and LEAs
work to develop and strengthen capacity to implement, scale-up, and sustain LEA-level systems
that result in improved outcomes for students with disabilities (SWD).
Supporting Tier (Risk Level 1)
Supporting Tier Description
LEAs in the Supporting Tier demonstrate the minimum level of risk. They show successful self-
monitoring, high levels of compliance with IDEA regulations, acceptable rates of positive outcomes
for SWD, and effective use of professional learning resources. LEA-specific areas of
need/improvement are targeted through activities and interventions outlined in a Program

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Improvement Plan (PIP) developed by the LEA. A progress report on the PIP is submitted annually
by the LEA. LEA special education program implementation is supported by the USBE SES for LEAs
in this tier.
Supporting Tier Supports Available
LEAs in the Supporting Tier have access to funding for special pilot projects or innovative
approaches that have the goal of improving outcomes for SWD. Projects must be aligned with
Utah’s State Systemic Improvement Plan (SSIP). LEAs have access to universal supports and
activities from the USBE SES. This includes professional learning and technical assistance, USBE SES
guidelines and technical assistance manuals, and any online resources.
Supporting Tier Activities
LEAs in the Supporting Tier are required to conduct a data review with an LEA stakeholder steering
committee to evaluate the special education program and determine areas of strength and areas
of need. As part of the data review, steering committees are expected to examine LEA policies,
procedures, and practices. Additionally, the steering committee should review student outcome
data, APR/RDA data, dispute resolution data, compliance data, stakeholder input, and any other
data the LEA has available or would like to collect. After identifying areas of need, the LEA creates
a PIP to address those areas of need and submits the final plan to the USBE SES by June 30. LEAs
that would like USBE SES feedback on their PIPs before June 30 must submit a draft PIP by April 30.
Guiding Tier (Risk Level 2)
Guiding Tier Description
LEAs in the Guiding Tier demonstrate low risk. They show successful self-monitoring, high levels of
compliance with IDEA regulations, acceptable rates of positive outcomes for students with
disabilities, and effective use of professional learning resources. However, one or more areas of
minor need have been identified. USBE SES and LEA identified areas of need are targeted through
activities and interventions outlined in a PIP developed by the LEA with guidance from the USBE
SES if required or requested. A progress report on the PIP is submitted annually by the LEA. LEA
special education program implementation is guided by the USBE SES for LEAs in this tier.
Guiding Tier Supports Available
LEAs in the Guiding Tier have access to technical assistance for conducting a data review, as well as
for areas of identified need. LEAs have access to universal supports with possibly some targeted
supports from the USBE SES. This includes professional learning and technical assistance, USBE SES
guidelines and technical assistance manuals, and any online resources.
Guiding Tier Activities
LEAs in the Guiding Tier are required to conduct a data review with an LEA stakeholder steering
committee to evaluate the special education program and determine areas of strength and areas
of need. As part of the data review, steering committees are expected to examine LEA policies,
procedures, and practices. Additionally, the steering committee should review student outcome
data, APR/RDA data, dispute resolution data, compliance data, stakeholder input, and any other
data the LEA has available or would like to collect. After identifying areas of need, the LEA creates

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a PIP to address those areas of need and submits the final plan to the USBE SES by June 30. LEAs
that would like USBE SES feedback on their PIPs before June 30 must submit a draft PIP by April 30.
Assisting Tier (Risk Level 3)
Assisting Tier Description
LEAs in the Assisting Tier demonstrate medium risk. They have shown one or more areas of
moderate need. USBE SES identified areas of need are targeted through activities and
interventions outlined in a PIP developed by the LEA with assistance from the mentor assigned
through the USBE SES if required or requested. A progress report on the PIP may be reviewed by
the assigned mentor before the plan is submitted. LEA special education program implementation
is assisted by the USBE SES for LEAs in this tier.
Assisting Tier Supports Available
LEAs in the Assisting Tier are provided professional learning on conducting a data review and a
root cause analysis. The USBE SES provides the LEA with support up to two hours a month by the
assigned mentor to help reduce the LEA’s risk. LEAs have access to targeted supports from the
USBE SES. This includes professional learning and technical assistance designed to address the
LEA’s areas of need. LEAs also have access to USBE SES guidelines and technical assistance
manuals, as well as any online resources.
Assisting Tier Activities
LEAs in the Assisting Tier are required to conduct a data review with an LEA stakeholder steering
committee to evaluate the special education program and determine areas of strength and areas
of need. The LEA may receive UPIPS support as part of this process. As part of the data review,
steering committees are required to examine LEA policies, procedures, and practices. Additionally,
the steering committee should review student outcome data, APR/RDA data, dispute resolution
data, compliance data, stakeholder input, and any other data the LEA has available or would like to
collect. After identifying areas of need, the LEA creates a PIP to address those areas of need. The
LEA may utilize UPIPS support to review the PIP before submitting the final plan by June 30. LEAs
that would like USBE SES feedback on their PIPs before June 30 must submit a draft PIP by April 30.
LEAs will also be able to receive UPIPS support to make corrections before the final deadline.
Coaching Tier (Risk Level 4)
Coaching Tier Description
LEAs in the Coaching Tier demonstrate high risk. They have demonstrated either one area of
intense need or multiple areas of moderate need. USBE SES identified areas of need are targeted
through activities and interventions outlined in a PIP jointly developed by the LEA and USBE SES. A
progress report on the PIP is submitted annually by the LEA and may be reviewed by the coach
assigned through the USBE SES before the plan is submitted in UPIPS. LEA special education
program implementation is coached by the USBE SES for LEAs in this tier.
Coaching Tier Supports Available
LEAs in the Coaching Tier will receive up to four hours per month of UPIPS support as well as
technical assistance for conducting a self-assessment. This includes facilitated development of a
professional learning and technical assistance plan designed to address the LEA’s areas of need.

