MODULE 4: Eligibility Determinations and the Interview

Section 1: Ethics and Recruitment Standards
Section 2: MEP Eligibility Determinations
Section 3: Interviewing Families and Youth
Section 4: Decision Making
Section 5: Determining the Need for a Follow-up Interview

Section 1: Ethics and Recruitment Standards

Goal

The recruiter will demonstrate the knowledge of ethical behaviors in determining the eligibility of a child or youth.

Objectives

After completing this section, the participant will be able to:

Define “ethics,”

Explain the importance of maintaining high ethical standards,

Explain the purpose of an ethics policy,

Identify the MEP standards of conduct for the recruiter, and

Apply the MEP standards of conduct in making child eligibility determinations.

Materials:

“Ethics” PowerPoint
MEP Recruiter Ethics Policy

Defining Ethics:

Ethics: “A discipline dealing with what is good and bad and with moral duty and obligation; a set of moral principles: a theory or system or moral values; The principles of conduct governing an individual or a group; A guiding philosophy; A consciousness of moral importance.” (http://www.merriam-webster.com/disctionary/ethics)

Additional points to remember:

Ethical decisions are often difficult to conceptualize clearly.
Ethical problems frequently come in shades of gray, rather than black-and-white.

Review “Ethics” PowerPoint Slide (5)

Think of a situation in which you needed to make an ethical decision. What was the conflict in that situation? How did you feel after making the decision?

Additional Points:

Sometimes the conflict for recruiters can be balancing their personal values with the values of the organization. A recruiter’s desire to help a migrant family in need may tempt him/her to ignore the eligibility requirements, but the ethical (and legal) decision is to act within the legal bounds of the program.
Despite the discomfort that sometimes comes with making an ethical decision, it is important to maintain high ethical standards in order to:

Establish trust,
Adhere to guidelines,
Ensure everyone is treated fairly and justly,
Maintain high expectations, and
Develop accountability.

Guidelines that direct recruiters on how to act ethically are called “standards of conduct.”

The standards of conduct to which a recruiter should adhere could include:

Protect the privacy and confidentiality of all migrant family data,
Abide by all laws,
Be honest in interactions with other people,
Avoid misuse of authority,
Know the eligibility rules,
Be objective,
Report fraud and misconduct,
Treat people the way they want to be treated,
Fill out all paperwork accurately and truthfully, and
Avoid misuse of MEP resources.

These standards of conduct form the basis of an ethics policy. The purpose of an ethics policy is to support a culture of openness, trust, and integrity.

**Note: The terms standards of conduct, standard of ethics, ethics policy, etc. are often used interchangeably. Think of standards of conduct as the building blocks for an ethics policy, which is an official document that establishes expectations.

An Ethics Policy is important in order to:

Establish a culture of openness and integrity,
Establish trust,
Develop accountability,
Adhere to legal guidelines, and
MEP recruiters are funded by public funds and have a responsibility to the public.

Review the MEP Recruiter Ethics Policy:

Migrant Education Recruiter Ethics Policy

The recruiter’s primary responsibility is to properly identify and recruit migrant children for the Migrant Education Program (MEP). In carrying out this work, every recruiter is expected to make a commitment to ethical professional behavior. This ethics policy explains what this commitment means.

Recruiters work with migrant farm workers and their families, who are often highly mobile, experience educational disruptions, encounter cultural and language barriers, live in poverty and rural isolation, and have health-related problems that inhibit their ability to do well in school. This policy is intended to serve as a basis for ethical decision-making in the conduct of identification and recruitment.

Migrant Education Recruiter Standards Of Conduct

1. Know the eligibility rules. The recruiter should study and prepare to make proper eligibility determinations. The recruiter is expected to have up-to-date knowledge of the rules of eligibility established at both the federal and state level.

2. Be objective. Recruiters are expected to put aside personal beliefs and biases when making eligibility determinations and to base all decisions on objective facts. Gender, race, religion or age should have no bearing on a recruiter’s decisions. Other factors, including whether a particular child “deserves” assistance, should not be considered.

3. Be honest. The recruiter’s job is to gather information, provide clear documentation on the Certification of Eligibility, and help make the eligibility determination. Recruiters must not exaggerate, falsify or omit information. Falsification of program documents may deprive eligible migrant children of needed services, is against the law and could result in criminal prosecution. Honest recruiters keep the MEP safe so that eligible migrant children will continue to receive educational services.

4. Report fraud. It’s the recruiter’s job to protect the reputation and integrity of the MEP. If the recruiter feels pressured to enroll a child who doesn’t appear to be eligible or observes others who are being pressured or who are committing fraud, it is the recruiter’s responsibility to report what he or she has observed.

Identify Fraud, Falsification or Misconduct

The dictionary defines fraud as, “intentional perversion of truth in order to induce another to part with something of value or to surrender a legal right” or “an act of deceiving or misrepresenting.”1 It defines falsify as “to represent falsely” or “misrepresent.”2 It may be difficult to understand how these terms apply to the identification and recruitment (ID&R) of migrant children, particularly since it may not seem that any particular person is being deceived. In the case of fraud, intentional falsification or misconduct in ID&R, it is the federal government that is being deceived. Ultimately, when there is fraud, intentional falsification or misconduct in ID&R, the public at large, who pay taxes in the belief that federal funds are being spent as authorized by Congress, is being deceived, as is the federal government, which awards state funding on the assumption that state child counts are accurate. Furthermore, counting children who are not eligible for the MEP can affect the size of subgrants within each state and can dilute services to eligible migrant children. This is why it is important to preserve the public trust by rooting out fraud, intentional falsification and misconduct in ID&R.

Although it is not possible to provide a complete guide of how fraud or misconduct would look in ID&R, here are some tip-offs or examples of possible fraud or misconduct:

• A supervisor tells a recruiter that the recruiter needs to give the supervisor 40 new COEs by the next week, even though it is impossible to find that many eligible children and interview their families in that amount of time.

• A recruiter picks out a needy family each year and enrolls their children in the MEP so they can get extra services, even though the recruiter knows they don’t qualify.

• A data entry specialist points out missing information on a recruiter’s COEs; the recruiter disappears for a few minutes and then returns with the information filled out. The data entry specialist thinks the recruiter made up the information since the recruiter couldn’t possibly contact the family in that short amount of time.

• A supervisor announces that any recruiter who finds 5% more children than he or she found the previous year will get an expense paid trip to the National Migrant Education Conference.

• A local recruiting agency qualifies children whose parents supposedly moved to find work picking blueberries. However, none of the workers ever actually seem to get jobs in agriculture. Most, if not all, of the families find work in construction or other non-qualifying jobs.

Report Fraud, Falsification or Misconduct

If a recruiter observes fraud, falsification or misconduct, some things he or she can do include:

• If the recruiter has been asked to do something he or she believes is inappropriate, the recruiter should make it clear that he or she isn’t comfortable with what is being asked.

• Write down what happened with as much detail as possible (if others witnessed what happened, have them write down what they observed as well).

• Report what happened to the appropriate person (if the supervisor is involved, the recruiter should report the problem to someone who is at a higher level within the MEP).

The recruiter should not do things that he or she believes to be wrong, and should follow up on any concerns until they have been properly addressed. Furthermore, if the recruiter suspects that another recruiter is enrolling children in the MEP who are not eligible, the recruiter is obligated to report that as well. If the state MEP does not take the recruiter’s concern seriously, the recruiter should report the problem to the federal Office of Migrant Education. Current contact information is available on the U.S. Department of Education’s website at http://www.ed.gov/about/offices/list/oese/ome/aboutus.html#contact.

