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​The purpose of Student Specific Corrective Action (SSCA) is to identify and provide a remedy for students with disabilities who were adversely impacted during the 2016-17 and/or 2017-18 school years by special education procedural changes and “locks and blocks” in the electronic IEP system in one or more of the five areas identified by the ISBE Public Inquiry.  CPS is presently screening and hiring SSCA staff members. CPS also created a specific site for SSCA within its Special Education web page and is named “ISBE Student Specific Corrective Action.​” This page contains information on SSCA including an overview, current draft documents open for public comment, archived documents, parent notices, and SSCA/ODLSS contact information. 

 Timeline

SSCA has faced unexpected obstacles since its inception and continued rollout. The timeline below summarizes the key events that impacted SSCA and required significant revisions over the past two school years.

2018-19 School Year


  • Summer 2018 – ISBE & U.S. Department of Education’s Office of Special Education Programs (OSEP) determines IEP teams should conduct SSCA Meetings to determine appropriate remedies.
  • October 16, 2018 – Advocates request written guidance and clarification from USDOE regarding IEP team involvement.
  • January 31, 2019 – OSEP responds to request, reiterating that IEP Teams are “well positioned” to make determinations of SSCA.
  • Spring 2019 – Discussions resume regarding SSCA process, rollout, and training.
  • Spring/Summer 2019 – ISBE & CPS develop a process to identify students potentially impacted during the 2016-17 and 2017-18 school years.
    • Process discussed with stakeholders to obtain additional input
    • Training sessions developed for school staff and parents
  • July 2019 – CPS posts SSCA details on its main and ODLSS web pages

2019-20 School Year


  • July/August 2019 – Principals, Assistant Principals, and Case Managers are trained on SSCA guidelines and processes for IEP teams.
    • CPS begins to identify potentially impacted students
    • CPS, ISBE, and stakeholders begin to draft SSCA letters to parents/guardians
  • September 2019 – CPS sends 3 versions of SSCA letters to parents/guardians
    • Letter A is sent to parents/guardians of students identified by CPS data run as being potentially impacted and requiring an SSCA meeting;
    • Letter B is sent to all other parents/guardians of active/current students with disabilities with information on the SSCA process; and,
    • Letter C is a notice to all CPS parents/guardians regarding the SSCA process via website notification and a “backpack notice.”
  • September 2019 – ISBE and CPS hold SSCA trainings for parents/guardians at six Parent University sessions, including two evening sessions.
  • September 2019 – CPS sends Principals a list of students who currently attend their school and were identified by ODLSS as students potentially eligible for SSCA.
  • October 1, 2019 – The expected rollout of school level SSCA meetings is delayed by Public Act 101-0515, which requires CPS to publish all new guidelines/procedures (e.g. SSCA) for a 45-day public comment period prior to finalization.
  • October 17-30 – Chicago Teachers Union strike period.
  • November 2019 – CPS-CTU bargaining team develops bargaining agreement language stating that CPS “will not increase workload for bargaining unit members due to the Student Specific Corrective Action.” As such, CPS commences hiring procedures to staff centralized SSCA teams to implement SSCA. ISBE advises OSEP of the change in SSCA implementation due to the new language
  • November/December 2019 - CPS, ISBE, CTU, Parents, and Advocate representatives engage in discussions regarding new ways to implement SSCA and hold SSCA meetings since CTU members (i.e. school-based IEP teams) cannot be utilized given the new CPS-CTU agreement.
  • December/January 2019/20 – New SSCA implementation process.
    • CPS-proposed Universal Enrichment Remedy (UER) process accepted; further development continues. 
    • UER described in detail below.
    • Previous list of students who were potentially impacted by issues identified in the Public Inquire is reviewed to identify students now automatically eligible to receive a UER.
    • Monitors assist with individual reviews of over a thousand IEPs and documents for students who were reported by their schools to have received services despite identification of those who were possibly denied services and thus eligible for a UER.
  • February 2020 – CPS sends updated letters to parents/guardians
    • Letter 1 to Parents whose children were identified as eligible to receive a UER.
    • Letter 2 to Parents who are automatically entitled to have an SSCA meeting to determine if their child was impacted during the 2016-17 and/or 2017-18 school years.
    • Letter 3 to all other CPS Parents informing them of the SSCA process and how to request an SSCA meeting if they believe their child was impacted via issues identified in the Public Inquiry.
  • March/April 2020 – During COVID-19 (shelter-in-place requirements, remote learning days, etc.), CPS continues to seek candidates to staff centralized SSCA teams. All ISBE, CPS, and stakeholder focus shifts primarily to remote learning, with continued conversations and adjustments to proposed SSCA guidelines and procedures. CPS’ timeline during this period follows:
    • March 17-30: Act of God Days per Illinois declaration
    • March 31, April 1-3: Remote Planning Days (via ISBE)
    • April 6-10: CPS Spring Break
    • April 13: First day of remote learning for CPS

