Eligibility Reviewer Training Texas Migrant Education Conference November 15-17, 2006

1. Eligibility Reviewer TrainingTexas Migrant Education ConferenceNovember 15-17, 2006 Maria Elena Garza, NGS/Quality Control Specialist megarza@esconett.org Region One ESC 1900 West Schunior Edinburg, Texas 78541 (956) 984-6000 www.esc1.net REGION I ESC

2. Purpose of Eligibility Reviewer Training • To provide intensive training on procedures and re-interview & verification scenarios to ensure accurate protocol in the Texas Quality Control Plan. REGION I ESC

3. AgendaEligibility Reviewers need to be familiar with… • Texas Quality Control Procedures • Eligibility Reviewer Responsibilities • Eligibility Process • PMOL Concerns • Non-qualifying PMOL • Non-qualifying conditions • Mapping & networking • Agricultural & Fishing Activities • Required documentation for eligibility determinations & comments for clarification • Validation Process REGION I ESC

4. Importance of Identification and Recruitment (ID&R) The State’s core responsibility is to ensure that only those children who are eligible for MEP are recruited, counted and served: • State directs MEP-funded services only to eligible migrant children; • MEP allocation is an accurate reflection of children who are migrant; and • MEP’s integrity remains strong. Section 5.1 REGION I ESC

5. Quality Control Plan Also ensures that: • Annual eligibility validations are conducted by trained ESC migrant staff. • COEs are randomly checked. Section 5.1 REGION I ESC

6. Texas Quality Control Plan • All individuals involved in identification and recruitment for the MEP must follow the guidelines and procedures outlined in section 5 of the ID&R manual. REGION I ESC

7. Texas Migrant Education Program Quality Control Procedures Know the Texas Quality Control Procedures • Recruiters must be trained by their regional ESC annually in ID&R and cannot begin recruiting students for the new school year until they have successfully completed the training. (Only those individuals who have undergone annual training can sign the COE-2.3, 2.16, ID&R Manual). • ESCs train all recruiters annually and certify them on NGS by assigning each trained recruiter and reviewer an I.D. 5.2 REGION I ESC

8. Texas Migrant Education Program Quality Control Procedures • Recruiters must always use the newest version of the Texas COE to record eligibility (2.3). • The COE Supplemental Documentation Form is required for any family who does not rely on migrancy for the sole source of income (2.20). There are 2 ways to answer question 2: • “Migrant work is the family’s only livelihood (2.21).” • Responses must be documented in the parent’s words and completed in the presence of the parent (2.20). 5.2 REGION I ESC

9. Texas Migrant Education Program Quality Control Procedures • Trained eligibility reviewers verify recruiters’ eligibility determinations. The eligibility reviewer’s signature certifies that the COE has been reviewed by a district official and that no concerns exist regarding the eligibility of any of the children listed on the COE (2.16). • COEs requiring more than 1 comment are forwarded to the ESC (1.28-1.29 or back of supplemental doc). 5.2 REGION I ESC

10. Texas Migrant Education Program Quality Control Procedures 7. COEs are used on an intra-state basis (2.6) • Residency verification occurs annually (9/1 thru 11/1 ). • The ESC conducts annual eligibility validation in coordination with the LEA. • ESC re-interviewers interview families if questions regarding the initial determination arise. • The State MEP randomly selects children for eligibility review. 5.2 REGION I ESC

11. To Investigate Eligibility A recruiter asks the following…. Who What and Where Why When REGION I ESC

12. Eligibility Criteria • Who-children under 22, no graduation or G.E.D. • What-worker is engaged in qualifying activity • When-within the last 36 months • Where-across school district boundaries • Why-PMOL *Principal Means of Livelihood means that migrant work is necessary to sustain family. REGION I ESC

