Formal data governance for Part C or Part B 619 programs provides both program oversight functions organized into a decisionmaking structure and a process for management to develop, review, and implement data governance policies. A purpose, structure, and process charter outlines the approach to Part C or Part B program data governance and details basic information about the Part C or Part B 619 program and data system.
It is important to create clear purpose statements for both the Part C or Part B 619 data system and data governance structure.
- The data system purpose statement articulates the intended use of the data and informs decisionmaking, priorities, and communication with stakeholders throughout data system development and enhancement. It is often aspirational, describing how the data system will support the state’s goal of improving outcomes for young children with disabilities and their families.
- The data governance structure purpose statement articulates the purpose of the data governance structure and outlines the scope of decisionmaking authority.
Detailing the structure and process provides the framework for who is involved in data governance decisions, how data governance policies are developed and support management of the data system. Through the development of a charter, this section of the toolkit provides the foundation to formalize and sustain data governance for Part C or Part B 619 programs. It provides a basis for understanding the context for decisions and a template for developing goals and strategies to support data management functions.
The Individuals with Disabilities Act (IDEA) does not require states to state a purpose, implement a data governance structure, or design a data governance process, but it does specify data collection requirements (relevant IDEA federal regulations are referenced in the template in this section). Formalizing the purpose, structure, and process guides states’ development of clear policies and procedures, clarifies decision making authority, and outlines expectations for management of IDEA-related data.
A formalized data governance structure is charged with establishing policy and procedures for the overall management of the data and the data system. The data governance structure may be organized differently for Part C and Part B 619 programs depending on where the program is housed, where the data are located, and the extent to which the program is included in an overall agency data governance structure and processes. The data governance structure could be a state agency committee with designated representatives from each unit/division/section/program. The agency committee could be charged with overseeing data governance for all agency data-related efforts. In contrast, the data governance structure could be as simple as one or two key program staff members designated to oversee Part C or Part B 619 data governance. Regardless of the size or location of the Part C or Part B 619 program, the data governance structure must be well defined to support a clear understanding of the hierarchy of roles and responsibilities, including decision-making authority.
Because Part C and Part B 619 programs do not operate independently of the state agency where they are housed, it is essential that program staff first review the state agency’s data governance structure and policies. Part C or Part B 619 may fall within the purview of a data governance structure that already exists. In the absence of a state agency data governance structure, a program-level data governance structure should be created specific to Part C or Part B 619.
Use the considerations below to support discussion on how to:
- develop a comprehensive purpose statement for Part C or Part B 619;
- develop a data governance structure purpose statement;
- document the organization of the larger data governance structure that the Part C or Part B 619 program belongs to and how the program interacts with it or establish a program-level data governance structure; and
- outline the new program-level data governance process or how Part C or Part B 619 will interact with the larger data governance process.
These considerations should be discussed with appropriate state and local program staff, parents, and stakeholders. Additionally, if Part C or Part B 619 is part of a larger governance structure, the results of these discussions should be shared with members of that structure to increase awareness about the Part C and Part B 619 programs and to support future work on program data governance issues. Development of purpose, structure, and process does not require responses to all the considerations below to be effective. However, review of each applicable consideration will help ensure that Part C or Part B 619 programs draft a comprehensive and clear purpose, adequately describe the existing structure or establish a new program-level structure, and detail the data governance structure process.
Supporting documentation should be referenced as needed. Where appropriate, organizational charts and procedures and operations manuals detailing specific structures or actions supporting implementation should be created.
Addressing these considerations will support completion of the template following the considerations. The policy can be updated or amended later as needed.
Note: Some consideration questions are coded. “N” supports the development of a new program-based data governance structure. “E” supports issues related to an existing larger data governance structure. Questions without either code are general, to be addressed by all structures. Of course, states with existing data governance structures may also want to review the “N” considerations as best practice.
1. Purpose, Structure, and Process Charter: Purpose
- What federal legislation or executive actions allow or require Part C or Part B 619 programs to collect and manage early intervention or preschool special education data?
- What state legislation or executive actions allow or require Part C or Part B 619 programs to collect and manage early intervention preschool special education data?
- Where within the state departments/agencies is the Part C or Part B 619 program housed?
- What data system(s) is the Part C or Part B 619 program using?
- What is the funding source for the data system(s)?
- What is the purpose(s) of the data system(s) supporting your Part C or Part B 619 program relative to accountability, program operations, public reporting, and program improvement?
- Whom does the data system support? What audiences are informed by the outputs of the data system(s) (e.g., parents, program staff, state agency leaders, state legislators)?
- How does each user group use the data system?
- What is the purpose of the data governance structure?
2. Purpose, Structure, and Process Charter: Structure
- What committee, office, or individual(s) is charged with Part C or Part B 619 program data governance?
- What is the function of the data governance structure? (N)
- How does it establish policy and procedures for the overall management of the data and data system?
- How does it support decision-making authority?
- How does it inform policy determinations?
- How does it establish criteria for approving development and implementation plans?
- How does it support the review of system designs or changes?
- What is the extent of the data governance structure’s authority?
- How does the data governance structure support oversight decisions or recommendations to higher levels that make decisions?
- Who (what roles) serves on the data governance structure?
- How many members does the structure include?
- How are the members determined (e.g., selected, appointed)? (N)
- Who (what role) is designated to represent Part C or Part B 619 on the larger data governance structure? (E)
- How does the existing data governance structure meet Part C or Part B 619 needs?
- Who (what role) has authority to make decisions about data systems/data collection?
- What is the role of participating agencies in Part C or Part B 619 in the data governance structure?
- Who (what role) has authority to make decisions (e.g., changes, enhancements, integration) about data systems/data collection?
3. Purpose, Structure, and Process Charter: Process
- What are the frequency, dates, location, and duration of data governance structure meetings that address Part C or Part B 619 data? (N)
- Where are meetings held?
- How do the Part C or Part B 619 program staff members interface with their designated representative for the larger data governance structure to address program-level data governance needs? (E)
- Which role(s) are involved in the decision-making process? (N)
- What is the process for approvals or major decisions? (N)
- How do interested parties submit issues for the data governance structure to address?
- What entity (role) are they addressed to?
- How are decisions regarding submissions communicated?
- How is data governance information, including current and updated policies, made available to program staff, participating agencies, and stakeholders? (N)
- What entity or role(s) is responsible for implementing the data governance policies created by the data governance structure?
- What entity or role(s) is responsible for training and technical assistance on the data governance policies created by the data governance structure?
- What entity or role(s) is responsible for monitoring the implementation of the data governance policies created by the data governance structure?
- What entity (or role) is responsible for responding to data governance policy violations?
Use and modify this template as needed to develop a data governance purpose, structure, and process. Select the highlighted text and replace it with your state/program information. We recommend that you consult with relevant staff and stakeholders when developing these policies. Upon completing the template, be sure to follow your state’s processes for finalizing and enacting policy.