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TRANSCRIPT
Adult Education
Compliance Monitoring Process Training Manual
2019–2020
Mr. Michael R. King, Director
Office of Adult Education
South Carolina Department of Education
Office of Adult Education
1429 Senate Street
Columbia, SC 29201
The South Carolina Department of Education does not discriminate on the basis of race, color, religion, national origin, sex, sexual
orientation, veteran status, or disability in admission to, treatment in, or employment in its programs and activities. Inquiries
regarding the nondiscrimination policies should be made to the Employee Relations Manager, 1429 Senate Street, Columbia, South
Carolina 29201, 803-734-8781. For further information on federal non-discrimination regulations, including Title IX, contact the
Assistant Secretary for Civil Rights at [email protected] or call 1-800-421-3481.
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Contents I. The Compliance Monitoring Process Overview......................................................................................... 4
II. The Compliance Monitoring Team Training and Team Responsibilities ............................................... 5
A. Compliance Monitoring Team Member Training .............................................................................. 5
B. Adult Education Director/Community Based Organization (CBO) Director Training .................. 5
III. Preparing for the On-Site Compliance Monitoring Visit ....................................................................... 6
A. Staff Orientation ..................................................................................................................................... 6
B. Superintendent and/or CBO Board Chair Orientation ...................................................................... 6
C. Documentation Preparation .................................................................................................................. 6
1. Written Documentation. .................................................................................................................... 6
2. Organization of the Files .................................................................................................................... 7
3. Records Selection Process .................................................................................................................. 8
4. Classroom Documents ........................................................................................................................ 8
D. SCDE Protocol............................................................................................................................................. 8
E. Group Interview .......................................................................................................................................... 8
F. Classroom Observation Schedule .............................................................................................................. 9
IV. Scope of Compliance Monitoring Review .............................................................................................. 10
A. Activities Matrix ................................................................................................................................... 10
B. General On-site Procedures ................................................................................................................ 11
C. Evidence Base for Recommendations ................................................................................................. 11
1. Triangulation .................................................................................................................................... 11
2. Documentation .................................................................................................................................. 12
3. Observations...................................................................................................................................... 12
4. Conclusion of Evidence .................................................................................................................... 13
5. Team Member Assignments ............................................................................................................ 13
D. Logistics ................................................................................................................................................. 13
1. Team Workroom .............................................................................................................................. 13
2. Building Orientations and Building Tours ..................................................................................... 13
3. Travel and Lodging .......................................................................................................................... 13
4. Local Transportation ....................................................................................................................... 13
5. Meals .................................................................................................................................................. 14
6. Exit Conference................................................................................................................................. 14
V. Code of Conduct for the Compliance Monitoring Team’s Chairpersons and Members ..................... 15
A. Four Major Precepts ............................................................................................................................ 15
B. Communications and Interactions ...................................................................................................... 16
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VI. After the On-site Review ......................................................................................................................... 16
A. Timetable of Activities ......................................................................................................................... 16
B. Consensus .............................................................................................................................................. 17
C. Writing the Report ............................................................................................................................... 17
VII. Appendices ................................................................................................................................................ 18
APPENDIX A: Documentation Guidelines .................................................................................................. 18
APPENDIX B: On-Site Compliance Monitoring Planning and Preparation Tips ................................... 19
APPENDIX C: Compliance Monitoring Team Exit Conference Checklist .............................................. 21
APPENDIX D: Compliance Monitoring Team Contact Information ....................................................... 22
APPENDIX E: Compliance Monitoring Follow-Up Request 2019-2020 ................................................... 23
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I. The Compliance Monitoring Process Overview
Under the mandate of the S.C. State Plan for Adult Education and Family Literacy, the South Carolina
Department of Education, Office of Adult Education must assign a Compliance Monitoring (CM) Process team
to all school district programs or community based organizations (CBOs) receiving federal funds and/or state
aid to support approved adult learning services.
The CM process is a systematic approach designed to assess the educational opportunities and the effectiveness
of the adult education programs and services in the school districts and CBOs receiving federal funds and/or
state aid to support such services. The activities of the team include the following responsibilities:
examining all facets of adult education operations, focusing on strengths and challenges, determining the
extent to which the instructional program is aligned with the WIOA Adult Education Thirteen (13)
Considerations for Federal awards, SC State Regulations and effective program management;
making recommendations which draw upon strategies from other adult education programs with similar
student characteristics that have been successful in raising academic achievement;
consulting with teachers and administrative staff to gather additional information on the strengths and
weaknesses of the program;
identifying opportunities for improvement, if any, that are needed at the adult education program and/or
CBO and report such findings to the school district superintendent and/or Chair of the CBO Board;
providing information and insights for use in the design of the program’s improvement plan,
implementation strategies, and professional development training that can reasonably be expected to
improve student performance and increase the rate of student progress;
identifying needed support from the district, the South Carolina Adult Education Technical Assistance
Network (TAN), or the South Carolina State Department of Education (SCDE) Office of Adult
Education (OAE) and other resources for long-term technical assistance; and
developing a technical assistance plan to improve educational programs.