13. ID&R: What’s New? REGION I ESC

14. Eligibility Process 1.Recruiter • begins by recruiting and identifying 2. Eligibility Reviewer • Re-examines and verifies the eligibility of migrant children on COE 3. NGS Data Specialist • Enters COE data into NGS 4. Re-Interviewer • Validates child’s eligibility Section 5.4-5.5 REGION I ESC

15. Key Roles in the Eligibility Process Potentially misidentified children - COE sent to State MEP 1. The Recruiter COE back to recruiter for documentation/clarification. 2. The Eligibility Reviewer 4. Re-Interviewer 3. The NGS Data Specialist REGION I ESC 5.8 5.8

16. 4. ESC MAKING DIFFICULT ELIGIBILITY DETERMINATIONS 2. ESC 1. LEA 3. State MEP 5. LEA REGION I ESC 5.10

17. 1. Role and Responsibilities of the Recruiter Primary Role: Find and enroll eligible children. Responsibilities: • Attend annual training. • Locate families. • Gather facts & determine eligibility. • Keep records. • Additional duties. Section 3.2-3.4 REGION I ESC

18. Residency Verification • The recruiter verifies between 9/1-11/1/06 that all the children on the COE are present in the school district within the reporting period 9/1-8/31. • Residency Verification - Date parent signed the COE. (for new COEs) • Residency Verification by: • conducting face-to-face visit with the family; or • obtaining school PEIMS enrollment lists. Non-enrollees = ages 3-21 who are not attending school. Section 5.13 REGION I ESC

19. Termination of Eligibility • Has no eligible moves within three years from the last QAD; • Graduates from high school/GED; or • Turns 22 years of age. Section 1.25 MEP eligibility terminates when a student: REGION I ESC

20. Who is Eligible for the MEP? • Children, not their parents, are enrolled in the MEP. • Children benefit from the services offered by the MEP. • Children qualify because they do the qualifying work or they have moved with a parent/guardian who does the qualifying work. Section 1.3, 1.21 REGION I ESC

21. Children should not be included on the COE if: • They were born after the QAD; • They have graduated from a U.S. high school or have obtained a General Education Diploma (GED); • They did NOT move across school district lines with or to join the worker; • They did not make a new qualifying move within three years (36 months) of their existing QAD). REGION I ESC

22. 2. Role of the Eligibility Reviewer • Primary Role: to re-examine & verify the eligibility of the children listed on the COE. The Eligibility Reviewer must: • Attend annual intensive training conducted specifically for reviewers by the ESC before conducting eligibility verification and signing COEs. • Carefully re-examine the COE and verify the accuracy of all required information. • Know and identify situations that require additional documentation in the form of comments. 5.4 REGION I ESC

23. Role of the eligibility reviewer The Eligibility Reviewer must: • Know how additional documentation must be recorded on the COE and COE Supplemental Documentation forms. • Know how to interpret eligibility-related data on the New Generation System (NGS). • Know which qualifying agricultural and fishing activities take place in the local area and throughout the state and nation. 5.5 REGION I ESC

24. Role of the eligibility reviewer The Eligibility Reviewer must: 7. Verify eligibility based on the reviewer’s thorough knowledge of eligibility guidelines, as outlined in the Non-Regulatory Guidance and in this manual. 8. Maintain an auditable work log detailing the jobs and time spent fulfilling the reviewer’s duties. (5.5) 5.5 REGION I ESC

25. Based on the eligibility review: • The Recruiter may be asked to revisit family. • A second recruiter may be asked to visit family. • The family may be determined ineligible for the MEP. Section 5.5 REGION I ESC

26. Role of LEA in the Eligibility Process After COE has been signed (by recruiter and reviewer) and entered into NGS: • LEAs never re-interview parent/worker to verify eligibility after the COE has been signed by the recruiter & eligibility reviewer & entered into NGS. • COEs are forwarded to ESC. Section 5.6 REGION I ESC

27. Sections of the COE I. Family Data • Eligibility Data • Child/School Data • Parent/Guardian/Self Certification • Eligibility Certification Data • Continued Residency Verification Section 2.2 The COE is composed of the following parts: REGION I ESC