 Universal Enrichment Remedies (UER)

​A UER is an automatic remedy that will be offered to students identified as potentially adversely impacted during the 2016-17 and/or 2017-18 school years in areas identified by public inquiry. Last school year, the majority of these students were previously identified as those who would automatically receive an SSCA meeting. See above timeline for details.

While a student is typically only entitled to compensatory education services after a delay or denial of services that caused a lack of expected progress has been established, UERs are being offered to streamline the SSCA process and deliver services to students who may have been impacted by the violations identified in the ISBE Public Inquiry.

UER meetings will be conducted via conference call. A centralized ODLSS SSCA team will notify parents/guardians via U.S. mail, email, and/or telephone to inform them of their eligibility for a UER and schedule a phone conference to discuss UER options.

NOTE: The areas and years for which the student has been identified to receive a UER will be specified on the Notice of UER Conference Call document. If the parent/guardian believes that their child was impacted in another SSCA area or another year identified in the ISBE Public Inquiry Report, the parent/guardian may request an SSCA meeting.

Identification of Students Eligible for a UER

With ISBE approval, CPS utilized information from their electronic system (via SSM data pulls) to identify a class of students who were potentially impacted in three areas identified as problematic by the Public Inquiry: paraprofessional support, transportation as a related service, and eligibility for extended school year (ESY) services. For these three areas, data was pulled via the following parameters:

A student’s 2015-16 IEP was the starting point of analysis.

  • If the student’s 2015-16 IEP indicated eligibility for a particular support/service identified by the Public Inquiry, then the student’s 2016-17 and. 2017-18 IEPs were then reviewed to see if those services were removed. See Fig. 1

Fig. 1

Area Criteria
Extended School Year The student had ESY on their 2015-16 IEP but did not have ESY on the last finalized IEP in the 2016-17 abd/or 2017-18 school year(s).
Transportation The student has transportation on their 2015-16 IEP but the service was not on the 2016-17 abd/or 2017-18 IEP(s) and the student was not enrolled in his/her neighborhood school.
Paraprofessional The student had paraprofessional support on their 2015-16 IEP but the service was not on the 2016-17 and/or 2017-18 IEP(s) AND paraprofessional support was not noted in Section 10: Accommodation & Modifications or Section 11: Specialized Instruction (goal).
OR
The student's record includes a paraprofessional justification form that was left in draft during the 2016-17 and/or 2017-18 school year(s).
Specific Learning Disability The student's record includes a Learning Environment Intervention's (LEI) or Learning Environment Screening (LES) that was left in draft during the 2016-17 and/or 2017-18 school year(s).

NOTE: The review of the 2016-17 and 2017-18 IEPs was not conducted to determine whether the IEP team made the “correct” data-based decision or the student was harmed; instead, the review examines whether a “lock or block” within the system prevented the team from recommending services that the student may have otherwise been eligible to receive.

Two IEP-related areas were identified as potentially problematic by the Public Inquiry as challenging to include in the CPS data run: (1) an improper delay or denial of placement of students in a therapeutic day school setting (100% removal from the general education setting); and (2) identification of students eligible under the disability category of specific learning disability (SLD) (see Fig. 1 regarding the initial data capture). To address this problem, the notices and letters encouraged Parents to request an SSCA meeting if they believe their child was impacted in these areas.

CPS identified approximately 10,000 (i.e. about 1 in 5 students with disabilities) as qualifying for a UER. All identified students in this group may not have been delayed or denied services during the 2016-17 and/or 2017-18 school years. However, without admitting liability, CPS erred on the side of overinclusive data and agreed to provide a UER to these students without conducting further analysis.​

 UER Services and Funding UER

​UERs aim to provide options that include enrichment in the areas of academic support and tutoring, social/emotional learning, arts and culture activities, and/or physical activity and fitness programming. Depending on the service, the enrichment remedies may be provided before/after school and/or during the summer.

The amount of the remedy is based on the area identified by CPS in which the student was potentially impacted. If a student is identified by CPS as potentially impacted in more than one area, the amounts will be added together, up to a maximum UER of $4,000.00 per school year.