To be successful, the Compliance Monitoring effort requires continuous follow-up and support activities
including professional development and on-site assistance. The on-site review is the first step in a partnership
between the SCDE and the adult education provider. Working together, we can improve student and program
performance.
The Compliance Monitoring Process Training Manual has been developed as a guide for the formal review of
local Adult Education programs. The intent of the training manual is to assist adult education program
Directors, staff and the Compliance Monitoring team members to prepare for the Compliance Monitoring onsite
review.
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II. The Compliance Monitoring Team Training and Team Responsibilities
A. Compliance Monitoring Team Member Training
All Compliance Monitoring team members must successfully complete training provided by the SCDE Office
of Adult Education (OAE). This training will fully inform them of their roles and responsibilities they assume
when carrying out the Compliance Monitoring process. The major foci of the training will be on the Thirteen
Considerations as they relate to the satisfactory implementation and expected progress of Adult Education,
Corrections Education, Generational Family Services, and Integrated English Literacy and Civics Education.
Training will include the following:
the history and legal basis for the on-site review process,
the WIOA Thirteen Considerations,
specific instructions on the standards and procedures of the on-site review process,
data analysis,
classroom observation techniques,
interviewing techniques,
sensitivity training,
triangulation of evidence and consensus building,
working as a team member, and the
development of reports.
The SCDE Office of Adult Education will provide Compliance Monitoring team members with all of the
necessary material and training to perform the Compliance Monitoring review successfully. The goals for the
training sessions are as follows:
provide essential information about the Compliance Monitoring process and its purpose;
enhance the understanding of the Program Review Instrument and other documents;
outline expectations and working practices; and
instruct the review team in the areas of reporting, interviewing, consensus building, and analyzing
through observation and document analysis.
B. Adult Education Director/Community Based Organization (CBO) Director Training
The OAE will initiate the first contact between the school district program and/or CBO and Compliance
Monitoring team. The OAE will provide the initial Compliance Monitoring training for the Adult Education
Director/CBO Executive Director (hereafter referred to as the “Director”) at a joint session. The training is an
opportunity for Directors and staff to gain a full understanding of the review process. During the training, the
Monitoring team will review the Compliance Monitoring Tool and other pertinent information relevant to the
review process.
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The session will emphasize the following:
the on-site review is not a punitive process, and all staff should be informed of the process;
the CM process is designed to assess the strengths and needed improvements in adult education
programs and services;
the routine of the school day should continue as normal; the process is not to be disruptive;
dependent upon scheduling constraints, all teachers may not be observed or interviewed;
confidentiality of the interview responses is protected as much as possible during the on-site visit
and in the report’s writing process (responses are summarized);
the master schedule;
sites to be visited; and
staffing.
III. Preparing for the On-Site Compliance Monitoring Visit
A. Staff Orientation
Anxiety about the CM on-site visit will be greatly reduced if staff members are well informed about the review
process. It is highly recommended that the program’s staff receive orientation concerning the review. The
Director should conduct the orientation. The orientation should be conducted as a part of routine staff meetings
prior to the on-site visit. The staff orientation should emphasize all of the components outlined in Section II-B.
Teachers selected for observation during the on-site visit should be provided the official Adult Education
Teacher Checklist.
B. Superintendent and/or CBO Board Chair Orientation
The Superintendent or CBO Board Chair will receive a letter that explains the purpose of the review and may
attend any orientations and training provided to the program staff.
C. Documentation Preparation
1. Written Documentation.
The Compliance Monitoring team members will review the following WIOA and State Considerations:
1. Commitment to Serve Individuals in Need
2. Serving Individuals with Disabilities
3. Past Effectiveness
4. One Stop System Alignment
5. & 6. Evidence Based Instructional Practices
7. Activities Implementation, Technology Use and Delivery Method
8. Contextualized Instruction
9. Instructor and Staff Qualifications
10. Partner Coordination for Development of Career Pathways
11. Support Services, and Service Flexibility
12. Performance Management Outcomes
13. English Language Acquisition and Civics Education
14. Corrections Education
15. Generational Family Services
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16. Integrated English Literacy and Civics Education
17. Financial Monitoring
18. Student Records
19. Standardized Assessment
20. Program Management
The Compliance Monitoring Review process begins on the due date of the Written Documentation.