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LEAs also have access to USBE SES guidelines and technical assistance manuals, as well as any
online resources.
Coaching Tier Activities
LEAs in the Coaching Tier are required to conduct a data review and root cause analysis with an
LEA stakeholder steering committee to evaluate the special education program and determine
areas of strength and areas of need. The LEA may receive UPIPS support as part of this program
improvement planning process. As part of the data review, steering committees are required to
conduct a self-assessment of the LEA’s areas of identified need. The self-assessment must include
an examination of LEA policies, procedures, and practices. Additionally, the steering committee
must review student outcome data, APR/RDA data, dispute resolution data, compliance data,
stakeholder input, and any other data the LEA has available or would like to collect. Additional
data on LEA-identified areas of need are collected through an onsite visit. After identifying areas of
need, the LEA creates a PIP to address those areas of need. The LEA may receive UPIPS support in
developing the PIP prior to the LEA submitting the final plan by June 30. LEAs in this tier are
required to submit a draft PIP by April 30 to receive feedback from the USBE SES. LEAs will also be
able to receive UPIPS support to make corrections before the final deadline. A full onsite
monitoring visit may be scheduled for the current or following school year.
Directing Tier (Risk Level 5)
Directing Tier Description
LEAs in the Directing Tier demonstrate highest risk. They have demonstrated multiple areas of
moderate and/or intensive need. USBE SES identified areas of need are targeted through activities
and interventions outlined in a PIP jointly developed the LEA and USBE SES. At a minimum, a
written progress report based on the PIP is submitted annually by the LEA. The report may be
reviewed by the support person assigned through the USBE SES prior to submission. LEA special
education program implementation is directed by the USBE SES for LEAs in this tier.
Directing Tier Supports Available
LEAs in the Directing Tier are required to conduct a data review and a root cause analysis. They will
have the opportunity to receive information from LEAs who have effectively decreased their risk
as well as collaborate with the USBE SES and other at-risk LEAs. The assigned support person
provides intensive support up to six hours per month; more hours can be approved upon LEA
request. LEAs have access to the development of a professional learning and technical assistance
plan designed to address the LEA’s areas of need. The USBE SES provides support to the LEA in
building capacity across the LEA, and financial supports are available to assist the LEA in filling
programmatic needs. LEAs have access to USBE SES guidelines, technical assistance manuals, and
any online resources.
Directing Tier Activities
LEAs in the Directing Tier are required to conduct a data review and root cause analysis with an
LEA stakeholder steering committee to evaluate the special education program and determine
areas of strength and areas of need. The assigned support person may participate in this process.
As part of the data review, steering committees are required to conduct a self-assessment of the
LEA’s areas of identified need. The self-assessment must include an examination of LEA policies,
procedures, and practices. Additionally, the steering committee must review student outcome

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data, APR/RDA data, dispute resolution data, compliance data, stakeholder input, and any other
data the LEA has available or would like to collect. Additional data on LEA-identified areas of need
are collected through an onsite visit. After identifying areas of need, the LEA creates a PIP to
address those areas of need. The assigned support person may assist the LEA in developing the PIP
prior to the LEA submitting the final plan by June 30. LEAs in this tier are required to submit a
draft PIP by April 30 in order to receive feedback from the USBE SES. LEAs will also have time to
work with their support person to make corrections before the final deadline. A full onsite
monitoring visit may be scheduled for the current or following school year.