Anyone suspecting fraud, waste or abuse involving U.S. Department of Education funds or programs should also call or write to the Office of the Inspector General’s (OIG) Hotline. The OIG keeps these complaints confidential; it will not release the recruiter’s name, address or any other identifying information. The OIG can be contacted using any of the following methods:

• Call the OIG Hotline’s toll free number 1-800-MIS-USED. The Hotline’s operating hours are from 9:00 a.m. until 4:00 p.m. Eastern Time, Monday through Friday, except for holidays;

• Send an e-mail message to oig.hotline@ed.gov.

• Complete and submit an electronic Complaint Form, which is available on the U.S. Department of Education’s website at: http://www.ed.gov/about/offices/list/oig/hotlineform.html.

• To ensure complete anonymity, download a hardcopy of the special complaint form, complete, and mail to:
Inspector General’s Hotline
Office of Inspector General
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202-1510

Fraud or intentional falsification is not something that should be taken lightly. Remember that the recruiter commits to this Code of Ethics every time he or she signs a Certificate of Eligibility, which has a statement like the following:

I certify that these students are eligible for MEP services based on the information provided by
the parent/guardian/worker identified in the box to the left. I hereby certify that, to the best of
my knowledge, the information is true, reliable, and valid. Any false statement provided herein is
subject to fine or imprisonment pursuant to 18 U.S.C. 1001.

The recruiter has a special opportunity to help migrant children receive needed educational services through the MEP. Every service that is provided starts with a competent and qualified recruiter who is doing his or her job correctly and ethically (U.S. Department of Education. 2007. No Child Left Behind. Title I, Part C, Education of Migratory Children: Draft Migrant Education Program Identification and Recruitment Manual, Pages 179-182).

Please print a copy of this policy and post it in your office: MEP Recruiter Ethics Policy

Organization Values

Ethics policies may also include a statement of organization values. By making these values explicit, the organization encourages members to act based on specific principles. Consider the following example from the American Heart Association:

What values guide you in your work with the MEP?

“Ethical Issues and Solutions” Exercise

Please read the following case studies carefully, then answer the questions below.

Case Study #1
A local recruiter, Francisco Díaz has been working in the MEP for fifteen years. He is well liked throughout the community and works well with all of the agencies serving migrant families. Just recently, he received a community award for setting up a food drive during the holiday season. During September of last year, many migrant families moved into the area to harvest apples. The children of the migratory families were identified and recruited into the MEP program, thus eligible to receive educational and support services. During the data entry
process, the records clerk noticed three COEs listing children from longtime community families. She brought this concern up to Francisco’s attention. Francisco said that the children need the educational services and to leave them in as eligible. The data clerk didn’t agree and took the issue to Francisco’s supervisor. The supervisor told the data clerk to leave the issue alone since no one will know the difference if the children are eligible or not. The data clerk is not happy with the decision but is reluctant to say anything to upset Francisco or her supervisor.

What are the ethical issues?

What are the possible solutions?

Case Study #2
In the last couple of years, the number of eligible migrant children in the State has dropped and allocations to each of the districts have been lowered. The Calibri Valley District has begun to panic as they see their student numbers drop, allocations lowered, and good staff taking other jobs. The district leadership decides to evaluate the situation and do something about their identification and recruitment program. The district coordinator introduces a new incentive program in the fall. Each recruiter will need to identify 25 new students, over and
above last year’s numbers. The district says this proposed plan will increase student enrollment and guarantee their jobs, and the recruiter who identifies the most students will go to the National Migrant Education Conference in the spring. The district incentive brings a lot of excitement, enthusiasm, and competition among some of the recruiters.

What are the ethical issues?

What are the possible solutions?

Case Study #3
Jake Lamada is a well-respected recruiter at Middleton Unified School District. He has been recruiting migrant families for five years. Recently, he was instructed by his supervisor to look into concerns by other migrant education staff regarding the eligibility status of some migrant families in the district.

Drywood Elementary has a long history of migrant children withdrawing from school in December to travel to Mexico and then re-enrolling back in the school two or three weeks later. The recruiter at Drywood Elementary has been with the district for fifteen years and, due to her popularity and experience with the MEP, is very well known within the migrant community.

Jake met with MEP staff and began reviewing all Certificate of Eligibility (COEs) from Drywood Elementary. He reviewed the number of students that were withdrawn from school in December and re-enrolled two or three weeks later. He noticed that a small number of COEs with a new Qualifying Arrival Date (QAD) were completed for a few migrant families. Jake is informed by MEP staff that the migrant families that were given a new QAD were personal friends of the recruiter.

Jake noticed that the families in question, the one’s with new QAD’s, did not have any clarifying information in the comments section of the COE explaining why a new QAD was established. The other migrant families in the same situation all had comments explaining why a new QAD was established. Consequently, the new COEs were found to be ineligible in establishing a new QAD.

What are the ethical issues?

What are the possible solutions?

ANSWERS

Answers to Case Study #1:

Ethical issues:

Francisco is trying too hard to earn community respect and feel good about helping people. He is ignoring the legal guidelines and breaking the law by not adhering to proper legal use of funds.

Possible solutions:

Francisco needs to acknowledge that these children are not eligible for the program and follow the rules.

Answers to Case Study #2:

Ethical issues:

The district coordinator’s incentive policy could potentially lead to ineligible children being signed up for the MEP. The state might receive funding for these ineligible children, but using those funds for ineligible children would be a direct legal violation, questions could arise as to whether this information is accurate and truthful.

Possible solutions:

It is the recruiter’s responsibility to call the fraud hotline.

Answers to Case Study #3:

Ethical issues:

The recruiter is showing personal preference by extending the period of eligibility for some families but not for all. Given the inconsistency of the documentation among CEOs with children who are all in the same situation, questions could arise as to whether this information is accurate and truthful.

Possible solutions:

Jake should sit down with recruiter and clarify the information. If the families are, in fact, eligible then the recruiter needs to consider the other families in the same situation. If they are not eligible, he needs to remove the students from the computer system and report them as not eligible.

Review “Ethics” PowerPoint Slide (5)

What type of conflict did you witness in each case study?

Answers are:

Case Study #1

Conflict between personal values and values of the organization.

Case Study #2

Conflict between basic principles and the need to achieve a desired outcome.

Case Study #3

Conflict between personal values and values of the organization.

What are some unethical behaviors one should be careful to avoid?

Answers could include:

Incentives,
Increasing student count with ineligible students,
Falsifying information, and
Misconstruing program regulations.

Section 2: MEP Eligibility Determinations

Goal

The recruiter will demonstrate mastery of child eligibility requirements under the Title I, Part C Migrant Education Program (MEP).

Objectives

After completing this section, the participant will be able to:

Explain the requirements for determining child eligibility according to federal statute and regulations,

Explain the child eligibility sections of the draft Non-Regulatory Guidance and the draft ID&R Manual,

Describe the recruiter’s role in making the initial child eligibility determination according to the State and local process, and

Identify and use tools to aid in determining and justifying child eligibility.

Materials:

“Eligibility Requirements Study Group Review” PowerPoint

“Eligibility Definitions and Factors” PowerPoint

Basic Migrant Child Eligibility Factors Handout V.1.0

Review “Eligibility Requirements Study Group Review” PowerPoint Slides (2-3)

Eligibility Terms: What is meant by the following terms?

Qualifying work:

Qualifying work means temporary employment or seasonal employment in agricultural work or fishing work.

Agriculture work:

Agricultural work means the production or initial processing of crops, dairy products, poultry, or livestock, as well as the cultivation or harvesting of trees. It consists of work performed for wages or personal subsistence.

Fishing work:

Fishing work means the catching or initial processing of fish or shellfish or the raising or harvesting of fish or shellfish at fish farms. It consists of work performed for wages or personal subsistence.