See Fig. 2.

CPS Identified Area Remedy
Extended School Year (ESY) Parent is entitled to a maximum of $800.00 of UER per academic school year the student was impacted.
Transportation - student attended school
  1. Mileage Reimbursement at the IRS approved rate
    2017 = 53.5 cents
    2018 = 54.5 cents
  2. ​CTA Reimbursement
  3. Cab or Ride Share Reimbursement

Parents are required to submit the Transportation Affidavit reflecting the mileage that was driven or the exspenses incurred during the impacted school year. Parents are entitled to a reimbursement up to the maximum of $4,000.00 or UER per academic school year the student was impacted.

Transportation - student missed 10 or more consecutive days due to a lack of transportation $112.50 or UER for every 5 days missed.
At a minimum, parent is entitled to $225 of UER.
The maximum is $337.50 or UER per academic school year the student was impacted.
Paraprofessional Parent is entitled to a maximum of $2000.00 of UER per academic school year the student was impacted.
Specific Learning Disability (SLD) Parent is entitled to a maximum of $4000.00 of UER per academic school year the student was impacted.​​

Parents may select a provider from a CPS Approved List of Providers (a link to the menu of these providers is given to parents/guardians with the UER notification). Parents may also request a provider of their choice, and if the provider is not on the CPS Approved List of Providers, the provider can complete the CPS vendor application process and be reimbursed upon approval. Alternatively, the parent can become a parent vendor, pay the provider, and be reimbursed by CPS.

Parents may use a portion of their UER amount for transportation costs, if applicable, to and from the UER location. Transportation costs will be reimbursed upon submission of proper proof, using the IRS-approved mileage rate.

CPS will record and track all vendor choices and services. Parents/guardians will also be allowed to change UER providers after the service has begun. CPS will be notified of the change, so they are able to note any concerns or issues regarding vendors and/or the delivery of services.

If parents/guardians are not in agreement with the UER options and/or request remedies for additional SSCA areas or years, the parent should request a formal SSCA meeting.

NOTE: Any parent who requests a SSCA meeting will not be denied the UER originally offered to the student in the event an SSCA meeting results in a determination that no denial/delay occurred or that the student made expected progress.

 Additional Identification of Students for Automatic SSCA Meetings

CPS agreed to include an additional category of students who were potentially impacted by an area identified by the Public Inquiry: delays or denials in services due to the budget appeals and position request processes during the 2016-17 and/or 2017-18 school years. CPS identified both active and inactive students in this category for whom an automatic SSCA meeting will be offered.

SSCA Meetings

If a parent/guardian did not receive notification of a UER conference call or an automatic SSCA meeting, they may request an SSCA meeting based on the following criteria:

  • The student was enrolled and attended a CPS school during the 2016-17 and/or the 2017-18 school year(s). This includes students placed at a therapeutic day school by CPS via the student’s IEP. This also includes students who have since graduated or dropped out of school.
  • The student has not already waived his/her claims as a result of a due process hearing order, settlement agreement, and/or mediation agreement.
  • For budget-related issues, the student has not already received a compensatory education meeting that addressed the same issue. CPS will verify that the student attended a school that submitted a budget appeal for a paraprofessional or special education teacher during the 2016-17 or 2017-18 school year, and that the student had services from that provider on his/her IEP at that time.

 SSCA Meeting Teams

The centralized SSCA Teams will consist of a special education teacher, who will likely also serve as district representative, a general education teacher, and the parent/guardian. The special education and general education teachers are hired by CPS to participate in SSCA meetings and are not likely to be members of the individual student’s current IEP team. At meetings when the SSCA Analysis Team will determine whether the student was delayed or denied placement in a therapeutic day school, a District Representative will also participate in the meeting per CPS policy. An ODLSS District Representative and/or ISBE Monitor may also attend any SSCA meeting to observe.

The SSCA Analysis Team will gather qualitative and quantitative data from the 2016-17 and/or 2017-18 school year(s) and any other relevant school years to enable the team to determine whether a delay/denial in supports or services occurred and whether the student made expected progress in light of their unique circumstances. See Fig. 3, containing additional information regarding the obstacles in the system or processes that may have caused a delay/denial in services during the relevant school years.