USBE SES MONITORING VISIT PROCESS

Selecting LEAs for Monitoring Visits
The USBE SES is required to monitor implementation of IDEA Part B and the Rules (Rules VIII.C.). To
this end, the UPIPS team selects a sample of LEAs for a full monitoring visit each school year. LEAs
with overall RDA risk scores of Coaching (4) or Directing (5) are more likely to receive a full
monitoring visit during the current school year or in the following school year. Other LEAs may also
be selected to receive a full monitoring visit based on other factors including, but not limited to,
dispute resolution, investigations related to a hotline tip, fiscal concerns, specific populations
(youth in care/custody), length of time between visits, and other areas as determined by the USBE
SES.
Full Monitoring Visit Components
A full monitoring visit includes the following components:
 Orientation  LEA Staff  Student  Student focus  Parent focus
meeting interviews observations group(s) group(s)
 File reviews  Exit meeting
A UPIPS specialist is assigned as the monitoring team lead and main contact for the LEA. The
monitoring team lead ensures the LEA receives a letter six to eight weeks prior to the visit with
specific details of the visit.
The LEA is provided a link to an interactive schedule to logistically coordinate and communicate
about the visit. This is intended to allow the LEA to schedule the activities, so the onsite visit
minimizes impact on student learning. The schedule for the onsite visit will be completed at least
one week prior to the visit.
Orientation Meeting
At the beginning of the visit, there can be an orientation meeting between the UPIPS monitoring
team and the LEA Steering Committee. The members of the Steering Committee are determined
by the LEA. The monitoring team lead can present an overview of the UPIPS program and the
onsite monitoring visit activities. The LEA will assist the monitoring team in establishing a Wi-Fi
connection at the start of the visit.
File Reviews
The LEA is asked to provide caseload details for each special education teacher and related service
provider in the UPIPS program prior to the visit. Caseload details include students’ names, grades,
disability categories, settings, current IEP dates, home language, Statewide Online Education

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Program (SOEP) status, and State ID (SSID) numbers. If the LEA has more than 15 files, the
monitoring team lead will select a minimum of ten files to review. File selection averages out to
two files per educator and should represent a variety of student grade levels, classifications, as
well as files where English is not the student’s first language.
File reviews are recorded in the UPIPS program, unless otherwise specified by the monitoring team
lead. Case managers are encouraged to engage with the file reviewers while their selected files are
being reviewed. This provides an opportunity for file reviewers to recognize compliance efforts
and for LEA staff to learn about any errors and needed corrections as they are found. If the case
manager is unable to attend the review, it is recommended that an alternate individual attend,
although it is not a requirement. To maintain confidentiality, students cannot be in the file review
or interview rooms.
LEA Staff Interviews
Interviews meet two objectives of the monitoring visit. First, they provide the USBE SES with an
understanding of the LEA to identify strengths and areas of concern that may need to be
addressed. Second, they provide an opportunity for one-on-one professional learning between the
UPIPS monitoring team and LEA staff. Conversation during the interviews is encouraged and
questions from the LEA are welcomed.
The LEA will determine which staff will be interviewed and interviews should be conducted in a
private room if possible. Although current interview questions are posted on the USBE SES UPIPS
webpage, LEA staff are asked not to bring notes to the interviews. The monitoring team member
conducting the interview will provide the LEA staff with a copy of the questions. The following LEA
staff will be interviewed at each school site, as available:
• Special education director (or another LEA administrator)
• School administrator(s)
• Special education teacher(s)
• General education teacher(s)
• School counselor(s)
• Related service provider(s) – Speech Language Pathologist (SLP), Occupational Therapist (OT),
Physical Therapist (PT), School Psychologist
Student Observations
Monitoring team members will visit special education and general education classrooms to
observe specially designed instruction aligned to students’ IEP goals. Specific students are chosen
by the LEA in advance of the visit to minimize disruption to the learning environment. The
monitoring team lead will ensure copies of student IEPs are uploaded to the UPIPS program for
review prior to the observations.
Student Focus Groups
At each secondary site visited, the LEA will be asked to gather five to ten students with a range of
grade levels and disability classifications for a focus group. The monitoring team will need space at
the school to conduct the focus group. LEA staff are excused from the focus group. Questions
asked during the student focus group center on general questions about student experiences and
school involvement. No questions regarding specific disabilities will be asked.

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Parent Focus Groups
The parent focus group is organized by the LEA and facilitated by the Utah Parent Center (UPC). It
generally lasts an hour and a half. A monitoring team member will attend to take notes in the
UPIPS program. The focus group is usually held the night before the visit but may take place any
evening during the visit if the visit is multiple days. The preferred start time is 6:00 PM. If it is not
possible to meet at 6:00 PM, the meeting can take place as early as 5:00 PM, but end no later than
8:00 PM.
If a parent requires an interpreter and/or an accommodation, the LEA must contact the USBE SES
at least two weeks in advance of the focus group so the parent need can be met. The LEA invites
parents of students receiving special education services to attend. A flyer is provided to the LEA to
use, if desired.
Exit Meeting
Following the completion of the above visit activities, the UPIPS monitoring team will return to the
LEA to hold an exit meeting with the Steering Committee. During the exit meeting, the monitoring
team lead will provide a verbal summary of what was found during the visit. The LEA is encouraged
to provide feedback at the meeting about what worked and what could be improved in a full
monitoring visit. A comprehensive written report will be provided to the LEA following the visit.