28. Why Eligibility Criteria: PMOL ConcernsClarification should be documented on COE. • Family indicates that migrancy is the only source of income, yet • the timeframe surrounding the qualifying move is very limited. • multiple moves are NOT made during the year. • Worker or family members have positions that are professional in nature, requiring training or higher education. • Non-entry level occupation, especially for non-qualifying work; non-agricultural/fishing occupations 1.23 REGION I ESC

29. Why Eligibility Criteria: PMOL ConcernsClarification should be documented on COE. Moves from urban or non-traditional migrant areas part-time non-agricultural/fishing employment non-migrant lifestyle 1.23 REGION I ESC

30. Why Eligibility Criteria:Non-Qualifying Conditions Related to Primary Purpose • A single one day move. • A move to relocate to the United States. • A move to seek non-agriculturally related work such a construction work. • A move to seek political asylum. • A move from a country other than Mexico or Canada. Section 1.20 REGION I ESC

31. Why Eligibility Criteria:Non-Qualifying Conditions Related to Primary Purpose • A move back to Mexico. • A move where a worker is returning form doing agricultural work in Mexico, visiting a sick relative, or traveling for personal reasons. • A move where a worker is returning to the same job after taking a vacation or taking leave without pay. • A “to seek” move back to the worker’s homebase. 1.20 REGION I ESC

32. When Eligibility Criteria:Non-Qualifying Conditions • A first time “to seek” move; • A second consecutive “to seek” move; • A “to seek” move back to the worker’s home base. • A ‘to seek” short distance and/or short duration move. • A ‘to seek” move where the worker never arrived at the work site. Section 1.26 REGION I ESC

33. When Eligibility Criteria:Non-Qualifying Conditions • Any “to seek” move that cannot be documented by well-established migratory pattern AND an explanation as to why work was not obtained. • A “to join” move in which a child’s move occurs after a year of the worker’s move. • A move of a single day. • Moves for 7 day or less, unless required documentation is supplied in the comment section. 1.26 REGION I ESC

34. When Eligibility Criteria:Non-Qualifying Conditions • A move of short distance (100 miles or less), unless required documentation is supplied in the comment section. • A move with the purpose of establishing a new residence or permanent location. • Permanent employment in a qualifying activity. • Work in which a worker is hired on a “probationary basis.” REGION I ESC

35. When Eligibility Criteria:Non-Qualifying Conditions • A move where a worker is returning from vacation, leave without pay, doing agricultural work in Mexico, visiting a sick relative, or traveling for personal reasons. • A move for political asylum • An international move from a non-border country. • Activities involving transporting or hauling. • Personal subsistence. • Daily commuting. • Activities, or a series of activities, that would be either temporary or permanent. • Supplemental income involving work in a professional or certified field. 1.27 REGION I ESC

36. What is an eligibility comment? • There are eleven comments related to eligibility that must be supplied on a COE. From “The Weekly Recruiter” July 12, 2006 REGION I ESC

37. Required Documentation:Comments Needed on COE • “To seek” move • Short distance move • Short duration move • Temporary employment • “To join” move • Qualifying move back to home base Section 1.28 REGION I ESC

38. Required Documentation:Comments Needed on COE (cont.) • Multiple intent move • Early move • Industrial survey • Unusual qualifying work • Series of activities that could be considered year round • Industrial survey Section 1.29 REGION I ESC

39. What is a procedural comment? • A procedural comment is a comment that clarifies an item on the COE that is not directly related to the eligibility determination. Examples of procedural comments are: • A second COE was needed to include all the children in the family who made the move with the worker; • The child was the worker but, because of age, the mother signed the COE. Child was present during the interview and supplied the information; or • Comment references another COE on file. From “The Weekly Recruiter” July 12, 2006 REGION I ESC

40. Required for Clarification Purposes:Additional Comments • Guardian • Self • Cross-Referencing Children • Intrastate Movement • Changes on the COE 1.29 REGION I ESC