The director has the responsibility of creating the documentation files and completing and submitting the
Compliance Monitoring Written Documentation Template, which contains information regarding each of the
Compliance Monitoring considerations. The template is organized by:
consideration requirements, and
organizational checklist listing the documentation needed during the on-site visit.
The Compliance Monitoring Written Documentation Template must be submitted prior to the on-site visit.
Directors will use the provided template to submit required written documentation of the considerations to the
OAE. See the Compliance Monitoring Review schedule for written documentation due dates.
Submit the template to: [email protected], with the Subject Line: <Program Name,
Compliance Monitoring Written Documentation>
On site Files
The Directors documentation file should be organized by the considerations detailed above (C.1.). Each file
should contain documentation that provides evidence showing that the requirements for the respective
consideration is being fulfilled. As necessary, the Director should provide supporting evidence to prove the
program’s efforts to comply with each consideration.
The Compliance Monitoring team may ask that additional documentation be provided if questions arise during
the review of written documentation, and/or request that information be available during the on-site review.
Refer to Appendix A.
2. Organization of the Files
Adult Education programs must submit written documentation for the considerations to the Compliance
Monitoring Team for review prior to the Compliance Monitoring visit. The required documentation will be due
approximately two weeks prior to the Compliance Monitoring site visit. Copies of the submitted information
should be maintained by the program for future reference.
Files should be housed within boxes, containers, hanging files, etc. Each piece of documentation should be
marked with the heading of the respective consideration. Large documents, such as curriculum guides, school
board policy manuals, and adult education procedures must be clearly labeled and readily accessible to the team
during the on-site review.
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3. Records Selection Process
The Compliance Monitoring team will conduct a document review (current student records, previous three
years’ permanent graduate records, and attendance). The Audit report will be used to randomly select the
following number of records to be reviewed.
Current (Records and Attendance) 25 for programs with less than 999
40 for programs with more than 999
Graduate (HSD and HSED) 25 for programs with less than 999
40 for programs with more than 999
4. Classroom Documents
As a part of the teacher/classroom observation, the following documents should be readily available for the CM
team member:
Teacher folders/binder
Student folders/binder
Instructional Planning
Sign-in/sign-out sheets
Individual teacher’s Table 4 and 4B
D. SCDE Protocol
The school district superintendent, superintendents’ designee, CBO Board Chair or designee must be scheduled
for a brief introduction at the beginning of the visit.
E. Group Interview
The CM Team will conduct a group staff interview. The interview process will be conducted in two parts.
Part 1: On the date that the written documentation documents are due, a survey will be sent to program staff
members. The survey questionnaire consists of questions that should be completed and submitted by staff
members before the end of the first day of the Compliance Monitoring review.
Part 2: A second set of questions will be asked during the scheduled lunch that will take place between the
Compliance Monitoring Team and program staff members. The interview will be held in a relaxed group
setting.
Group Interview Time: The interview will be scheduled at the end of the instructional day around lunch time.
The interview should last approximately one hour.
Group Interview Location: The Director must coordinate appropriate interview space—one that provides
minimal distractions and that will accommodate all those who will attend. The room arrangement should be
conducive to group discussion.
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Group Interview Goals: Meeting with key stakeholders to pose questions and provide discussion is a critical
part of evidence gathering. The interview process occurs in a group setting and will involve individuals from the
program, including teachers, and staff. Administrators, (directors, coordinators), are not included in the group
interview. The primary purpose of the interview is to gain insight into program practices through firsthand
accounts. Interviewing also offers a way to acquire varying perspectives in a personalized, interactive manner.
Additional goals of interviewing are to
uncover additional information (particularly on how program staff relate to one another),
test the validity of information gathered elsewhere, and
strengthen the relationship with the Office of Adult Education.
The purpose of interviewing is not to collect facts, such as the names of programs and the persons responsible
for various initiatives. This kind of information should be acquired by other means, including reviewing the
documents that the program provides to the CM team. Interview protocols are provided as separate documents.
Each protocol provides guiding questions tied to one of the twenty (20) considerations. Compliance Monitoring
team members are not required to ask every question in the interview protocol. They should move on to the next
set of questions once they have the information needed to make their judgment. Compliance Monitoring team
members may also ask additional questions to clarify responses.