IDENTIFICATION AND CORRECTION OF NONCOMPLIANCE

Compliance Identification
The USBE SES reviews data collected from LEAs during full monitoring and indicator visits to ensure
compliance with the regulatory requirements of the IDEA and the Utah State Board of Education
Special Education Rules. Data collected on the date of the visit is reported in the APR and RDA
scores as the level of compliance. As outlined by OSEP, the LEA is not provided an opportunity to
correct noncompliance prior to reporting.
LEAs are considered substantially compliant, relative to each compliance indicator, if the LEA’s
data indicates a very high level of compliance (generally 95% or above) (OSEP Memo 09-02). OSEP
has stated a very low level of compliance exists for indicators at 75% or below target (OSEP Memo
09-02).
LEAs have the option to correct areas of student-specific noncompliance within 85 days of data
collection. The USBE SES reviews corrections of student-specific noncompliance and the additional
data submitted by the LEA to verify the corrections data demonstrate compliance. After the 85-
day correction window, written findings of noncompliance will be issued to the LEA
superintendent/director if the LEA data is below 100% compliant.
Correction of Noncompliance
OSEP requires that all noncompliance be corrected as soon as possible, but in no case later than
one year from the date of identification of noncompliance. The USBE SES has worked to create a
method that will require the least amount of time and effort for LEAs while providing the USBE SES
with evidence verifying corrections.
Before the USBE SES can conclude and report that noncompliance has been corrected, it must first
verify, consistent with OSEP Memo 09-02, that the LEA: 1) has corrected each individual case of

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student-specific noncompliance (Prong 1), and 2) is correctly implementing the specific regulatory
requirements (i.e., subsequently achieved 100% compliance) (Prong 2), based on USBE SES review
of the corrections data.
Prong 1: Correcting Each Individual Case of Student-Specific Noncompliance
To correct noncompliance concerning student-specific requirements subject to a specific timeline,
the LEA must submit documentation that the required action (i.e., the evaluation, reevaluation, or
IEP) was completed, though late.
To correct noncompliance concerning student-specific requirements not subject to a specific
timeline, the LEA must submit documentation that the LEA has corrected each individual case of
noncompliance, unless the student is no longer within the jurisdiction of the LEA. These items
include requirements such as:
• Eligibility determination is current and complete
• Student meets eligibility criteria
• Evaluation Summary Report is current and complete
• IEP content meets criteria (i.e., measurable goals, Present Levels of Academic Achievement
and Functional Performance (PLAAFP) statements include current data and how the disability
affects progress in the general curriculum, statewide assessment, Extended School Year (ESY)
decision, etc.)
• IEP is current and complete
• Consent for Initial Placement signed by parents
• Transition Plan is complete
• Age of Majority notification
• Transfer of Rights notification
• Prior Written Notice
• Documentation of IEP and eligibility team participation
• Change in Placement
The LEA documents the required evidence by indicating correction and providing it to a UPIPS
team member for review in person, or by uploading the evidence to the UPIPS program. If the LEA
provides evidence of correction of all noncompliance within 85 days of data collection, the LEA will
not be required to provide any additional files for review.
Prong 2: Correctly Implementing the Specific Regulatory Requirements (i.e., Subsequently Achieved
100% Compliance)
If the USBE SES review of the corrections data submitted by the LEA during Prong 1 reveals
noncompliance still exists, the LEA will be required to provide additional student special education
files for review. The number of additional files provided by the LEA will be determined based on
the identified root cause of noncompliance.
The LEA documents it has subsequently achieved 100% compliance by providing evidence to a
UPIPS team member for review in person, or by uploading the evidence to the UPIPS program.

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Additional Noncompliance Corrections
The USBE SES occasionally finds additional compliance errors during the corrections process. Any
errors found during the process are not included in APR or RDA reporting. LEAs will not receive a
written finding for these errors unless several files are found with the same error.
Compliance errors found during the corrections process must be corrected and verified with a
UPIPS team member.
The USBE SES is committed to supporting LEA efforts to improve results for students with
disabilities through the framework of compliance.
Enforcement
In addition to monitoring implementation of IDEA Part B and the Rules, the USBE SES is also
required to enforce implementation (Rules VIII.C.). Enforcement is necessary when the USBE SES
obtains evidence of denial of rights outlined in the IDEA and/or systemic errors in procedural and
substantive implementation. Evidence can be identified through a variety of methods including,
but not limited to, file reviews, observations, interviews, dispute resolution, focus groups, and
fiscal compliance. Methods of enforcement include technical assistance, conditions on funding,
corrective action or improvement plan, and withholding funds (Rules VIII.C.).

