Why Does ODE have a Corrective Action Plan process for data submission?
State Law requires public schools to submit complete and accurate data to the Ohio Department of Education (ODE) through the Education Management Information System (EMIS) and its subsystems. Reporting complete and accurate data is critical for funding, accountability and programmatic purposes. According to Ohio Revised Code section §3301.0714(L) districts that fail to submit complete and accurate data in accordance with the established deadlines are subject to corrective actions and the possible withholding of a percentage of foundation funds.
The Data Submission Requirements address the aspect of “complete” data submissions by EMIS reporting entities. Currently only the October (K) and Yearend (N) reporting periods are included for the purpose of the Data Submission Requirement process. The outcome of the last week’s data submission by a reporting entity determines whether a formal corrective action plan (CAP) will be required
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What does “corrective action” for Data Submission Requirements mean?
During the reporting period, corrective action is addressed through the Warning or Out of Compliance notifications sent to the reporting entity each week of the Data Submission Requirement period. These are formal notifications, sent to the Superintendent, Treasurer and EMIS Coordinator of those reporting entities not yet meeting the data submission requirements. The recipient of a Warning notification is notified that unless corrective action occurs a financial penalty will be incurred. The recipient of an Out of Compliance notification will incur a financial penalty and this notification is usually sent two weeks after a Warning notification. To review the Data Submission Requirements click here.
After the reporting period closes correction action is addressed through corrective action plan (CAP) requests. There are two types of CAP requests:
Acknowledgement – this request is used for reporting entities which have ended the reporting period with minimal data submission issues (i.e., small percentage of measures/data missed. Superintendent’ signature is only required.)
Full – this request requires a formal plan from the reporting entity that shows detailed actions to be taken to ensure that future data submission issues are addressed. A Corrective Action Plan Review committee reviews/approves these plans.
The Corrective Action Plan Determination criteria can be found here
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When do financial withholdings occur and what does it mean?
During the reporting period, financial withholdings occur based on data submission dates identified as Out of Compliance dates on the Data Submission Requirements document. For a reporting entity to be identified, the same measure must have been missed at least one other time previous to the current week. A withholding will not occur if the “Out of Compliance” date is the first date a reporting entity was identified for a measure(s). In these cases only a Warning notification would be sent. Once the reporting entity meets the measure(s) the withholding will be processed for release.
After the reporting period closes, any reporting entity which has not met the Data Submission Requirements will incur a financial withholding, unless it is the first time a reporting entity has missed the identified measure(s). In this case no withholding will take place, but a CAP will be requested. If financial withholdings are still in place from the Out of Compliance dates, those withholdings will remain in place. Financial withholdings are usually released once the reporting entity submits and ODE approves their CAP. Reporting entities which continue, for multiple reporting periods, to fall into the “Full” CAP category can lose all or a portion of the withheld funds. Reporting entities need to show improvement in their data submissions and adherence to the approved correction plan submitted.
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How long does it take for withholdings to be released once approved?
The identification of a reporting entity for the purpose of releasing withheld funds occurs on a weekly basis during the reporting period, as this is based on their data submissions. After a reporting period closes, it works basically the same way; once a CAP has been approved, the funds are identified for release and again this can occur on a weekly basis. Once the funds have been identified, the actual processing of the release usually takes an additional week.
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What is the timing for correction action requests?
CAP requests are sent within two weeks after the end of the reporting period. These requests take longer to generate as requests for overrides continue even after the reporting period ends and additional time is needed to determine which CAP will be required for each of the identified reporting entities.
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