F. Classroom Observation Schedule
Class selection
Using the submitted staff roster, the Compliance Monitoring team will select individual classes/teachers to be
observed, with input from the program Director. The number of classes observed will be determined by
program size and activities offered.
It will be the responsibility of the Director to inform the Compliance Monitoring team representative of any
issues with the classroom observation list and to inform teachers which days they will be observed. Once
completed, the schedule should be disseminated to all staff.
If a Compliance Monitoring team member arrives for a classroom observation and the class is not available for
observation, he/she will conduct an unscheduled observation of a similar class during that time frame.
Classroom observation times (20-30 minutes)
Observations will be scheduled during the normal program day. The Compliance Monitoring team member will
stay in the classroom for at least thirty minutes, but may stay as long as needed to properly observe the class and
complete the classroom observation instrument. The Teacher Observation Checklist is posted on the TAN
website (www.scTAN.org) with other Compliance Monitoring forms and documents. Teachers who have been
selected to be observed should be provided this official observation instrument.
Documents/files to have available during the classroom observation:
Teacher records for current students
Student folders/binders/portfolios for current students (not required for ESL)
Tables 4 and 4B for class
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IV. Scope of Compliance Monitoring Review
A. Activities Matrix
Activity Suggested Timeframe
Director Technical
Assistance session with
SCDOE – Office of Adult
Education representative(s)
This is the primary training held with directors prior to the
Compliance Monitoring on-site visit.
Due date/Submission of
completed Written
Documentation template
Compliance Monitoring review process begins at this point.
Template should be submitted to: [email protected]
Technical Assistance
Directors are encouraged to contact members of the Monitoring team
for clarification on any aspect of the Compliance Monitoring
process. (See Appendix C)
Staff Orientation and
Training
Staff orientation and training for the CM process should be a part of
regularly scheduled staff meetings. The Compliance Monitoring
review should be on the meeting agendas as many times as necessary
to ensure that all staff understand the purpose and process of the
Compliance Monitoring process. Meetings should be held prior to
the first day of the Compliance Monitoring Process.
Schedule Finalization On the first day of the on-site review the schedule will be adjusted if
needed.
School Familiarization Team members should be given a quick tour of the adult education
building.
Written documentation
review Review of submitted Written Documentation template
Document and Records
Review
The Document Review process will continue throughout the on-site
visit as necessary.
Group Staff Interview The group staff interview will conducted at the end of the
instructional day.
Teacher Observations
Teacher observations will be conducted at scheduled times during
the on-site review. Compliance Monitoring team members may visit
additional classes if the scheduled class to observe is unavailable.
Preliminary Consensus A preliminary consensus by all Compliance Monitoring team
members.
Final Consensus
In preparation for the exit conference, the Compliance Monitoring
team members will meet at the end of the on-site visit to discuss
general findings and trends. The Team will meet with the Director
(and Director selected staff) during the exit conference.
Exit Conference Conducted at the completion of the on-site review. Complete Exit
Conference Checklist, Appendix C.
Compliance Monitoring review process ends at this point. Follow-up (if necessary) will be scheduled
with program director if corrective actions are identified.
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B. General On-site Procedures
Length of the visit
The review time will range from one to a maximum of two days (in most programs). The review will be
comprised of:
Program familiarization
Written documentation review. (Collection of additional information, if needed, to satisfy
requirements of individual considerations.)
Records review
Teacher/Classroom Observations
Director clarification
Team consensus
Exit Conference
Consecutive days
The on-site review will be conducted on consecutive program days unless a modified schedule is approved by
the Office of Adult Education. All members of the Compliance Monitoring team must be present throughout
the on-site review.
C. Evidence Base for Recommendations
1. Triangulation
The on-site review process involves careful, systematic research and examination of the programs’ activities,
practices, and systems. In order to form sound recommendations in each of these areas based on facts, the
Compliance Monitoring team must be provided with solid means and sources to obtain accurate information
that serve as evidence. Furthermore, it is important that the adult education program provide the Compliance
Monitoring team with a method of obtaining evidence from multiple people, as well as multiple sources, so that
information can be cross-referenced.
The basis for the on-site review process is founded on three methods of obtaining evidence:
1. Review of documentation,
2. Conducting interviews, and
3. Observations
All of these methods will be employed, whenever possible, to gather evidence to address each consideration and
to answer the key questions. It is a requirement that the Compliance Monitoring review address every
consideration with at least one source of primary evidence. Primary evidence is defined as information obtained
directly from its original source. Secondary evidence is information that is channeled through one person or
several people.
