Explore the regulations, objectives, terms, governance, and charter related to linking data between Part C and Part B 619 for effective decision-making and support in education systems.
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Linking Part C and Part B 619 Data Linking Part C and Part B 619 Data What To Know Before You Go What To Know Before You Go Sarah Carter, SD Part C Vivian James, NC Part B Elizabeth Jehangiri, SD Part B Jill Singer, NC Part C Baron Rodriguez, DaSy/PTAC Denise Mauzy, DaSy Sharon Walsh, DaSy 2017 LEADERSHIP CONFERENCE
Session Objectives Session Objectives Understand the IDEA and FERPA regulations that relate to data linking between Part C and Part B 619 Learn about two state experiences related to data linking Part C and Part B 619 Know how to access resources and technical assistance and support for linking Part C and Part B 619 data 2017 LEADERSHIP CONFERENCE 2
Definition Definition of Terms of Terms Uni-Directional Bi-Directional Bi-Directional Sharing Linking Integrating Combining data from two systems into a new system or file (e.g. linking Part C and 619 data in an Microsoft Access database or Excel file) Moving data from one system into another (e.g. migrate child specific data from Part C into 619 data system) Providing data or reports (e.g. sending transition notification data from Part C to Part B 619) 2017 LEADERSHIP CONFERENCE 3
Data Governance Data Governance Management of availability, usability, integrity, quality, and security of data We need to formalize some of our program s data governance policies. Can I still pursue a data linking partnership? Organizational process and a structure Establishes responsibility Creation and enforcement of policies, roles, responsibilities, and procedures 2017 LEADERSHIP CONFERENCE 4
Joint Part C and Part B 619 Data Linking Joint Part C and Part B 619 Data Linking Charter Charter Purpose and vision for data linking work Scope of joint work and shared goals Stakeholders impacted 2017 LEADERSHIP CONFERENCE 5
Joint Part C and Part B 619 Data Linking Joint Part C and Part B 619 Data Linking Charter Charter Time parameters (longevity of effort, frequency of meetings, and review of work) Relation to other data efforts Composition of joint team 2017 LEADERSHIP CONFERENCE 6
Joint Part C and Part B 619 Data Linking Joint Part C and Part B 619 Data Linking Charter Charter Decision making process/authority for joint work Communicating about progress Leadership endorsement and approval 2017 LEADERSHIP CONFERENCE 7
Technical Considerations Technical Considerations Unique IDs Secure Transfer of Data 2017 LEADERSHIP CONFERENCE 8
Unique IDs Unique IDs Program Specific vs. Cross-Program Types of Unique IDs SSN Combo of Demographic Info (First two initials first name+ month/year of birth+last four digits of SSN) System assigned (From data system, E-Scholar, etc.) 2017 LEADERSHIP CONFERENCE 9
Unique IDs Unique IDs Same Unique ID exists in both Part C and Part B 619 Data Systems (you re lucky!) Different Unique ID in Part C and Part B 619 Data Systems (most common) Create a Unique ID Examine other linking efforts in your state (SLDS, ECIDS, etc.) 2017 LEADERSHIP CONFERENCE 10
Unique IDs Unique IDs Matching Reconciling near-matches (probabilistic matching) Importance of Data Quality 2017 LEADERSHIP CONFERENCE 11
Secure Transfer of Data Secure Transfer of Data Review established policies for Part C and Part B 619 data systems Determine how to combine data Direct interface/interoperability (least likely) Data export and matching (e.g. MS Excel, Access) Print-outs (not recommended) 2017 LEADERSHIP CONFERENCE 12
Secure Transfer of Data Secure Transfer of Data Security of Data At export During Transfer (email, flash drive, cloud) Combining data (in Excel or Access) Storing Data Questions Who has access? Where is data stored? In what format is it stored? 2017 LEADERSHIP CONFERENCE 13
Consider Two Scenarios Consider Two Scenarios Scenario A Scenario B Single lead agency, Education, two separate data systems for Part C and 619 Two different lead agencies, Health for Part C and Education for 619 each has its own data system 2017 LEADERSHIP CONFERENCE 14
Privacy Considerations Privacy Considerations What data will need to be shared AND how will the data flow? Where does the data reside as a result of your inventory? ? What data sharing agreements need to be in place? Requirements? What federal, state, and local laws apply to data sets? 2017 LEADERSHIP CONFERENCE 15