In order to obtain:

In order to obtain, when used to describe why a worker moved, means that one of the purposes of the move is to seek or obtain qualifying work.
If a worker states that a purpose of the move was to seek any type of employment, i.e., the worker moved with no specific intent to find work in a particular job, the worker is deemed to have moved with a purpose of obtaining qualifying work if the worker obtained qualifying work soon after the move.
Notwithstanding the introductory text, a worker who did not obtain qualifying work soon after a move may be considered to have moved in order to obtain qualifying work only if the worker states that at least one purpose of the move was specifically to seek the qualifying work, and—

(i) The worker is found to have a prior history of moves to obtain qualifying work; or

(ii) There is other credible evidence that the worker actively sought qualifying work soon after the move but, for reasons beyond the worker’s control, the work was not available.

Migratory agricultural worker:

Migratory agricultural worker means a person who, in the preceding 36 months, has moved, as defined in paragraph (g), from one school district to another, or from one administrative area to another within a State that is comprised of a single school district, in order to obtain temporary employment or seasonal employment in agricultural work, including dairy work.

Migratory child:

Migratory child means a child— (1) Who is a migratory agricultural worker or a migratory fisher; or (2) Who, in the preceding 36 months, in order to accompany or join a parent, spouse, or guardian who is a migratory agricultural worker or a migratory fisher—

(i) Has moved from one school district to another;

(ii) In a State that is comprised of a single school district, has moved from one administrative area to another within such district; or

(iii) As the child of a migratory fisher, resides in a school district of more than 15,000 square miles, and migrates a distance of 20 miles or more to a temporary residence.

Migratory fisher:

Migratory fisher means a person who, in the preceding 36 months, has moved, as defined in paragraph (g), from one school district to another, or from one administrative area to another within a State that is comprised of a single school district, in order to obtain temporary employment or seasonal employment in fishing work.
This definition also includes a person who, in the preceding 36 months, resided in a school district of more than 15,000 square miles and moved, as defined in paragraph (g), a distance of 20 miles or more to a temporary residence in order to obtain temporary employment or seasonal employment in fishing work.

Move or moved:

Move or moved means a change from one residence to another residence that occurs due to economic necessity.

Personal subsistence:

Personal subsistence means that the worker and the worker’s family, as a matter of economic necessity, consume, as a substantial portion of their food intake, the crops, dairy products, or livestock they produce or the fish they catch.

Temporary employment:

Temporary employment means employment that lasts for a limited period of time, usually a few months, but no longer than 12 months.

Seasonal employment:

Seasonal employment means employment that occurs only during a certain period of the year because of the cycles of nature and that, by its nature, may not be continuous or carried on throughout the year.

Additional information regarding these terms can be found in the Non-Regulatory Guidance issued by the OME: 2010 Non-Regulatory Guidance

Eligibility Factors

6 Basic Eligibility Factors

1. AGE

The child is younger than age 22

2. SCHOOL COMPLETION:

The child is eligible for a free public education (e.g., the child is not a high school graduate and does not hold a high school equivalency certificate.)

3. MOVE ACROSS SCHOOL DISTRICT BOUNDARIES:

The child moved from one school district to another.

4. DATE OF MOVE:

The child moved within the past 36 months.

5. REASON FOR THE MOVE:

The worker moved in order to seek or obtain qualifying work.

6. QUALIFYING WORK

The worker sought or obtained temporary or seasonal employment in agricultural or fishing work.

Review “Eligibility Factors” PowerPoint slide (25)

All 6 Eligibility Factors must be present for each and every child.

Additional points to consider (FYI):

If a State has only one school district (Hawaii or Puerto Rico), the requirement is that the child has moved from one administrative area to another within the district.
If a family resides in a school district larger than 15,000 square miles, the requirement is that the family has moved 20 miles or more to a temporary residence to engage in a fishing activity. (This provision applies only to Alaska.)

Another way to visualize the Eligibility Factors is through a “Yes/No” chart.

Again, all 6 Eligibility Factors must be “Yes” for each and every child.

OME has provided 2 concise reference pages to help remember the factors and official definitions (links below).

Basic Migrant Child Eligibility Factors Handout V.1.0

MEP Definitions Poster-8 x 11 V. 1.0

Eligibility Scenarios

Scenario 1

Are the Gómez children eligible for Migrant Education Program services?

A. Yes

B. No

C. Need More Information

Answer: A

Points to be noted:

A qualifying move was made by the parents in order to obtain employment in an agriculture-related job, and the move was made within the last 36 months. All six eligibility factors are met in this case. The children qualify for MEP services. See factors below.

In Region 1, this move would be a 4c move.

Eligibility Factors to Consider:

Age of Children: The children meet the age requirement (15,17).
School Completion: The children have not graduated from high school or obtained their GED.
Move Across School District Boundaries: The children moved across school district boundaries (Tucson, Arizona, to local community).
Date of Move: The children moved within the past 36 months (March 15, two years ago).
Reason for the Move: The family moved to seek qualifying work.
Qualifying Work: The worker sought seasonal employment in agricultural work.

Agriculture or Fishing Work: The work qualifies because it is agricultural.
Temporary or Seasonal Employment: The work qualifies because it is seasonal.

Scenario 2

Do any members of this family make a qualifying move?

A. Yes

B. No

C. Need More Information

Answer: A

Points to be noted:

Children of a family that seeks political refuge are not necessarily eligible for the MEP. The two children, ages 8 and 10, who made the move with the parents are not eligible for MEP services, although subsequent moves may qualify the children later. Not all of the eligibility factors are met here, so the younger children are not eligible. However, the two older children, ages 16 and 17, made a qualifying move when they moved to join the parents and find qualifying work. It is important to note that unaccompanied minors and emancipated youth who are themselves migrant workers or who are married to a migrant worker can make qualifying moves on their own.

Eligibility Factors to Consider:

Age of Children: All these children (ages 8, 10, 16, and 17) meet the age requirement.
School Completion: The children have not graduated from high school or obtained their GED.
Move Across School District Boundaries: The moves were made across school district boundaries.
Date of Move: Both moves were within the past 36 months.
Reason for the Move: The first move, made by the parents to seek refuge with the 8- and 10-year-old children does not qualify these children. It appears that the older children were already living in the United States. However, when the two older children moved from Barron, Wisconsin, in April, they became eligible once they found qualifying work.
Qualifying Work: Initially, the parents’ move was not to seek qualifying work in the United States. However, the work is agricultural and possibly temporary. When the two older children moved and found qualifying work, they became eligible.

Agriculture or Fishing Work: The work qualifies because it is agricultural.
Temporary or Seasonal Employment: The work qualifies because it is temporary.

Scenario 3

Does the family qualify for MEP services?

A. Yes

B. No

C. Need More Information

Answer: A

Points to be noted:

A qualifying move was made by the parents to seek employment in an agricultural (melon packing shed), and the move was made within the past 36 months. All six eligibility factors are met in this case. The child and the parents qualify for MEP services. See factors below.

Eligibility Factors to Consider:

Age of Children: The child and parents meet the age requirement (3 and 20).
School Completion: All the family members have not graduated from high school or obtained their GED.
Move Across School District Boundaries: The parents and child moved across school district lines (from Hope, Arkansas, to Beardstown, Illinois).
Date of Move: The move was made within the past 36 months (April 1).
Reason for the Move: The family moved to seek employment in an agricultural job.
Qualifying Work: The family sought seasonal employment in agricultural work.

Agriculture or Fishing Work: The work qualifies because packing or sorting melons is agricultural.
Temporary or Seasonal Employment: The work qualifies because it is seasonal.

Scenario 4

Are the children eligible for MEP services?