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2. Documentation
Each program schedule to be reviewed has an individually assigned submission due date for Written
Documentation. The Written Documentation is due to be submitted to the OAE approximately two weeks prior
to the on-site visit. The Compliance Monitoring process begins on the date that the program’s Written
Documentation Template is due. Depending on the size and complexity of the adult education program, the
on-site review process involves one or two full days on-site. In order to generate an accurate final report, it is
essential for the Compliance Monitoring team to review all aspects of the program’s operation.
The term documentation refers to every type of record, manuscript, file, report, data, statistical summary,
handbook, chart, plan, and outline. All documents should be provided by the program.
Directors must submit written documentation by the assigned due date (see Compliance Monitoring schedule of
dates). Compliance Monitoring Team will review the submitted responses and on day one of the onsite visit, a
designated team member will review each consideration. Compliance Monitoring Team members will make
every effort to collect any additional needed information prior to the Compliance Monitoring visit. However, on
day one, additional information, based on the submission of written documentation, (Compliance Monitoring
Review Written Documentation Template), will be collected.
All documents related to the considerations will be carefully studied and matched to the appropriate
consideration and key questions. The Compliance Monitoring team will devote most of its attention, during this
phase, to the documents that correspond to the considerations. The information gleaned from this review will
serve as part of the evidence base for all judgments formed.
The Compliance Monitoring team members will make written notes as they analyze documents and be prepared
to cite specific evidence for each consideration in the final report. When the Compliance Monitoring team has
systematically reviewed the documents against the considerations, evidentiary gaps may emerge. These gaps
will raise questions and help prompt ideas about what needs to be investigated further. Additionally, in
instances that evidence is discovered which supports a judgment on a specific consideration, the Compliance
Monitoring team will create preliminary hypotheses about the program that will be tested during the on-site visit
either by interview or by direct observation. Document analysis, together with observations, forms the primary
basis for making recommendations.
3. Observations
The term observation refers to the practice of witnessing firsthand the climate, setting, operations, and
classroom instruction while on site. The CM team will be expected to observe the following:
Classroom environments,
Teachers delivering instruction, and
Other activities conducted at the program site during the week of the Compliance Monitoring Process
Most times and places for observations will be scheduled before the week of the on-site review. The CM team
leader, however, may insert additional observations into the schedule and should exercise this option as needed
to help make sound judgments on each consideration. It is extremely important that the instructional lessons and
classrooms observed represent the full range of abilities, programs, and subject areas delivered by the program
under review. The Compliance Monitoring team members should make certain that, by the end of the review,
they feel confident that they have observed everything in order to form sound, substantiated judgments about
the program in relation to each indicator. Compliance Monitoring team members should scrupulously document
their observations on the review instrument and submit these with their notes to the CM leader at the end of the
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review. The CM team will use the Teacher Observation Instrument for the observations. The Teacher
Observation Instrument can be found posted on the TAN website with the CM documents and forms.
4. Conclusion of Evidence
Gathering evidence through observation and communication from multiple people yields an additional set of
information. The more sources of evidence used (a source can be a person or a method) and the more
individuals who provide information, the more secure the evidence base. Every additional instance of
assembling evidence increases the accuracy of the final judgments made by the CM team.
5. Team Member Assignments
The CM team leader will assign each team member with primary responsibility for specific considerations and
secondary responsibility for others. Each consideration will have, at a minimum, one CM team member
assigned as a primary reviewer and one CM team member assigned as a secondary reviewer. In some cases, it
may be prudent for all Compliance Monitoring team members to review a consideration. This is especially true
if some problems or issues begin to emerge. By requiring that at least two team members review each
consideration, it is ensured that each section is viewed from different perspectives.
D. Logistics
1. Team Workroom
The program must provide the CM team with a private workspace that is large enough for the entire team
(usually two to four individuals). In addition to providing privacy, the workroom must have sufficient space for
documentation files and a place for the team members to write. The documentation files should be assembled in
this location prior to the arrival of the CM team. The space should be separate from major functions/operations
of the school to avoid possible outside interruptions.
2. Building Orientations and Building Tours
The Director should conduct a brief tour of facilities to acquaint team members with classroom locations.
Frequently, such a tour of the school is conducted on the first morning of the CM team’s visit to the school.
3. Travel and Lodging
Compliance Monitoring team members are responsible for their own transportation to the main program site.