Disclosure of PII From Education Records Disclosure of PII From Education Records under FERPA under FERPA FERPA permits non-consensual disclosure of PII from education records under several exceptions Staff or employees who need access to perform duties School official exception Legitimate educational interest External entities Studies exception Audit or evaluation exception Uninterrupted Scholars Act Other (e.g., court order, health or safety emergency) 2017 LEADERSHIP CONFERENCE 16
Note on the Studies Exception Note on the Studies Exception The "Audit/Evaluation exception in 34 CFR 99.31(a)(3) and 99.35 is the most appropriate exception under IDEA and FERPA for data sharing arrangements for the IDEA early childhood community. In the very limited instance in which IDEA Part C or IDEA Part B section 619 agencies or programs propose to consider using the Studies exception under FERPA, such agencies and programs will want to consult with the Department s Office of Special Education Programs (OSEP) and Family Policy Compliance Office (FPCO) regarding how the proposed data sharing would meet the requirements in 34 CFR 99.31(a)(6) and 303.414 (for IDEA Part C) and 34 CFR 99.31(a)(6) and 300.622 (for IDEA Part B Section 619). 2017 LEADERSHIP CONFERENCE 17
IDEA Safeguards IDEA Safeguards Each participating agency must protect the confidentiality of PII at all stages. One official at each participating agency must assume responsibility for ensuring the confidentiality of any PII. All persons collecting or using PII must receive training on state s privacy procedures. Each participating agency must maintain a list of employees with access to PII. 2017 LEADERSHIP CONFERENCE 18
Scenario A: One lead agency, Education, two Scenario A: One lead agency, Education, two separate data systems for Part C and 619 separate data systems for Part C and 619 Overall Agency Data Governance Part C Data Stewardship Provisions 619 Data Stewardship Provisions 2017 LEADERSHIP CONFERENCE 19
Scenario B: Two different lead agencies, Health for Scenario B: Two different lead agencies, Health for Part C and Education for 619 Part C and Education for 619 Multi-agency Governance Health Agency data stewardship input Required: Data Sharing Agreement Audit/Eval Exception ED Agency data stewardship input 2017 LEADERSHIP CONFERENCE 20
Discussion Question Discussion Question What privacy and confidentiality, technical, and data governance challenges exist in your state for sharing and linking Part C and Part B 619 data? 2017 LEADERSHIP CONFERENCE 21
NC Context NC Context Part C in Health (DHHS) Part B 619 in Education (DPI) Participation in DaSy Linking C/619 Data Cohort starting February 2016 2017 LEADERSHIP CONFERENCE 22
North Carolinas Part C and Part B 619 Linking North Carolina s Part C and Part B 619 Linking Data Work Data Work Preparation for Linking Data Sharing Agreements/MOUs Data Elements Unique ID 2017 LEADERSHIP CONFERENCE 23
North Carolina Linking North Carolina Linking Agreements Agreements Challenges/Barriers: What is the format/language for the necessary agreement/MOU? Interagency Agreement on Transition (DHHS/DPI) ECIDS MOU Other approved agreements within Part C or Part B 619 Solutions/Lessons Learned Leverage existing MOUs/Agreements (ECIDS, Current Interagency Agreement on Transition) 2017 LEADERSHIP CONFERENCE 24
North Carolina Linking North Carolina Linking - - Agreements Agreements Challenges/Barriers: Who needs to be involved in the MOU/Agreement process? Separate agencies = Redundancies of roles (Lawyers from Part C, Lawyers from Part B) Who are the decision-makers? Are they at the table? Separate data systems Involving Data Governance groups Solutions/Lessons Learned Start early with meetings with key people Membership of core linking group is key 2017 LEADERSHIP CONFERENCE 25
North Carolina Linking North Carolina Linking Agreements Current Status Current Status Current Status: Amendment to current Interagency Agreement Under Review Utilized language from other accepted agreements Includes information on: Why to link data FERPA guidance and exceptions for sharing Personally Identifiable Information (PII) Joint Data Committee (decision-making body) Legalese data requests, re-disclosure, security considerations, permissions, etc. Agreements 2017 LEADERSHIP CONFERENCE 26
North Carolina Linking North Carolina Linking Data Elements Data Elements Challenges/Barriers: ECIDS data elements were insufficient No referral data No Child Outcomes data from Part B 619 Other data not included Solutions/Lessons Learned: Start with lists from ECIDS MOU Add in fields relevant to critical questions Include in Amendment 2017 LEADERSHIP CONFERENCE 27