POLICIES AND PROCEDURES MANUALS

LEAs are required to have a local board-approved policies and procedures manual on file with the
USBE SES. The policies and procedures manual must outline the specific learning disability (SLD)
method the LEA is using along with other mandated requirements outlined in Rules IX.A.2.
Policies and procedures manuals must be updated within one year of the Rules being updated and
given final approval through the USBE (Rules IX.A.3). LEAs should submit manuals to the USBE SES
for approval prior to submitting to the LEA’s local board for approval. The USBE SES will notify LEA
of approval/disapproval via email. Submitting to the USBE SES first will prevent LEAs from having
to submit to their local board for approval multiple times. The USBE SES may not be able to
approve it during the first attempt due to missing requirements. Once approval is received from
both the USBE SES and the LEA’s local board, LEAs may post the policies and procedures manual
on their websites.
The policies and procedures remain in effect until any of the following occur:
• The LEA submits modifications to USBE SES that have been deemed necessary by the USBE or
LEA;
o The provisions of the Rules apply to any modifications in the same manner and to the
same extent as the original policies and procedures.
• The USBE staff gives the LEA notice of a new interpretation of the IDEA by Federal or State
courts, or a change in Federal statute.
• There is an official finding of noncompliance with Federal or State law or regulations that
requires a change in the LEA’s policy and procedures (Rules IX.A.4.).
LEAs must determine which SLD method will be used before writing the policies and procedures
manual. LEAs can choose: 1) Response to Intervention (RtI); 2) Combination; or 3) Alternative
Research-Based Procedures, which includes Patterns of Strength and Weakness (PSW). Model

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policies and procedures manuals (https://schools.utah.gov/specialeducation/programs/
rulespolicies?mid=4962&tid=1) are available on the USBE Special Education Rules and Policies
webpage for all methods for both districts and charter schools. The model manuals outline the
information required to be included in the policies and procedures manual. They also identify the
sections the LEAs must complete regarding the individual LEA and its special education program.
LEAs are not required to use the model manuals, though it is suggested to ensure all required
information is included.

PROGRAM IMPROVEMENT PLAN (PIP)

Definition
A Program Improvement Plan (PIP) is intended to support an LEA in the development and
implementation of a comprehensive multi-year improvement plan. The PIP addresses areas of
concern as identified through the LEA data review process, with consideration of the RDA
determination and input from the stakeholder steering committee. The improvement activities
should focus on improving student outcomes and compliance with IDEA. PIPs should be viewed
comprehensively, and considered in whole, rather than divided into sections.
Purpose
One purpose of the PIP is to assist LEAs in identifying areas for program improvement, prioritizing
those areas, and developing meaningful plans to improve practices in special education. Another
critical purpose of the PIP is to improve the effectiveness, equity, timeliness, and safety of all staff
and students and improve the quality of the services being provided. As LEAs develop the PIP,
high-leverage and research-based practices should be used to achieve these purposes.
An effective PIP requires the LEA to conduct a comprehensive data analysis and needs assessment
with the stakeholder steering committee to systematically identify areas of strength and areas of
need. Once needs are identified, a root cause analysis would assist an LEA in establishing rigorous,
yet attainable goals used to establish activities and interventions to support improvement.
LEA Program Improvement Process
Each of the parts outlined below are a required piece of the process. The tips and ideas under each
part are provided from best practices and evidenced-based strategies to assist in this process.
However, the processes used are left to the expertise of the LEA.
Part 1: Gather Stakeholders Who Can Help with the Process
Build a stakeholder steering committee by starting with individuals directly involved with the LEA’s
special education program. Additional individuals can be considered as the group recognizes needs
and establishes goals to meet those needs. Stakeholders to consider include:
• The special education director
• A school administrator
• A general education teacher
• A special education teacher (including preschool, if applicable)
• A parent of a student with disabilities
• A student with disabilities, if appropriate
• Related services staff

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 • Other LEA personnel (e.g., technology, maintenance, media specialist)
• Community partnership members
• Local board members
• Advocacy groups (e.g., Utah Parent Center)
• Directors/staff from other LEA programs (e.g., Curriculum, Assessment, YIC, online personnel)
• Those who affect and are affected by special education systems
Part 2: Assess and Evaluate Program
Review quantitative and qualitative data, formal and informal evaluation, multiple stakeholder
perspectives, etc. Data to consider include:
• Federal and State data
o RDA
o APR
o UPIPS monitoring visit data
o Dispute Resolution
o Fiscal
• Current LEA data
o APR and RDA data (delayed by one to two years)
o Data Gateway
o UTREx
o Internal monitoring
o Self-Contained and Resource Accounting Management (SCRAM)
o UPIPS compliance (internal monitoring, full monitoring, indicator visits)
o Staff interviews (LEAs can use the UPIPS interview questions to conduct internally)
o Classroom observations
o Teacher licenses and endorsements for current assignments
o Caseloads of special education case managers
o Adequacy of LEA support for teachers in schools (e.g., staffing, leadership, supervision,
and professional learning)
o The LEA system for identifying professional learning needs
o Records of professional learning activities provided to all members of IEP team (including
LEA representative, general education teachers, special education teachers, and parents)
o How the LEA ensures timely and accurate data (i.e., what procedures are in place for
editing and validating data)
o Policies and procedures in place and followed across the LEA
o Strengths, needed improvements, and areas of noncompliance
Identify the relationship between LEA data and the following components:
• Climate (perceptions, biases, beliefs, etc.)
• Curriculum and instruction
• Leadership
• Family and community engagement
• Professional learning and staff capacity