Fig. 3​

Procedural changes that may have caused delays or denials of services, eligibility, or placement:

Area Procedures
Transportation If the school was a magnet, magnet cluster, selective enrollment, charter, contract, or options schools, the OLDSS District Respresentative needed to be part of the IEP team discussion. If the school was the student's neighborhood school, the OLDSS District representative needed to be pasrt of the IEP team discussion if the reason for transportation was because the student was a threat to self or others or was unable to navigate travel to school safely. The OLDSS District Representative had to either be physically present at the IEP meeting or delegate their role to the school through completion of the OLDSS DR Review Form.
Extended School Year The ESY section of the IEP did not open for the regression/recoupement discussion until after January 17th during the 2016-17 school year or after November 15th during the 2017-18 school year and closed May 10th. The ESY Data Collection - Fall Regression/Recoupment form, which required ten weeks of data, also had to be finalized in order for the section to open. If the school was considering ESY for critical skills, the ESY section of the IEP did not open until after spring break. The ESY Data Collection - Critical Skills/Special Circumstances from had to be finalized; ODLSS District Representative authorization was required for eligibility under special circumstances; Principal sign off was required for critical skills.
Paraprofessional The Paraprofessional Justification Form, whih required five unique days of data in the relevant academic or behavior support areas across settings and Principal sign-off, had to be finalized in order for the paraprofessional question in Section 10-A to open.
Specific Learning Disability Prior to determining a student eligible with an SLD, the IEP team needed to gather at least ten weeks (two five-week interventions that were not concurrent) of data regarding tiered supports and interventions (i.e., MTSS) and enter the data into the Learning Environment Intervention (LEI) form.
Therapeutic Day School Prior to consideration of placement in a theraputic school, the team was required to implement function-based interventions and monitor progress with data collection for a minimum of five weeks. The school team was supposed to review progress monitoring data and make any necessary changes/additions to the interventions, which had to be implemented for at least five additional weeks. ODLSS District Representative authorization was required for placement in a therapeutic school.
Budget CPS's special education position funding and budget appeals processes during the 2016-17 and 2017-18 school years may have caused the paraprofessional support or specialized instruction required by the student's IEP to be delayed or denied while the school requested additional funds for a special education position needed to implement the service or because such a request was denied.​

NOTE: The student’s current school staff are expected to cooperate with the SSCA Analysis Team and respond to all inquiries in a timely manner. The parent/guardian is encouraged to bring any relevant documents to the SSCA meeting that will assist in the SSCA decision. Such information could include communication between the parent and school, documentation of private services or evaluations provided, or other information the parent/guardian believes would be helpful to the team.

Qualitative and quantitative data that may be relevant to whether the student made expected progress:

Primary Secondary
  • IEP goals, benchmarks, and progress reports
  • Report cards/transcripts
  • Benchmark assessments (NWEA/MAP, DIBELS/TRC MClass)
  • PSAT/SAT
  • Progress monitoring data (EasyCBM, AIMSWeb, F&P)
  • Norm referenced test scores(KTEA-3, WIAT-3)
  • Previously attempted interentions
  • School attendance
  • Mobility
  • Disciplinary records
  • Behavior logs/BAG reports
  • Work Samples
  • Interviews
  • Correspondance between parent and school
  • Progress notes
  • Classroom assessments
  • Classroom observations
  • Prior evaluations
  • Rating Scales
  • Outside evaluation data
  • State assessments
  • Test item/error analysis
  • Language & cultural considerations
  • Environmental factors (home stressors, trauma)​


After the 45-day comment period, CPS SSCA teams will begin to schedule UER phone conference calls and SSCA meetings. There have been a few setbacks with the CPS SSCA team’s ability to obtain applicants and hire qualified general and special education teachers to staff the SSCA meeting teams. CPS is exploring administrative-based staffing resources to conduct UER phone conferences, and an SSCA Administrative Assistant will be hired to schedule and track meetings. Test or “pilot” UER calls conducted by the CPS SSCA Team for students that may have experienced a delay or denial of transportation services revealed that it generally takes at least an hour to conduct one UER phone call. Concerns expressed by several stakeholder groups and shared by the Monitors are that the SSCA IEP meetings and the UER phone conferences may not be completed by September 30, 2021, which is the deadline to file a state complaint for issues related to the Public Inquiry. ISBE has requested consideration of legislation that would extend the deadline for parents/guardians/students to file a state complaint for an issue related to the Public Inquiry.​

The Monitors will continue to focus on training various stakeholder on the SSCA and UER process, procedures and guidelines. The training deck for parents on SSCA meetings has been developed, and once the training is recorded it will be published on the ISBE Monitor and ODLSS websites. The Monitors are also in the process of developing a specialized training for educational surrogates whose students have already been identified as qualifying for a UER. This training is tentatively scheduled for the end of October 2020.​

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