41. Basic Steps for Accuracy • Complete COE using black or blue ink; • Corrections are made using redink, dated and initialed (Section 2.5); • Review COE for blanks; • Compare Qualifying Arrival Date (QAD) vs. Residency date; • Include all necessary comments to support eligibility; • Check COE for accuracy, legibleness and neatness; • Must be completed in English only; • Recruiters MUST not give the parents a copy until all signatures have been obtained & eligibility has been established. Section 2.3 REGION I ESC

42. Critical and Non-Critical Errors4.41 • A critical error is data or information that indicates that the children listed on the COE are not eligible for migrant services. Examples of critical errors are the following: • Child did not accompany worker; • Move was to permanently re-locate; or • Work was of a permanent nature. • A non-critical error is data or information that is missing or is specified incorrectly, but is not essential to identifying the children listed on the COE as eligible for migrant services. Examples of non-critical errors are: • Lack of supporting comments on COE; • Lack of specific detail in qualifying activity; or • Wrong dates reported on COE. From “The Weekly Recruiter” July 12, 2006 REGION I ESC

43. Forward COEs forAdditional ReviewLEA to ESC • COEs containing more than one comment (may be forwarded from ESC to State MEP if unable to make an eligibility determination). • PMOL concerns (may be forwarded from ESC to State MEP if unable to make an eligibility determination). • COEs on existing QADs containing conflicting qualifying information (may be forwarded from ESC to State MEP if unable to make an eligibility determination). • LEAs cannot change QADs on COEs. LEA must forward COE and reasons why QAD should be changed to the ESC migrant staff. (ESC should check with the state if unsure if new QAD falls outside of the reporting window). • Extenuating circumstances. • Potentially misidentified children Section 5. REGION I ESC

44. Forward COEs forAdditional Review (cont.)From ESC to State • Extenuating circumstances • Potentially misidentified children Section 5.11 REGION I ESC

45. Exceptions Children not eligiblefor the MEP: • Children who are born after the qualifying arrival date. • Children who did not make the move across school district lines or to join the worker. • Youth who have graduated from a U.S. high school or have obtained a General Education Diploma (GED). • Did not make a new qualifying move within three years of the existing QAD. Section 2.2 REGION I ESC

46. COE Copy Distribution After the form is signed by the recruiter and the eligibility reviewer, the copies should be distributed as follows: • The recruiter should give the goldenrod copy to the parent/guardian/worker. • The original (white) form should be filed in the auditable file for the district or the fiscal agent. • The yellow copy should be forwarded to the ESC. • The pink copy should be forwarded to the PEIMS clerk unless arrangements have been made to keep PEIMS copy in the migrant department/office. Section 2.22 REGION I ESC

47. Yellow Copies • The Texas MEP recommends that in districts with more than 100 identified migrant students, the ESC select a random sample of at least 1% of the yellow copies submitted to them to review for non-critical as well as for critical errors. This should be done as part of the ESCs ongoing quality control process. When errors are found, the ESC must contact the district to follow up in terms of eligibility determinations and/or to make corrections on the COE as needed. 5.7 REGION I ESC

48. Maintaining Auditable Files • The original Certificate of Eligibility must be maintained by the fiscal agent. The fiscal agent must also maintain documentation regarding annual training of all individuals signing the COE. • Retention of COE (original) is 10 years from the QAD Section 2.24 REGION I ESC

49. Why Mapping and Networking? To locate all migrant children residing within the state: • Map where migrant families reside; • Map agriculture and fishing areas; • Maintain lists of migrant housing; • Conduct community and industrial surveys; • Network with agencies. Section 5.3 REGION I ESC

50. Texas Fresh Produce Availability Chart • Created by the Texas Department of Agriculture. • Information on the months when the fruits and vegetables are available in different regions of the state. • Familiarizes recruiter with produce season/cycle. Section 4.27, 4.29-4.32 REGION I ESC