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 • Student outcome data (assessment, graduation, etc.)
• Policies and procedures
Part 3: Conduct a Root Cause Analysis
A root cause analysis is a multi-step, systemic process to identify root causes of risk or other areas
of need so plans can produce better long-term outcomes. This is a critical part of the PIP process,
and the following steps are just a snapshot of a root cause analysis. LEAs are encouraged to learn
more about this step in the process through personal research, RDA TA, USBE supports and
resources, etc.
Step 1: Identify the Problem
• Is the problem within LEA control?
• Is the problem measurable?
• Does this problem have the strongest leverage or potential impact?
• Hypothesize where the problem exists: Is the problem a systemic problem or specific to a few
grade levels or settings?
Non-example: Higher education is not adequately preparing teachers for the reality of teaching.
Example: New teachers across the LEA have little understanding of practical ways to collect
accurate data while teaching and do not know what resources or tools are available to them to
support the data collection process.
Step 2: Clearly Define the Problem
• Use clear and concise language with enough detail to make the problem clear.
• Use quantifiable data.
Non-example: We have high turnover of teachers.
Example: Of the teachers we lose each year, 60% are within their first three years of teaching.
When new teachers were given a survey, 85% reported feeling inadequate support with
classroom management and data collection. Adequate time and resources have not been spent
with training new staff on data-driven practices and classroom management techniques.
Step 3: Understand the Problem from Multiple Perspectives
• Make a list of information to be gathered from stakeholders.
• Create a plan for gathering the information.
• Identify specific data tools to be used by stakeholders to review data.
• Develop questions to be asked of all stakeholders.
Step 4: Uncover the Root Cause(s) of Risk or Other Areas of Need
• Start big and broad: what are the working parts of the organization?
o Teachers, students, data measurements, resources, structures/systems, communication,
etc.
o Each stakeholder should help make a list of all the possible ideas for what is causing the
problem.
• Organize the ideas into the broad categories from above.
• Once the problem is identified, the key is to ask, “Why?” at least five times to identify the
root cause of the problem. Each time why is asked, the answer should dig deeper from the
answer to the previous why.

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 Example: Our LEA has high turnover.
• Why?
o Because teachers don’t implement a consistent data collection process.
• Why?
o Because teachers don’t understand how to build data collection into routines.
• Why?
o Because we didn’t train new teachers as they joined our staff.
• Why?
o Because we relied on new teacher mentors and departments to support this in
Professional Learning Communities (PLC) meetings and it wasn’t done effectively.
• Why?
o We didn’t communicate and support PLC and department teams to make sure this
process was well established and implemented consistently.
Hypothesis: Lack of effective data collection and collaboration put strain on the PLC process and
impacted the support that all teachers felt.
Conclusion: In order to decrease turnover of teachers, we need to address data collection
procedures and collaboration in PLC meetings, so educators have more support.
Step 5: Identify and Prioritize LEA Strengths and Needs
Use the following questions to prioritize which needs the LEA is going to address. The areas of
need that answer more of the questions below would be a great starting point for identifying the
highest priorities.
• Which areas have the most needs?
• Which areas could have the biggest impact?
• Which areas can be the most easily changed?
• Which areas would align with other LEA initiatives or plans?
• Which areas have the greatest consequences?
• Which areas impact compliance with LEA, state, and federal requirements?
Write up a summary of the data analysis and list areas of strength and areas of need identified by
the stakeholder steering committee.
This summary is considered the LEA’s present level as to why goals are being written or not
written. The goal would be that anyone who reviews the plan understands how and why the goals
or focus areas were selected by the steering committee.
Step 6: Write Specific, Measurable, Attainable, Realistic, Time-bound, and Challenging (SMART-C)
Goals
Use the areas of need identified in previous steps to guide the goals being written. Any goals that
are written must use the SMART-C format.
• Each area identified as a need and a priority must have a goal that aligns with it.
• Each area with a risk score of 4 or 5 must address activities outlined in the RDA letter.

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 This SMART-C goal quick reference is intended to support LEAs in writing SMART-C goals. Following are examples of things to consider
and not an exhaustive list. The risk score for the PIP is based on whether the SMART-C goals address each of six components.
S – Specific M – Measurable A – Attainable R – Realistic T – Time-bound C – Challenging
Questions to Ask: Questions to Ask: Questions to Ask: Questions to Ask: Questions to Ask: Questions to Ask:
 Who is involved?  How much?  Do the action  Is the target  How much time is  Who is this goal
 What do we want  How many? steps lead us to realistic in needed to going to challenge?
to accomplish?  How will the our goal? relation to the accomplish the (e.g., educators,
 Where will this team know  Do the action baseline data goal? students,
happen? (identify when this is steps have people and the  Is the goal based stakeholders, etc.)
a location) accomplished? responsible? timeframe set? on results from  Do the action steps
 When will this  What is the  Do the action the APR Indicator require training and
Example:
happen? (establish baseline data? steps have a scores? If so, is professional
With a baseline of
a timeframe)  What is the timeframe for the timeframe set learning to meet
5% student
 Which target data? accomplishing appropriate based the goal?
proficiency, a
requirement(s) will  Is the progress each step? on when the data  Does the goal push
target of 85%
this satisfy? Are monitoring plan will be reflected to make reasonable
Note: student proficiency
there any specific to the in the APR scores? gains?
Most goals are in six months
constraints? data that will be
attainable when steps would not be Reflection:
 Why do we want used to
are planned wisely, realistic based on Complete the action
to accomplish this? measure
and a timeframe is the identified skill. steps and re-evaluate
(specific reasons, growth?
established allowing the timeframe. Reset
purpose, and/or
for those steps to be if appropriate.
benefits)
carried out.