A. Yes

B. No

C. Need More Information

Answer: C

Points to be noted:
Roberto and Dunia Treviño and their three children, Ava age 6, Yolanda age 9, and Perla age 11, live in Paw Paw, Michigan. Were the children eligible for the MEP in Paw Paw? It is not clear. Is the work seasonal or temporary? More information is needed about the move to Mexico and the move back to Michigan.

Eligibility Factors to Consider:

Age of Children: The children meet the age requirement (under 22).
School Completion: The children have not graduated from high school or obtained their GED.
Move Across School District Boundaries: The facts here are not certain. You would need more information about the move to Paw Paw, Michigan.
Date of Move: The move was made within the past 36 months, but there is not enough information to determine whether this was a return from vacation or to seek or obtain qualifying work.
Reason for the Move: More information is needed here as you cannot be certain whether the requirements for a qualifying move were met when the family returned to Lagunillas.
Qualifying Work: It is not clear if the work is qualifying work.

Agriculture or Fishing Work: The work is agricultural.
Temporary or Seasonal Employment: You need more information to know whether the job at the nursery was permanent.

Scenario 5

Do the Adams’ children qualify for MEP services?

A. Yes

B. No

C. Need More Information

Answer: A

Points to be noted:
A qualifying move was made by the parents to seek employment in a fishing-related job and the move was made within the last 36 months. The father has a history of moving each summer to fish for salmon, and the money earned is crucial to the family’s income. All six eligibility factors are met in this case, so the children qualify for MEP services. See factors below.

Eligibility Factors to Consider:

Age of Children: The children meet the under-22 age requirement.
School Completion: The children have not graduated from high school or obtained their GED.
Move Across School District Boundaries: The children moved across school district boundaries with their parents, from Tacoma, Washington to Homer, Alaska.
Date of Move: The children moved within the past 36 months.
Reason for the Move: The family moved to obtain employment in a fishing-related job.
Qualifying Work: The work was seasonal employment in fishing.

Agriculture or Fishing Work: The work meets this requirement because it is directly related to the production of fish.
Temporary or Seasonal Employment: The work meets this requirement because it was seasonal, occurring over the summer.

Section 3: Interviewing Families and Youth

Goal

The recruiter will know how to effectively interview a family or youth for the Migrant Education Program (MEP).

Objectives

After completing this section, the participant will be able to:

Explain the purpose of an interview;

Apply basic interviewing strategies to build rapport, overcome resistance, elicit information, confirm information, and record information for observation, including:

Realize when to use probing questions and

Demonstrate how to use probing questions and avoid asking leading questions;

Describe the components of an interview for determining MEP eligibility; and

Conduct a child eligibility interview for the MEP.

Materials:

“Interviewing Techniques and Strategies Goal and Objectives” PowerPoint

“The Interviewing Process” PowerPoint

“Elements of an Interview” PowerPoint

“Types of Questions” PowerPoint

“Questions and Answers” PowerPoint

“Interviewing” video

The Interviewing Process

Points to consider:

The purpose of an interview is for a recruiter to obtain the specific information needed to determine a child’s eligibility for the MEP.
The recruiter must be careful not to offend the family while gathering the sometimes very personal information needed to determine eligibility.
The interview process consists of all activities associated with obtaining the information and building the relationship with the migrant family.

Review “The Interviewing Process” PowerPoint slide (3)

Points to be noted:

The interview process consists of three sets of activities:

Those that are done to prepare for the interview,
Those that are done during the interview itself, and
Those that are done after the interview.

Before the Visit

Review “The Interviewing Process” PowerPoint slides (4)

Additional steps to perform:

Utilize referral services prior to the visit so that you bring useful resources
Make arrangements for a translator to accompany you (if needed)
Dress neatly, but not too formally, so that the family is comfortable
Consider placing a large magnetic sign on the door of your vehicle, clearly identifying the MEP
Let all appropriate parties (i.e., schools, employers, housing unit manager) know your reason for contacting families
Review the Sample Interview Script and basic child eligibility to be discussed at the interview
Bring your personal digital assistant (PDA), laptop, COE forms and writing materials
Create a checklist and be organized before the interview
Remember that you represent the MEP and the program’s success is vital to the migrant community

During the Visit

Review “The Interviewing Process” PowerPoint slide (8)

Points to be noted:

A recruiter always needs to be observant of the surroundings for both safety reasons and clues of issues that may require asking additional questions to help determine eligibility.
For example, upon seeing a migrant mother operating a day-care business out of her home, a recruiter might want to ask whether the family has moved within the last three years.
A recruiter should start an interview by introducing himself/herself and providing a general explanation of the program.
A recruiter should establish rapport by commenting on something the recruiter has in common with the person being interviewed, such as “I used to live in Texas, too.”
A recruiter should take notes rather than rely on memory in case questions arise later.

Review “The Interviewing Process” PowerPoint slide (9-10)

Points to be noted:

Recruiters should help the family feel comfortable by being friendly and conversational rather than too business-like.
Asking probing questions too early in the interview can sometimes be offensive.
Use active listening skills, such as:

Focusing on the speaker,
Leaning forward,
Restating the speaker’s key points,
Showing interest by facial expressions and nodding, and
Asking relevant questions.

Recruiters may need to reword a question to help the interviewee understand what information is needed.
Recruiters should answer questions if they know the answer or do additional research and get back to the family with a response later.
A recruiter may need to ask more questions if an interviewee gives conflicting or unclear answers.
If an interviewee moved to find work that had not previously qualified, the recruiter would need to collect additional information from the State to determine if the status has changed.
If recruiters fail to properly apply eligibility requirements, children could be incorrectly identified as eligible for the MEP.
Sometimes family members will say whatever is necessary to get MEP services for a child. Recruiters need to be vigilant for discrepancies.

After the Visit

Review “The Interviewing Process” PowerPoint slide (11)

Additional steps to perform:

Is there anything more we do in Region 1?

One example would be reviewing the COE on your laptop for complete notes and to make sure that it paints a “complete and concise picture” of the migrant family.

Can you think of anything else needed to finish up your recruitment?

In More Detail: Preparing for the Interview

As taught in this module, an interview has 6 parts.

1: Lay the Groundwork for the Interview

2: Transition to the Interview

3: Gather Information on Child Eligibility

Factor 1 – Age of Child(ren)
Factor 2 – School Completion
Factor 3 – Move Across School District Boundaries
Factor 4 – Date of Move
Factor 5 – Reason for the Move
Factor 6 – Qualifying Work:

Agriculture or fishing work or

Temporary or seasonal employment

4: Transition to the Confirmation Process

5: Confirm Responses for Child(ren), Confirm Responses for Out-of-School Youth

6: Close the Interview

Let’s take a look at each step by following the Sample Interview Script.

Printable Version: Sample Interview Script

Once the tone has been set for the interview, the recruiter begins asking questions pertaining to the “6 Basic Eligibility Factors” (age, school completion, move across school district boundaries, date of move, reason for the move, qualifying work).

Once you’ve gathered all the information, it’s important to transition to the confirmation process. This gives the parent an additional opportunity to give you more useful information.

Tips for the Recruiter

1. Be sensitive:
To migrant needs and lifestyles. Be aware of the following:

The migrant families’ work schedule may be different from yours.
The family may be arriving from work tired.
Their work schedules may prevent them from visiting schools.
They might not be working on rainy days.
Bring information to them from the schools, the MEP and their child’s performance in school.
Use every opportunity to educate migrant parents about school and the importance of education.
The family might need other services such as clothing or food.

To Cultural differences. Be aware of the following:

Cultural customs,
Relationship between men and women, and
Appropriate dress for the culture.