North Carolina Linking North Carolina Linking Unique ID Unique ID Challenges/Barriers: No C/619 unique ID currently exists Solutions/Lessons Learned: Standard ID currently used by DPI for all students is also ID used for ECIDS ECIDS ID is in DHHS Data Warehouse, working on getting Part B 619 data staff access 2017 LEADERSHIP CONFERENCE 28
North Carolina Linking North Carolina Linking Next Steps Next Steps Approval of Amendment to Interagency Agreement Joint Data Committee/Joint Data Governance Permissions Secure data transfer Secure storage Link Data Use Data To Answer Critical Questions Generate Reports/Data Visualizations for Stakeholders 2017 LEADERSHIP CONFERENCE 29
South Dakota Part C and 619 South Dakota Part C and 619 Department of Education Lead Division of Educational Services and Supports Part B, 619, Part C, Title etc. BDI-2 State 2017 LEADERSHIP CONFERENCE 30
Ultimate Goal Ultimate Goal Improvement Improvement College, career, and life ready Use data to improve programs and child outcomes Districts will be able to run their own data linking with student demographics with evaluation data to make comparisons between race, disability categories, etc. Define the value add of the Birth to Three Program Does Birth to Three have an impact on children s education later in school? Next Steps South Dakota Data Partners Birth to Three Part C Part B / 619 K12 General Education State SLDS team Secretary of Education 2017 LEADERSHIP CONFERENCE 31
32 South Dakota Data Partners South Dakota Data Partners Birth to Three Part C Part B / 619 K12 General Education State SLDS team Secretary of Education 2017 LEADERSHIP CONFERENCE
Existing Data Systems Existing Data Systems Birth to Three online IFSP (stand alone) BDI--2 Data Base (Part C and 619) Infinite Campus (District Student Record) SDStars (SLDS) 2017 LEADERSHIP CONFERENCE 33
Where to Begin??? Where to Begin??? Global State DaSy Technical Assistance Talk through the process Part B / General Ed SDStars Team Understand how SLDS works Technology considerations Language Connect with contractor (OTISEd) Find $$ s!! DaSy Technical Assistance Coordinate calls with other states Part C programs Federal Privacy Rules Connect the dots 2017 LEADERSHIP CONFERENCE 34
Key Questions We Wanted to Answer Key Questions We Wanted to Answer Does length of time for participation have any impact? Do the accuracy of diagnosis in IFSP s have any impact? Length of Services (shorter or longer for same services in region have any impact)? Do BT3 receive SPED services later? Progress? Are there any patterns among providers? Are there any patterns among regions? Do IEP s in later years relate to the BT3 years? 3rd Grade reading score: Does early intervention have impact to outcomes? Does BDI-2 evaluations show any patterns related to child 2017 LEADERSHIP CONFERENCE 35
Choosing Data Elements Choosing Data Elements Child Demographics Frequency and Intensity BDI-2 Evaluation Medicaid, private insurance IFSP UNIQUE IDENTIFIER??? 2017 LEADERSHIP CONFERENCE 36
Linking Part B and Part C Data Linking Part B and Part C Data 619 has begun process of merging demographics from Infinite Campus and BDI-2 Data Manager Will allow state to pull a variety of reports to analyze data and improve special education programs for children ages B-5. Benefits: Reduce staff time pulling individual district reports Improve ability to make comparisons and analyze data across programs Cost savings internally completing data analysis and preparing reports for Indicator 7 Provide the Indicator C3 and B7 reports needed for federal reporting 2017 LEADERSHIP CONFERENCE 37
Important Considerations Important Considerations Familiarize yourself with your state SLDS technology and lingo Do your homework what is your state s DOE ESSA? Know the costs associated Data linkage is costly Make sure you have good technical expertise to help with these discussion (DaSy!!) 2017 LEADERSHIP CONFERENCE 38
Follow DaSy Follow DaSy Visit the DaSy website at: http://dasycenter.org/ Like us on Facebook: https://www.facebook.com/dasycenter Follow us on Twitter: @DaSyCenter 2017 LEADERSHIP CONFERENCE 41
Thank you Thank you The contents of this presentation were developed under grants from the U.S. Department of Education, # H373Z120002 and H326R140006. However, those contents do not necessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement by the Federal Government. DaSy Center Project Officers: Meredith Miceli and Richelle Davis. NCSI Project Officers: Perry Williams and Shedeh Hajghassemali. 2017 LEADERSHIP CONFERENCE 42