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 S – Specific M – Measurable A – Attainable R – Realistic T – Time-bound C – Challenging
Considerations: Considerations: Considerations: Considerations: Considerations: Considerations:
 Specific skills  Baseline data  Clear action steps  The  Timeframe  Student outcomes
 Specific behaviors  Target data that align to the relationship  References to  Professional
(e.g., physical  Numbers goal between the APR data have a learning needs
aggression  Percentages skill, baseline timeframe of at  Goal addresses
resulting in  Timeframe data, target least one year out needs and gives a
suspensions)  Data sources to data, and (e.g., new goals push to achieve
 Specific data use (see PIP timeframe can’t refer to the more than current
sources (see PIP headers) current APR data
headers) because the data
is from a previous
year and can’t be
impacted)
Step 7: Implementation, Measurement, and Assessment
Each goal must include action steps and progress monitoring to assist the LEA in achieving the goal.
• When developing an action plan, it can be helpful to use the goal targets (end outcomes) as a starting point and then break down
the goal into steps needed to accomplish the goal. It is important to have action steps that are sequential.
• Use details to develop an action plan that can be easily understood by a new employee assisting with implementing the plan.
• Program improvement must have check-in points established to determine progress.
• What data collection methods will be used to measure progress?
• What indicators would show the LEA is making progress?
• Establish timelines and assign a point person(s) for progress monitoring.
• Each year, review data and progress on the action plan before updating the PIP.

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INTERNAL STUDENT FILE REVIEW GUIDELINES
An annual internal student file review must be conducted by each LEA no later than June 30 of
each school year. The number of files reviewed is based on the December 1 Child Count of the
previous year. File reviews can be accomplished using the Internal section of the UPIPS program.
December 1 Child Count Number of Files to Review
Up to 500 Students 20 Files (or All)
501–900 Students 35 Files
901–1300 Students 45 Files
1301–1700 Students 55 Files
1701–2000 Students 65 Files
2001–4000 Students 75 Files
4001–6000 Students 100 Files
6001–8000 Students 140 Files
8001–10,000 Students 180 Files
10,001+ Students 200 Files

When an LEA receives a full monitoring visit, the number of files reviewed during the visit will
count toward the required number above for that school year.
Files reviewed must be a representative sample of the LEA and include:
• Preschool, elementary, middle school, and high school files across the LEA geographically;
• Special schools, including YIC, Adult Education, online schools (if any), and SOEP;
• All races/ethnicities;
• Multi-language learners; and
• All disability categories.
NOTE: In order to get a representative sample, the LEA may need to increase the
number of files reviewed.
Noncompliance identified through LEA internal file reviews is not subject to USBE
SES review. However, LEAs must still correct noncompliance identified through
internal reviews within one year as required by OSEP.
An LEA may choose not to use UPIPS to conduct internal file reviews. An alternate internal
monitoring process as robust as the UPIPS Lite Review must be developed and uploaded to the
UPIPS program for approval. The process will be approved/disapproved in the UPIPS program and
will be reviewed annually. Those using an approved alternative method must submit the previous
year’s documentation no later than January 15 for RDA determination. Documentation will also be
accepted during the appeal process of the initial RDA determination.

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TECHNICAL ASSISTANCE AND RESOURCES FOR COMPLIANCE
Strong Start
Strong Start provides new special education directors/leaders in their first three years with
professional learning, resources, and one-on-one mentoring. Those invited to attend may be a
special education director, special education coordinator, special education specialist, or a whole
team within the LEA. Strong Start is intended to support these leadership roles across all LEAs,
regardless of titles. Each LEA is required to meet basic compliance and reporting requirements
outlined in this manual. The roles of those responsible for overseeing these requirements are
determined by the LEA. The intent of the training sessions is to help new special education leaders
establish a strong foundation of knowledge by gaining a more in-depth understanding of the Rules
and compliance with federal and state reporting requirements.
Utah Institute on Special Education Law
The USBE SES hosts the Utah Institute on Special Education Law every summer. This conference is
designed for administrators, educators, service providers, parents, families, and others responsible
for the implementation of the IDEA and the Rules. Information is shared regarding regulatory
requirements, relevant case law, and best practice to ensure students with disabilities receive a
FAPE. For more information about rules and regulations, please visit the USBE Special Education
Rules and Policies (https://schools.utah.gov/specialeducation/programs/rulespolicies) webpage.
Utah Systems Conference
The Annual Utah Systems Conference brings together LEAs and school administrators, teachers,
paraeducators, parents, and student support providers. The conference provides tools intended to
guide LEA teams in evaluating and analyzing current practices, establishing supportive
infrastructure, and utilizing data to improve student outcomes through a Multi-Tiered System of
Supports (MTSS). MTSS is a framework for implementing systemic, evidence-based practices to
maximize student achievement in academics and behavior in preparation for and leading to
college and career readiness. The MTSS model includes universal, targeted, and intensive levels of
support.
Transition Institute
The annual Transition Institute supports post-secondary transition planning and building capacity
to improve college and career readiness for students with disabilities. This institute is designed for
LEA-based teams which may include special educators, post-secondary transition specialists,
general education teachers, parents, administrators, outside agency providers, higher education,
related service providers, school counselors, career and technical education (CTE) counselors,
Vocational Rehabilitation, paraeducators, and others. LEAs learn more about outside agencies,
transition services, and how to use a web-based tool for post-secondary transition planning. For
more resources on post-secondary transition planning, please visit the USBE Special Education
Secondary Transition and Graduation (https://schools.utah.gov/specialeducation/programs/
secondarytransitiongradutation) webpage.