Compliance Monitoring team members must complete a SC Department of Education Travel Request
Authorization form prior to the on-site visit. If lodging is required, team members will follow the SCDE process
for securing hotel rooms in the area. Compliance Monitoring team members must use the approved “Domestic
Per Diem Rates” for South Carolina when completing the travel request form. All Compliance Monitoring
team members must save hotel receipts and attach them to a completed SC travel reimbursement form.
4. Local Transportation
It is the responsibility of the Director to arrange/provide transportation for the team members to the off-site
(satellite) locations, including the location(s) of the interview.
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5. Meals
It is encouraged that lunch be brought to the main site (or at a satellite site based on the time); however, the
program is not responsible for the cost of lunches for the CM team. It is helpful if the program has available a
couple of menus from local restaurants. The CM team may leave the program site for lunch but should limit
lunch to one hour. Compliance Monitoring team members will be reimbursed for the cost of meals at the
approved per diem rate.
6. Exit Conference
At the conclusion of the on-site review, an exit conference to identify preliminary findings must be held with
the Director and other adult education staff selected by the Director. These findings represent a description of
the programs and services at the time of the on-site review. The Exit Conference Checklist in Appendix C
should be used as a guide for conducting this conference.
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V. Code of Conduct for the Compliance Monitoring Team’s Chairpersons and Members
A. Four Major Precepts
The right of entry into any facility housing adult education programs carries important responsibilities for
Compliance Monitoring teams. All Compliance Monitoring team members should maintain the highest
standards of professional ethics and personal integrity before, during, and after the review process.
The on-site review process is a comprehensive assessment of a program and its level of achievement in
addressing the twenty (20) considerations. The code of conduct required of all Compliance Monitoring team
members is built upon four major precepts: integrity, focus, communication, and objectivity. It is imperative
that the Compliance Monitoring team members and the adult education staff understand the significance and
seriousness of the role of the Compliance Monitoring team. The demeanor must be professional at all times. It is
essential that the Compliance Monitoring team members maintain an objective relationship with the program
staff.
1. Integrity
Be considerate and sensitive to the needs of the program and to the convenience of the staff
Ensure confidentiality at all times and convey confidentiality to staff, faculty, and any others who are
being interviewed
Retain mutual respect and value the opinions of others
Endeavor to understand the actions and reactions of staff
Be supportive, remembering that evidence given under undue stress is often unreliable
Offer only feedback that is constructive
Avoid compromising students or staff by putting them in a position where conflicting loyalties might
arise
2. Focus
Focus on what is best for the students in the program
Adhere to the standards of the external review process
3. Communication
Communicate openly and honestly at all times
Listen attentively and actively
Question appropriately and relevantly
Express judgments succinctly and in a positive manner
Never discuss program issues outside the confines of the Compliance Monitoring process
Avoid conversations in public places regarding the program or the Compliance Monitoring process
4. Objectivity
Distinguish clearly between opinions that are invalid and objective perceptions that may be used as
evidence
Fully support all judgments with evidence, documentation, interviews, and observations
Examine the judgments of staff and other Compliance Monitoring team members to ensure that these
conclusions are based on evidence
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B. Communications and Interactions
1. Perceptions
The working relationship between the Compliance Monitoring team and the program must be professional at all
times.
2. Working relationship
It is important for the Compliance Monitoring team to develop a good working relationship with the director
and staff. The results of the on-site review must reflect a partnership between the program and the CM team.
Everyone concerned should work together to determine how best to improve student and school performance.
Compliance Monitoring team members are guests in the program and should act accordingly, just as program
personnel should act as good hosts. The CM team leader will communicate daily with the director, discussing
concerns as they arise so that the program is given every opportunity to demonstrate how well it is
implementing each consideration
VI. After the On-site Review
A. Timetable of Activities
Activity Timeframe
After the Compliance Monitoring team members conduct their
consensus session, a draft report is completed.
No later than one week after on-site
activities are completed.
The Office of Adult Education will review the report for
completeness and compliance with proper procedures. If the
report is incomplete, the Compliance Monitoring chairperson
will be required to make the required adjustments to the report.
10-20 working days after the report is
completed.
The final report is prepared and submitted to the local AE
Director. A copy is sent to the District Superintendent or the
CBO Board Chair.
No later than 45 days after on-site
activities are completed.
After the final report is received, the local AE Director prepares
a “Corrective Action Plan” for all required actions (if
applicable).
No later than 45 days after the report is
received.
The OAE completes a follow-up visit to the local AE program
to assess progress relative to the “Corrective Action Plan” and
submit a follow-up report to the SCDOE (if applicable).