2. Be Safe:
Be aware of potentially dangerous situations, including:

Presence of dogs and other animals;
Dark, dangerous neighborhoods;
Dangers of the elements, such as extreme heat and cold;
Female recruiter visiting a male at home alone; and
Male recruiter visiting a female at home alone.

Use these safety practices:

Use humor and show confidence to deflect sexual advances.
Use a team approach in visiting families.
Strategically place yourself between the door and anyone who arouses your suspicion.

3. Insensitivity or lack of caring is revealed by the following undesirable characteristics:

Not listening to the family,
Being in a hurry,
Making promises that cannot be kept, and
Dressing inappropriately.

4. Practice the following for a good interview:

Present yourself well.
Dress appropriately.
Be friendly.
Arrive on time and at a good time.

Determine eligibility:

Have written information to explain the program and cards to identify yourself.
Explain the program without the jargon.
Handle delicate situations (e.g., how to say no, using the term “migrant” in a way that will not offend).
Listen to what the family says.
Determine the family’s needs.
Complete the COE.
Be aware of safety.
Ask for referrals (location of other families).
Don’t make promises that cannot be kept.

* Note: It is important for the recruiter to make the migrant family or youth feel comfortable during the interview in order to obtain the information he/she needs. One way of doing this is to be sensitive to the migrant needs and lifestyle.

Review “Elements of a Good Interview” PowerPoint slide (4)

* Note: A recruiter should always be sensitive to cultural differences. The topic “Cultural Awareness and Communication” is covered in depth in Module 7 of the curriculum.

The role of the recruiter is to make an eligibility determination. It’s important not to let empathy for the family lead to making a questionable eligibility decision in order to help a needy family that doesn’t qualify for the MEP.

Types of Questions During the Interview

There are two basic types of questions: “open-ended” and “closed-ended.”

Open-ended questions cannot be answered with a simple word: a more significant amount of information needs to be given to answer the question.

Closed-ended questions can be answered with one or few words, such as “yes” or “no.”

Both open-ended and closed-ended questions can have positive and negative aspects.

Review “Types of Questions” PowerPoint slides (2-5)

Please note:

You can use open-ended questions to probe for more information and to confirm that information provided to you is correct.

Review “Types of Questions” PowerPoint slides 6-8

Leading questions are types of questions that should not be used, as they may generate incorrect information.

Review “Types of Questions” PowerPoint slides 9

Identifying leading questions:

Go through the list and indicate whether each question is a leading (L) or open-ended (O) question.

____ 1. You moved here to work in agriculture, right?

____ 2. Did you move to obtain any type of agricultural work?

____ 3. How did you know this type of work was available?

____ 4. What kind of work were you looking for?

____ 5. Why did you move here?

____ 6. You’ve moved recently, haven’t you? Say, within the past 3 years?

____ 7. How long has your family been living in [name of current home town]?

____ 8. You know we have a great summer program for children who have moved. I’ll bet your kids have moved in the last few years, haven’t they?

____ 9. Has anyone in your family moved recently?

____ 10. When did they move?

Answers: 1. L; 2. L; 3. O; 4. O; 5.O; 6. L; 7. O; 8. L; 9. O; 10. O

Common Challenges

Consider the following challenges, adding a personal example if you can.

Resistance:

Stress/Disappointment:

Distractions:

Assumptions and Judgments:

Issues to consider in each item listed above.

Resistance:

Assure the family you are not from the Immigration Office and immigration status is not a factor determining eligibility.

Stress and Disappointment:

Premature determinations can lead to stress and disappointment for the family.
Do not tell the family they are eligible during the visit.

Distractions:

If there are too many distractions, find another place or time.
Consider a screening interview; too many distractions might decrease the quality of the interview.

A screening interview is an abbreviated interview during which the recruiter only asks questions concerning the basic child eligibility factors. The answers to these questions will determine whether a more in-depth interview is warranted.

Assumptions and Judgements:

Recruiters also need to guard against making assumptions about the family or youth and to base their decisions on facts.

INTERVIEWING: Written Scenarios

Printable Version: Written Scenarios

Scenario 1

The migrant family is about to have dinner when the recruiter arrives. The mother is preparing dinner. The children are screaming and running around. The T.V. and radio are blaring. The father keeps pestering the mother to bring him a drink. When the recruiter rings the doorbell, no one hears the bell. The recruiter rings several times, and finally a child answers and announces that someone is at the door. The recruiter comes in and goes to talk to the mother who continues to cook. The recruiter forgets why she is there and talks about the latest soap
opera, recipes, etc. Meanwhile the children are still yelling. Finally, the recruiter remembers why she is there and asks the mother to sign the COE, thanks the family, and leaves.

1. Positive Elements:

2. Negative Elements:

Possible Answers

Positive Elements:

Recruiter took time to build rapport with the mother.

Negative Elements:

Recruiter visited family at an inappropriate time.
Recruiter did not explain the program.
Recruiter did not gather required information

Scenario 2

The recruiter arrives at the door of a migrant family, and the parent is home alone. The parent is worried about many things (i.e., her child is not adapting in school; at times they don’t have enough to eat; the spouse worked only a few days the week before; the children do not have enough clothes). The recruiter is in a hurry and does not want to hear about the parent’s problems. The recruiter continually looks at his/her watch and makes a comment about a previous commitment to be met after the interview. The recruiter repeatedly interrupts the parent. The recruiter finally gets the signature and leaves in a hurry while the parent is left frustrated.

1. Positive Elements:

2. Negative Elements:

Possible Answers

Positive Elements:

None

Negative Elements

Recruiter did not allow enough time for interview.
Recruiter lacked sensitivity.
Recruiter did not explain the program.
Recruiter didn’t try to build a relationship.
Recruiter didn’t gather information.
Recruiter ignored the opportunity to learn about the family’s needs that could have led to referrals for other services.

Scenario 3

A recruiter, very formally dressed and carrying a briefcase, knocks at the door of a migrant family. A parent looks out the window with suspicion and refuses to answer the door for a while. Eventually, the parent allows the recruiter in. The recruiter states the family’s name, but it is the wrong name. The recruiter does not introduce him-/herself and refuses a drink the parent offers. He/she wipes off the chair before sitting and cannot answer any questions (i.e., when asked where the bus picks up the child, the recruiter answers but is very vague). The recruiter continually asks leading and inappropriate questions (i.e., “You came here to pick apples didn’t you?” and “You’re a migrant, aren’t you?”). The recruiter gives the parent the COE to fill out and leaves.

1. Positive Elements:

2. Negative Elements:

Possible Answers

Positive Elements:

None

Negative Elements:

Recruiter both dressed and acted too formally.
Recruiter did not know family’s name.
Recruiter did not explain the program.
Recruiter was ill prepared to answer any questions.
Recruiter asked leading questions.
Recruiter used inappropriate terms (i.e., the term “migrant” may be objectionable to some).
Recruiter gave the parent the COE to fill out.

Scenario 4

The recruiter comes to the door, dressed appropriately and not too formally. The recruiter introduces him-/herself as being from the schools and asks if it is a convenient time to visit the family. The recruiter has some information about the child which he/she uses as an opening remark to the parent. The recruiter is friendly and pleasant, accepts a glass of water, and takes time to get to know the family. The MEP is fully explained with a notebook containing pictures. The recruiter makes no promises to the family that cannot be kept. The recruiter asks appropriate questions in order to fill out the COE. He/she also asks for referrals for other families.

1. Positive Elements:

2. Negative Elements:

Possible Answers

Positive Elements:

Recruiter dressed appropriately.
Recruiter asked if it was a convenient time to visit.
Recruiter brought information about the program and the child.
Recruiter was culturally sensitive and took time to get to know the family.
Recruiter explained the program fully.
Recruiter made no promises that cannot be kept.
Recruiter filled out COE correctly.
Recruiter asked for referrals for other migrant families.