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Targeted Trainings
Co-Teaching
Co-teaching is an instructional model that provides access to the grade-level core to all students.
Co-teaching is an instructional arrangement in which a general education teacher and a special
education teacher deliver core instruction (along with specialized instruction, as needed) to a
diverse group of students in a single space. These co-teaching partnerships require general and
special educators to make joint instructional decisions and share responsibility and accountability
for the learning of all students, while at the same time building on the strengths of each educator
to provide high-quality core instruction paired with needed specialized instruction to meet the
variety of student needs. This professional learning series is a year-long cohort with multiple
learning sessions. The cohort combines methodology and content to support the co-teaching
team.
Indicator 13 (Compliant Transition Plans) Canvas Course
As part of the State Systemic Improvement Plan (SSIP), the USBE has increased the focus on
developing compliant postsecondary transition plans for students who are 14 years old at the time
the IEP is written (Indicator 13). The Indicator 13 virtual Canvas course focuses on creating a
greater understanding of how compliance and effective practices must be utilized in conjunction
with each other to prepare students for further education, employment, and independent living.
The virtual course provides opportunities for participants to work directly with USBE coaches to
receive feedback on student transition plans throughout the training. Additional information
regarding training and resources for developing transition plans can be found on the USBE Special
Education Secondary Transition and Graduation webpage.
Newsletters
Each month, the USBE SES emails two newsletters to LEA special education directors. The
SpEdOmeter for LEA Action contains important information LEAs need to be aware of, deadlines,
and required activities or actions. The SpEdOmeter for LEA Support contains information about
trainings, conferences, best practices, etc.
The USBE SES also provides an online monthly newsletter of articles and professional learning
opportunities aimed at improving outcomes for students with disabilities to subscribers (https://
mtsports.us17.list-manage.com/subscribe?u=751ab87d1fa81859e0e48b064&id=f87b23355a).
Utah Special Educator Administrators’ Meeting (USEAM)
The USBE SES holds quarterly meetings for all special education directors that are held in-person
and streamed online. Meetings include the latest compliance requirements, best practices, new
initiatives, legislative updates, and networking with other special education directors and USBE
staff.
Office of Special Education and Rehabilitative Services (OSERS), Office of Special
Education Programs (OSEP), Office of Civil Rights (OCR)
OSERS, OSEP, and OCR are departments through the federal government that provide guidance for
USBE and LEAs on providing services to students with disabilities. The guidance provided through
these departments is a great source for research and will often be referred to by the USBE SES

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when discussing compliance. Each of these departments publish Dear Colleague Letters to provide
guidance and clarification regarding special education services and compliance. LEAs working to
solve challenging issues may be able to find some answers in these letters. They can be found
using the search function on the U.S. Department of Education (https://www.ed.gov/) website.
Special Education Connection (LRP)
The USBE SES believes in providing educators with the tools needed to support compliance and
providing a FAPE to students. LRP’s Special Education Connection is a national database of proven
strategies, helpful tools, special education case law, federal statutes/regulations, and more. The
USBE SES pays for a subscription to the newsletter for all special education directors and
administrators in the state. Special education directors and administrators may share this resource
with teachers and related services providers. Those with a login may opt-in to receiving a weekly
summary via email to be informed of recent information and available tools. Special education
directors who need login information should reach out to the USBE SES for support.
Fiscal Compliance and Accountability Monitoring
A comprehensive fiscal review is also a piece of USBE SES policies, procedures, and practices. The
purpose of the review is to ensure LEAs are evaluating all areas that impact special education
services and programming. Please refer to the Special Education Fiscal (https://schools.utah.gov/
specialeducation/programs/fiscal) webpage for direction on fiscal compliance.
USBE SES Fiscal and Staff
• Fiscal Awards Manager: Sarah Grisenti ([email protected]), (801) 538-7854
• Federal Funds: Neil Stevens ([email protected]), (801) 538-7819
• State Funds: Cole Shakespear ([email protected]), (801) 538-7576
• Data Reporting: Tami Gear ([email protected]), (801) 538-7724

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