Within the first semester of the
following school year.
The OAE will assign an “All Clear” or “Not Clear” status to the
local program after the completion of a follow-up visit to the
local program.
No later than 30 days after the receipt
of a final follow-up report.
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B. Consensus
It is important that the Compliance Monitoring team members come to consensus on the findings and
recommendations for each consideration. The Compliance Monitoring Team chairperson will facilitate the
consensus session. At the conclusion of the consensus session, the Compliance Monitoring report will be
completed and ready for submission to the Director of the Office of Adult Education.
C. Writing the Report
Findings
The Compliance Monitoring team findings will be reported by evaluating each consideration. The report will
include commendations, recommendations, and required actions. Based on specific individual considerations,
expectations will be either “met” or “not met.” Key indicators have been identified for each consideration.
If one or more of these indicators is marked unfulfilled, then the expectation(s) has/have not been met. Conversely, if all identified indicators are marked fulfilled, then all consideration expectations have been met.
Commendations
Exemplary practices are either observed or are evident through the review of program data and records.
Recommendations
Suggestions made by the Compliance Monitoring team that would positively impact the quality of programs
and services.
Required Actions
Whenever there is an instance that State or federal regulations (as related to Adult Education in South Carolina)
are violated, a “required action” will be generated. The Office of Adult Education must choose the “required
actions” that need to be addressed and affirm the best course of action required by the program to make
improvements related to that consideration.
Technical Assistance
Technical assistance to address required actions may be provided by OAE staff, designated individuals, and/or
other agencies and organizations. If there is a program concern that needs to be addressed immediately a
Compliance Monitoring team member should completed the “Follow-Up Request Form,” (see Appendix D),
and indicate if the concern is urgent or may be addressed as soon as possible.
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VII. Appendices
APPENDIX A: Documentation Guidelines
Review of Submitted Documentation Guidelines
Programs must submit written responses to specific considerations as outlined on the Compliance Monitoring
Written Documentation Template.
The following are guidelines for the submitted documentation:
Submit documentation on or before the due date. The Monitoring Process Begins on the Day the Written
Documentation is due.
Use the provided template, and
Submit the completed template to: Submit the template to: [email protected], with
the Subject Line: <Program Name, Compliance Monitoring Written Documentation>
Programs will be notified prior to the on-site visit if additional documentation is needed. Additional
documentation should be available on Day One of the on-site visit.
On-site Review Documentation Guidelines
Programs must assemble documentation according to the twenty (20) considerations. The following are
guidelines for programs in assembling documentation in preparation for the Compliance Monitoring on-site
review:
Each piece of documentation should have a clear reference to the specific Considerations and the SC Adult
Education Considerations being referenced. The relationship should be made very clear so that the Compliance
Monitoring team member who is reviewing the information can readily discern the information being provided.
Programs must use the following procedures to organize the documentation:
1. Use the provided template to submit written documentation.
2. Use file folders with tabs and clearly label the folder by each of the twenty (20) Considerations.
3. If the connection is not apparent, provide an annotation that clearly explains why the information is
considered significant.
4. Maintain a hard copy of the submitted responses to all of the considerations. It is suggested that
documentation files be arranged by consideration, (1-20), within boxes, plastic containers, hanging files or
by any method that you find convenient and easily accessible.
Cross-referencing by citing page numbers may be used freely; however, programs must make sure each piece of
documentation is carefully labeled. If the most significant and relevant document is “lost” in a flood of other
materials, team members may overlook a document or be unable to adequately evaluate its significance.
APPENDIX B: On-Site Compliance Monitoring Planning and Preparation Tips
The following Compliance Monitoring visit planning tips are derived from program directors
who have experienced the Compliance Monitoring Process and from collective observations of
the Compliance Monitoring Team. The tips are not in a specific order.
1. Inform Staff About The Review - Include the Compliance Monitoring Process as a staff
meeting agenda item early on.
2. Notify Key District Personnel – Notify Superintendent, Financial Officer, etc. of the review
dates as early as possible.
3. Review the WIOA 13 Considerations –The WIOA Considerations were addressed in the
AEFLA RFP. Reference your RFP as you respond to the considerations in the Compliance
Monitoring tool.
4. Documentation – Documentation is coded in three ways, Written, Copy of and/or Observe.
Directors have found that as each consideration is addressed it is easier to assemble the
copies needed as supporting evidence at the same time. See “Collection and Organization of
Required Supporting Evidence of Compliance”.
5. Filing System / Method – Decide on the most accessible and user friendly way to assemble
all the documentation needed for the review.
