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ISD Administration of GSRP
Child Eligibility Files
Eligibility for GSRP requires verification of a child’s age, as well as documentation of prioritization factors (self-reported income on an application constitutes documentation). Documentation of eligibility must be on file for every child enrolled in GSRP. This documentation must be maintained for seven (7) years.
MiLEAP requires that ISD monitoring of subrecipients includes annual review of child files to verify child eligibility was accurately and properly determined. If a Head Start Waiver was granted, refer to the Head Start Program Performance Standards Waiver Shared Responsibility Framework. All child files are also subject to periodic MiLEAP review.
Security of Sensitive Information
Maintaining copies of child’s birth certificates or other child and family personal information must be considered with great care. Maintenance procedures for sensitive documents must include security measures to ensure the files and the data contained therein is protected. This includes redacting personally identifiable data on forms including social security numbers, date of birth (for all but the child enrolled), maiden names, etc. Files should be kept in a secure location under lock and key, only accessible to authorized program staff.
Applications and accompanying documents should only be discussed with those that have permission to access the information. This would include among programs to determine placement as well as any others the parent/guardian authorizes to have access.
Electronic Files
Files may be electronic with scanned or photo images of prioritization documentation but must include proper security protocols to ensure safety of the data and limit file access only to authorized program staff.
Educational Records vs. Priority Documentation Records
The educational record for each child - including home visit and family conference forms, observation data, developmental screener data, other child growth/progress documentation, and samples of child’s work, etc. - is distinctly different than prioritization documentation and should be maintained in a separate file. In cases of single, separated, or divorced families, both parents must be granted access to the child’s educational information (unless court documents specify otherwise), however, access to personal data provided to determine prioritization should be restricted to only the parent that provided that data.