Negative Elements:

None

View “Interviewing Video”

Please watch the following video closely and take notes. The purpose of this exercise is to critique the video and refine our interviewing techniques.

Interviewing Video Questions

1. What went well?

2. What did the recruiter do to develop a relationship?

3. Did the interviewer cover all of the six eligibility factors and sub-factors?

1. Age of Children
2. School Completion
3. Move Across School District Boundaries
4. Date of Move
5. Reason for the Move
6. Qualifying Work
• Agricultural or Fishing Work
• Temporary or Seasonal Employment

4. Did the interviewer ask any leading questions?

5. What else could the recruiter have done better?

Printable Version: Interviewing Video Questions

Here are some possible answers to the questions above.

What went well in the interview?

Answers should include that the recruiter:

Communicated in the migrant family member’s native language,
Was prepared for the interview,
Dressed appropriately,
Explained the MEP,
Covered the factors, and
Showed sensitivity.

What did the recruiter do to develop a relationship?

Answer is “nothing.”

Did the recruiter cover all of the eligibility factors (age of children, school completion, move across school district boundaries, date of move, reason for move, and qualifying work) and sub-factors (agricultural or fishing work, temporary or seasonal employment)?

Answer is “yes.”

Did the recruiter ask any leading questions?

Answer is “no.”

What could the recruiter have done better?

Answers should include:

Could have provided a better explanation for the terms “seasonal” and “temporary,” and
Could have brought a smaller folder with interview materials instead of the intimidating binder.

Section 4: Decision-Making

Goal

The recruiter will know how to make valid and reliable child eligibility determinations for the Migrant Education Program (MEP).

Objectives

After completing this section, the participant will be able to:

Identify and apply the basic principles of decision-making;
Use verifiable information/observations and reliable data to make decisions.
Recognize when information is inconclusive.
Apply the principles of decision making to MEP child eligibility determinations;
Make a child eligibility decision;
Resolve child eligibility questions when data, information or observations are inconclusive;
Recognize the warning signs for ineligibility and falsification of information;
Present the facts of an eligibility scenario to request a second opinion from the State or local I&R chain of command; and
Explain the importance of making reliable and accurate child eligibility decisions and the need for accuracy.

Materials:

“Decision-Making Model” PowerPoint
“Decision-Making Chain of Command” PowerPoint
“Decision-Making Scenarios” PowerPoint
Basic Migrant Child Eligibility Factors Handout V.1.0
MEP Definitions Poster-8 x 11 V. 1.0

Participants will be learning the principles of decision-making and applying them to make child eligibility decisions. Participants likely already do something similar to this in their personal lives.

Review the “Decision-Making Model”

Printable Version: Decision Making Model

Printable Version: Steps in Decision Making

“Red Flags” Activity

After gathering information—whether during an interview, reviewing records, or other research—you may come across some warning signs or “red flags.”

These red flags alert you to the need to do further investigation in an area.
This further investigation may be needed to ensure a correct eligibility determination or to determine whether an error was made by MEP staff.
For example, if the family has never performed agricultural or fishing work before, this would be a red flag to prompt you to investigate further.

Activity: Using a blank paper, take 2 minutes to list possible “red flags” that might come up as you gather facts that would alert you to the need to follow up in some areas.

Some of the responses should include (U.S. Department of Education 2007, page 76):

Contradictory information, e.g., school records don’t match interview information;
Move to an urban or non-traditional migrant area where migrant work is not generally found;
A household having some members in non-agricultural/non-fishing occupations;
A worker having a job for part of the year in a non-agricultural/non-fishing area;
A family having a lifestyle where migration doesn’t seem to be an important factor in the family’s life (e.g., no school interruptions and non-traditional migrant housing);
Workers having non-entry-level positions for non-qualifying work they do as an alternative to work that would be qualifying;
A family having had moves associated with vacations or other non-work reasons;
A family having arrived in a new location at a time that doesn’t align with agricultural or fishing work, such as late in the season after agricultural jobs are filled or too early in the season for jobs to be available; or
A family making moves of short duration.

Summarized points:

A red flag does not automatically mean that the child is not eligible for the MEP.
A red flag does mean that you need to ask additional questions or do additional research on the situation.

Making Eligibility Decisions in Difficult Cases

Reference: Basic Migrant Child Eligibility Factors Handout V.1.0

Points to be noted:

The Basic Child Eligibility Factors handout is a tool to help you check through all the criteria to make sure all the factors are met.
If the criteria for even only one factor are not met, the child is not eligible for the MEP.
Sometimes it is not clear whether all criteria have been met and additional research is needed.
Some cases may be beyond your knowledge or authority even after more research.
In these cases, you need to refer the question to your State’s eligibility chain of command.
The chain of command differs from State to State, so you should learn your State’s process.
We will now review the general process.

Review “Decision-Making Chain of Command” PowerPoint Slide (2):

Note that the MEP organizational structure and the identification and recruitment (ID&R) roles of MEP staff were covered in Module 2.

To review:

The Federal Office of Migrant Education administers the MEP nationally and provides guidance and support to State departments of education.
Each State has a MEP Director who oversees the administration of the program, including the ID&R system.
Most States have ID&R coordinators who provide leadership and guidance to recruiters.
The recruiter, working with other local operating agency (LOA) staff, focuses on finding and serving migrant children.

Review “Decision-Making Chain of Command” PowerPoint Slide (3):

Points to be noted:

If the recruiter is uncertain whether a child meets a certain eligibility criterion, he/she should do additional research on the question.
The recruiter should check the State ID&R materials, State policy letters, or the Federal draft Non-Regulatory Guidance (draft NRG).
If the question is still not resolved, the recruiter should talk to colleagues in the State to see if a similar situation was previously encountered and resolved.
If not, the recruiter should consult with his or her immediate supervisor.
In doing so, the recruiter should:

Clearly present all the facts,
Include information on each eligibility factor, and
Give an informed opinion as to the child’s eligibility and why.

Review “Decision-Making Chain of Command” PowerPoint Slide (4):

Points to be noted:

The recruiter’s supervisor will (U.S. Department of Education 2007, page 74):

Make sure the recruiter has gathered all information and understands the facts.
Ask for additional information if needed.
Check the State materials and the draft NRG.
Contact colleagues and/or other districts to see if a similar issue was previously resolved elsewhere and a precedent set.
If there is a clear answer, give it to the recruiter.
If there is no clear answer, refer the question to the next person in the chain of command, usually the State I&R coordinator.

After this, the issue is passed up through the chain of command, including the State I&R Coordinator and State Director. They ultimately obtain guidance directly from OME.

Points to be noted:

The State I&R Coordinator will (U.S. Department of Education 2007, page 74):

Do the same analysis as the supervisor.
If there is no clear answer and the determination will affect the eligibility of a significant number of children in the State, refer the issue to the State Director to forward to OME.

In his or her query to OME, the State Director should include (U.S. Department of Education 2007, page 75):

The question,
All relevant facts,
The approximate number of the children whose eligibility will be affected by the decision,
The State’s analysis of the question,
An explanation of why the State believes it has no clear answer, and
The ruling that the State believes is appropriate based on its analysis.

Review “Decision-Making Chain of Command” PowerPoint Slide (7):

Points to be noted:

After OME makes a determination and relays its decision to the State, the State should disseminate this response to all State ID&R staff at the same time.

Requesting a Second Opinion

One of the first steps a recruiter should take when an eligibility decision is unclear is to ask a more experienced colleague for a second opinion. Recruiters should know not only who to go to for a second opinion, but also what follow-up questions to ask a colleague who comes to them for advice.