6. Dedicated Time – As with any project that requires extensive time and the collection of
resources, it is far easier to set aside consistent time/days to work on the project.
7. Reflect – Change – Eliminate – Revisit – The Quality indicators have changed to
Considerations. Use previous years’ information and RFP as a starting point for responding
to each consideration.
8. Counterparts - Use the Program Review List to reference other directors who have gone
through the review process.
9. Ask Questions – Feel free to contact the Compliance Monitoring team when questions arise.
10. Template for Written Documentation – This template must be submitted two weeks prior
to the on-site visit to [email protected].
11. Review Start Date –Remember that the Compliance Monitoring Review begins on the due
date of your written documentation.
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12. Compliance Monitoring Schedule – Consider which instructors you want the team to
observe and which classes (GED, Literacy, YAP, Family Literacy, etc.)
13. Designated Meeting Space For Compliance Monitoring Lead And Director – Designate
a work space for lead and program director.
14. Designated Work Space for CM Team – Designate a separate area for the remaining team
member(s) to review records.
15. Lunch – Depending on the schedule, the team may need to order lunch; please have one or
two menus from local restaurants available. Your recommendations are helpful. The team
would also appreciate recommendations for dinner, if applicable.
16. Documents Needed for the Review – Assemble Documents Needed for the Review;
a. Audit Report
b. Teacher Certification List and Certificates
17. Attendance Check – Dependent upon your attendance system, the Compliance Monitoring
team member verifying attendance will need assistance from the person most familiar with
recording, entering maintaining attendance.
18. Program overview- Your program overview allows the team and district personnel to get a
“Bird’s Eye” view of your program and it sets the tone for the on-site review. This is an
opportunity to showcase your program. The format is the director’s decision (oral
presentation, power point, video, handout, etc.). The overview should contain information
about the program that is not covered in the Compliance Monitoring Tool. Include local
initiatives, accolades, program data, partnerships, effective program management,awards,
etc.
19. Satellite Sites – Satellite Sites will follow the same process as the main site (observations,
teacher and student records review, attendance, etc.).
20. LACES Data – Alert LACES Specialist that irregularities in data will need to be reviewed
(test forms being alternated properly, program consistent with 30/40/60 rules, TABE test
forms alternated in pre/posttests, students post-tested after 30/40/60 hours, etc.).
21. Records Review – Start a records review schedule. Designate a team to review graduate
and current records. Use the records checklists. Place required items in the front of the
student folders. Follow with program specific information.
22. Schedule – Print the day of or day before. There are usually last minute adjustments.
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APPENDIX C: Compliance Monitoring Team Exit Conference Checklist
Recap the Compliance Monitoring on-site visit:
o Hospitality extended by program,
o Preparation of documentation, (submitted and onsite follow-up),
o Use of facilities,
o Openness and cooperation of the staff,
o Group Interview, and
o Other.
Provide an opportunity for the Director to add any documentation or information that he/she
would like to provide to the team that the Compliance Monitoring team members may have
missed.
Share trends that were observed in the program’s responses to the twenty (20) considerations
as outlined in the Compliance Monitoring tool.
Provide the Director with an overview of promising practices that were observed during the
on-site visit and opportunities for program improvement.
o Indicate any curricular programs or instructional strategies that are being implemented
extremely well.
o Indicate any individuals that really stand out as excellent educators.
o Describe opportunities for improvement relative to considerations and quality indicators.
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APPENDIX D: Compliance Monitoring Team Contact Information
COMPLIANCE MONITORING TEAM 2019-2020
Mike King [email protected]
803-734-8300
Jennifer Cooper-Keels [email protected]
803-734-8070
Dominique Dunbar [email protected]
803-734-4045
Andrena Duren [email protected]
(803) 734-8069
Wendy Griffin [email protected]
(803) 734-0762
Mary Hugee [email protected]
(803-734-1566
Harriette Jenerette [email protected]
(803) 734-4708
Kammie Reed [email protected]
(803 734-1944
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APPENDIX E: Compliance Monitoring Follow-Up Request 2019-2020
Program: ______________________________________ Date: _______________________
Follow Up Requested By: _________________________From:_______________________
The Compliance Monitoring Team was requested to, informed of, or identified the following concern(s) during
the Compliance Monitoring on-site visit. It is requested that follow up be provided. Detailed information is
listed below which includes who is suggested to follow up with the Adult Education Program Director from the
Office of Adult Education, a partnering agency and/or another entity:
Urgent ☐ ASAP ☐
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