What types of situations might an eligibility determination be unclear and a request for a second opinion needed?

Some possible responses are:

The family does not qualify for the MEP based on its most recent move, but did a previous, qualifying move occur during the past 36 months?
Is the “reason for move” criterion met even though the family was not seeking such work?
The family’s migration history includes moves back to the home country because it is cheaper to live there.

If you have already asked a more-experienced colleague, and he/she is also uncertain about the correct eligibility determination, the next step is to ask your supervisor.

What a recruiter must provide the supervisor in requesting a second opinion?

The answer is:

All the relevant facts,
All information concerning each eligibility factor, and
An informed opinion as to whether the child is eligible and why.

Requesting a Second Opinion Scenario:

A worker moved from Houston, Mississippi, to Brooklet, Georgia, with his wife and two children, ages 6 and 9, to harvest peanuts. He was especially excited to move to Brooklet because his older brother and his family live there as well. He knew that his children were looking forward to spending time with their cousins. Once the harvest is over, both families will travel together to Mexico and spend the holidays together. The worker began work the day
after the family arrived, about a month ago.

The recruiter working on this case needs to determine whether the children are eligible for the MEP. The recruiter’s gone through the eligibility factors and believes that the children are eligible. However, the recruiter is not sure if the move was made for economic necessity and wants to consult with his supervisor.

How would the recruiter present the three types of information (relevant facts, analysis of basic child eligibility factors, recommendation, and reason for this recommendation) that his supervisor needs in order to give the recruiter a second opinion?

Printable Version: Eligibility Factors Table – Blank

The analysis of the eligibility factors should be as follows:

Summarized points:

In this case, the supervisor would likely respond with a request for more information.
Before making an accurate decision, more information is needed about whether the move was made for economic necessity.
Since migrant families often have several reasons for moving, one could question whether the family is moving to be closer to others in their family.
The recruiter should consider asking more questions about the move, the family’s migration history, the type of work the family did in the past, etc.
Even if a child does not qualify for the MEP based on the family’s most recent move, previous moves, including those where the family did not move to/from the recruiter’s areas, may qualify a child if one of those moves met the eligibility criteria.

Falsification and Consequences

Important points to remember:

This decision-making process is part of the support available to every recruiter.
A recruiter can always ask peers and supervisors for help in making reliable and accurate eligibility decisions.
It is human to make mistakes, but it is the job of everyone in the MEP to find and correct mistakes as soon as possible.
This is why it is important to have a quality control system (quality control systems are covered in Module 9).
What is of concern is when a recruiter intentionally falsifies information on a Certificate of Eligibility (COE) for what he/she considers good reasons.

Why might a recruiter consider falsifying information? Please list a few ideas on your own.

Responses should include the following points:

The recruiter wants to help an especially needy child or family even though the child doesn’t qualify for the MEP.
The recruiter wants to gain status in the migrant community by having the personal power to decide who is eligible and who is not.
The recruiter equates identifying more “eligible” children with job security.
The recruiter is pressured to increase the number of “eligible” migrant children and/or falsify information in order to (U.S. Department of Education 2007, pages 77–78):

Increase funding,
Keep current staffing,
Not use district or other Federal funds to employ staff,
Provide services to non-migrant students, or
Respond to incentives such as being approved to attend conferences and other non-MEP meetings.

*Excerpt from pages 78 and 79 of the Draft Migrant Education Program Identification and Recruitment Manual (U.S. Department of Education2007).

Report fraud or misconduct. The recruiter should follow his or her State policies to report fraud or misconduct. If the recruiter feels pressured by a supervisor or colleague to enroll a child who doesn’t appear to be eligible for the MEP or to “increase the program’s numbers,” the recruiter
should:

Make it clear that the recruiter is not comfortable with what is being asked;

Write down what happened with as much detail as possible (if others witnessed what happened, have them write down what they observed as well); and

Report what happened to the appropriate person (if the supervisor is the person who is applying the pressure, the recruiter should report the problem to someone within the MEP at a level higher than the supervisor).

The recruiter should not do things that he or she believes are wrong, and should follow up on any concerns until they have been properly addressed. Furthermore, if the recruiter suspects that another recruiter is enrolling children in the MEP who are not eligible, the recruiter is obligated
to report that as well. It is everyone’s job to preserve the integrity of the MEP and to maintain public confidence in the program’s efforts to find and serve eligible migrant children. If the State MEP does not address the recruiter’s concern, the recruiter should report the problem to the Office of Migrant Education (OME). Contact information for the OME is available on The Department of Education’s (ED’s) Website at http://www.ed.gov/about/offices/list/oese/ome/aboutus.html#contact.

Anyone suspecting fraud, waste or abuse involving ED funds or programs should also call or write to the Office of the Inspector General’s (OIG’s) Hotline. The OIG keeps these complaints confidential; it will not release the recruiter’s name, address, or any other identifying information.
The OIG can be contacted using any of the following methods:

Call the OIG Hotline’s toll free number 1-800-MIS-USED. The Hotline’s operating hours are from 9:00 a.m. until 4:00 p.m. Eastern Time, Monday through Friday except holidays;

Send an e-mail message to oig.hotline@ed.gov;

Complete and submit an electronic complaint form, which is available on ED’s Website at: http://www.ed.gov/about/offices/list/oig/hotlineform.html; or

To ensure complete anonymity, download a hardcopy of the complaint form, complete it, and mail it to: Inspector General’s Hotline; Office of Inspector General; U.S. Department of Education; 400 Maryland Avenue, SW; Washington, DC 20202-1510.

Summarized points:

There is no excuse for falsifying information.
Falsifying information is a crime that is punishable by fines or imprisonment, and staff at all levels of the MEP can be affected by the consequences.
Such activity undermines the basic purpose of the MEP, i.e. to make sure the right children get the benefits to which they are entitled.

Review Decision Making Cases

Review “Decision-Making Scenarios” PowerPoint Slide (2):

Complete the Eligibility Factors Table:

Printable Version: Eligibility Factors Table – Blank

Answers (click link below)

Scenario 1 Eligibility Factors Table – Complete

Now consider what your answers would be to the 5 decision making steps in the Decision Making Model.

Printable Version: Steps in Decision Making

Responses to each Step

1. Define the decision to be made:

An eligibility determination needs to be made.

2. Gather information:

The move was from Burley, Idaho, to San Marcos, Texas.
In the past, the family has thinned and harvested sugar beets.
One of the reasons for the move was to be close to family.
The plan was to find whatever work is available, even field work.
The family heard about the MEP.
The family had school-aged children: 7 and 10.
The family wanted the recruiter to sign the children up for the MEP as soon as possible.

3. Evaluate the information:

A red flag is that one of the reasons for the move was to be close to family.
The family was eager for the children to receive MEP services, so that information provided by the family may not be completely accurate.
The family wanted the recruiter to sign the children up, which may make the recruiter feel pressured to deem the children eligible.

4. Consider options and implications:

Option 1:

The recruiter should do additional research by:

Asking the family for additional information, such as migration history, previous types of work, and whether the family has previously participated in the MEP. It would also be helpful to collect any student records or MEP documents the family may have.
Consulting other sources to verify the information provided by the family.

Pros for the option:

The family may not be eligible for the program on this move, but previous migration history may reveal a qualifying move.
The family may be able to recall or secure records from a school district where the children were previously enrolled.

Cons for the option:

The family may not be able to recall information about schools and have no records to prove their previous eligibility.

Option 2:

The recruiter should make an eligibility decision based on the information provided by the family.

Pro for the option:

An eligibility decision would be made quickly.

Cons for the option:

The data collected may not be accurate or complete.
The children may be found eligible when in fact they are not.
The children may be found ineligible when in fact they are eligible.
The recruiter is not adequately carrying out his/her responsibilities.

5. Select and implement the best option:

Option 1 is the best option.

Review “Decision-Making Scenarios” PowerPoint Slide (6)

Complete the Eligibility Factors Table:

Printable Version: Eligibility Factors Table – Blank

Answers (click link below)

Scenario 2 Eligibility Factors Table – Complete

Now consider what your answers would be to the 5 decision making steps in the Decision Making Model.

Printable Version: Steps in Decision Making

Responses to each Step

1. Define the decision to be made:

The correct eligibility decision needs to be made so that the family can receive the services for which it is eligible.

2. Gather information:

During October of last year, Joe Corey and his son, Ramon, age 17, moved from Fallon, Nevada, to Orange Cove, California, to pick oranges and lemons.
They moved within California to pick the citrus crop and eventually settle in Cutler, where they have found a place to live.
Once housing was found, Joe’s wife, Lucia, moved with their two other children from Nevada to Cutler to join Joe and Ramon.
Lucia told the recruiter that housing is important, especially during the winter months.

3. Evaluate the information:

A red flag is that a possible reason for the move is to find better housing.
A recruiter might disqualify the family based on Mrs. Corey’s statement on housing without gathering more information.

4. Consider options and implications:

Option 1:

The recruiter makes a determination based on incomplete information. This is not a valid option but could happen.

Pros for the option:

None.

Con for the option:

A determination is made using incomplete and possibly inaccurate information.

Option 2:

The recruiter conducts a follow-up interview, asking for more information from the family to include migration history and previous employment

Pro for the option:

The recruiter will likely receive more information from the family, enabling him/her to make an accurate eligibility determination.

Con for the option:

It will take more time for the recruiter to conduct a follow-up interview.

5. Select and implement the best option:

Option 2 is the best option.

Review “Decision-Making Scenarios” PowerPoint Slide (10)

Complete the Eligibility Factors Table:

Printable Version: Eligibility Factors Table – Blank

Answers (click link below)

Scenario 3 Eligibility Factors Table – Complete

Now consider what your answers would be to the 5 decision making steps in the Decision Making Model.

Printable Version: Steps in Decision Making

Responses to each Step

1. Define the decision to be made:

The correct eligibility decision needs to be made so that the OSY and migrant child can receive the services for which they are eligible.

2. Gather information:

It is fall in Newburgh, New York and apple harvest is taking place.
Three young men, ages 18, 19, & 20, a young woman age 19, and a child, age 2, have moved from Reynosa, Mexico, to Jonestown, Pennsylvania, and finally to Newburgh, New York, to harvest apples.
Their families have migrated annually to harvest apples but this year the young men, the young woman, and the child came without the rest of the family.
On a previous move, the MEP recruiter did not identify and recruit the family members.
On a most recent move, the MEP recruiter identified all five people and offered to interview them to determine whether they are eligible for educational and support services.

3. Evaluate the information:

A red flag would be that a recruiter had not identified the family on a previous move.

4. Consider options and implications:

Option 1:

The recruiter interviews the family members to determine whether they are eligible for the MEP or other services.

Pro for the option:

The recruiter is doing what needs to be done to make an eligibility determination for OSY.

Con for the option:

Although the case may be resolved, this option does nothing to address the oversight that took place the previous time the family moved.

Option 2:

The recruiter interviews the family members to determine whether they are eligible for the MEP or other services, but contacts his/her supervisor to alert the supervisor to the fact that this family was missed during a previous, apparently qualifying, move. The supervisor then determines the reason for this oversight and takes steps, such as additional training for recruiters, to avoid such an oversight in the future.

Pros for the option:

The recruiter is doing what needs to be done to make an eligibility determination for OSY.
The supervisor is alerted to the situation and can provide additional training for recruiters on identifying and recruiting OSY.

Con for the option:

A lack of staff resources, rather than training, may be the cause for this oversight. It is possible that the supervisor may not be in a position to resolve the situation.

5. Select and implement the best option:

Option 2 is the best option.

Section 5: Determining the Need for a Follow-up Interview

*NOTE: SECTION 5 IS UNDER CONSTRUCTION

Goal

The recruiter will know how to review information gathered during an interview and determine whether a follow-up interview is required.

Objectives

After completing this section, the participant will be able to:

Review the interview information and identify ambiguous, incomplete, or missing information, and

Determine if there is a need for a follow-up interview.

Materials:

“Interviewing” video

“Determining the Need for a Follow-up Interview Goal and Objectives” PowerPoint

Eligibility Factors handouts

Being successful in determining the need for a follow-up interview requires a thorough understanding of the eligibility criteria for the Migrant Education Program (MEP).

To determine whether a follow-up interview is needed, a recruiter must first examine the information gathered during an interview and other research.

To ensure objectivity, the recruiter must first be aware of any assumptions he or she may unconsciously be making that may affect an eligibility determination.

In addition to making unconscious assumptions, recruiters may also encounter difficulties during the interview that would keep them from obtaining the accurate and complete information they need.

Post workbook page 109

Responses to the Workbook page 109 should include:

Resistance from family members/youth:

Assure the family/youth you are not from the Office of Immigration.
Advise the family/youth that customs enforcement and immigration status are not factors in determining eligibility for the MEP.
Inform the family/youth that you are not a salesperson and that there is no cost to them for MEP services.

Stress and disappointment felt by family members/youth:

Do not make any promises you can’t keep.
Do not tell the family/youth they are eligible during the visit.

Distractions:

If there are too many distractions, find another place or time.
Consider a screening interview; too many distractions might decrease the quality of an interview.

False statements and assumptions:

Always consider just the facts as objectively as possible.
Never assume the family is eligible by their surroundings (housing, children not in school, rural setting near fields, etc.).

Note: that encountering some of these difficulties may require the recruiter to conduct a follow-up interview. we cannot always control situations but we can control our reactions to them.

Post workbook page 110

Once a recruiter looks at the information he or she has on a migrant family, what signs or signals would alert him/her that a follow-up interview is needed?

Responses should include the following:

Conflicting or incomplete information on the Certificate of Eligibility (COE): birth date, school district data, incomplete sections, children born after the move, incorrect dates, etc.;
Migrant database information differs from information on the COE or information provided by the family or youth;
Many corrections or mistakes on the COE;
Incomplete information on one of the criteria;
A belief that the parent or youth is not telling the truth;
Resistance during the interview that resulted in the recruiter’s not getting all the information needed; orA premature determination of eligibility based on inaccurate information.

Post the first interview on the “Interviewing” video

Post workbook page 111 (take notes as you watch the video)

As you are watching the video be alert to those signs or signals that indicate that a follow-up interview might bew necessary. You can also refer to the Eligibility Factors handout to see if all the eligibility factors are covered in the video.

Were all eligibility factors covered during the interview process?

The answer is no.

School completion was not addressed. The recruiter also could have done a better job asking about the move across school boundaries, although this factor was covered enough to determine that the children meet it.

Is there other information that should have been obtained during this interview?

Possible responses are:

Information about children’s current schooling and
Other services that might be needed (health services, childcare, etc.).

Should a follow-up interview be conducted? If so, what questions should be asked?

The answer is yes, and responses should include:

Are the children enrolled in school? If so, how are they doing and adjusting?
Do they need any social services?
Are there any other changes or information that the parent failed to mention?

At times a recruiter would like to see a family a second time to ask them further questions, and at other times the supervisor may see gaps that should be filled in. Your best insurance against having to conduct a second interview is proper completion of the COE.

There is a diffrence between a follow-up interview and a re-interview.

A follow-up interview is conducted to gather more information in order to make an eligibility determination;
A re-interview is done for quality control purposes after an eligibility determination has been made.