RECOVERY SCHOOL DISTRICT – NEW ORLEANS
TYPE 5 CHARTER SCHOOLS
INTENSIVE CORRECTIVE ACTION PLAN
ICAP: FAPE / DISCIPLINE
2012-13
Findings were issued in the areas of:
o §530.D.l.a. -FAPE: Students were suspended for more than 10 days without FAPE;
o §530.E.I-3-Manifestation Determinations were not conducted within 10 days of change of placement;
o §530.D.1.b. -Functional Behavioral Assessments (FBAs) and Behavioral Intervention Plans (BIPs) were not developed
and/or implemented to address targeted behavior and ensure access to and benefit from the general education
curriculum.
INTENSIVE CORRECTIVE ACTION PLAN – RSD TYPE 5 CHARTER SCHOOLS – NEW ORLEANS
GOAL #1: RSD must immediately correct the student specific findings documented in the referenced report
LEA/SCHOOL ACTIVITIES TO ACHIEVE
GOAL
DATE
ACTIVITY
BEGINS
PERSONNEL
RESPONSIBLE
FOR IMPLEMENTATION
PERSONNEL
RESPONSIBLE FOR
OVERSIGHT/
DATA DUE TO RSD (LEA/School
Responsibility)
DATA DUE TO LDOE
(RSD Responsibility)
VERIFICATION
1.1 LEA/School - Correct all student
specific citations from December
2011 follow-up site visit as listed in
monitoring report.
March 2012
School Leader
RSD Office of School
Performance (OSP)
Copy of revisions per each student
specific finding (e.g., revised IEP, FBA,
BIP, other)
May 30, 2012
1.2 Offer compensatory education to
identified students with OSS > 10 days
from 2011 follow up onsite visit.
March 2012
School Leader
RSD Office of School
Performance (OSP)
Copy of compensatory letter signed by
parent accepting or refusing services
October 30, 2012
Sign-in sheets with teacher/student
names, dates and services provided.
(First Quarterly
Report)
Copy of amendment to IEP with
compensatory education denoting
frequency and duration of
compensatory services.
RSD Type 5 Charters, New Orleans, Updated ICAP May 2012
Page 2
REGULATION REFERENCE: §530.D.l.a. -FAPE: Students were suspended for more than 10 days without FAPE
 RSD holds that this is a systemic finding at schools operated by New Orleans College Prep and New Beginnings, as well as the
9th Grade of Clark HS (operated by FirstLine). (Even though this citation was noted at these particular schools, all Type 5
Charter Schools need to continuously internally monitor student discipline data to ensure SWD are provided services after
the 10th day of removal. Also, for the follow-up visit, a random selection of schools will be chosen which may not include the
same schools that were selected during this monitoring so it is imperative these activities are followed by each Type 5
Charter School to ensure they are following district and state disciplinary guidelines).
DESCRIPTION/SUMMARY OF NON-COMPLIANCE: FAPE: Discipline Procedures – The students with disabilities did not continue to receive
educational services after the 10th day of OSS / (out of school suspension) so as to enable the SWD to participate in the general education
curriculum
GOAL #2. LEA will follow Policies and Procedures that ensure that students with disabilities are provided FAPE to enable participation in
the general education curriculum after the 10th day of OSS, including strategies to decrease the days of OSS (positive support).
BARRIERS TO GOAL #2: 1) Lack of knowledge special education procedures by school staff, administrators, teachers, etc.; 2) lack of
codified school practices related to support for students with challenging behavior , 3) lack of accountability for implementation
LEA/SCHOOL ACTIVITIES TO
ACHIEVE GOAL
DATE
ACTIVITY
BEGINS
PERSONNEL
RESPONSIBLE
FOR
IMPLEMENTATION
PERSONNEL
RESPONSIBLE
FOR
OVERSIGHT/
DATA DUE TO RSD (LEA/School
Responsibility)
DATA DUE TO
LDOE
(RSD
Responsibility)
VERIFICATION
2.1 LEA/School will continue to follow
already established compliant IDEA
Discipline Policies and Procedures
August
2012
School Leaders/CMO
RSD Office of School
Performance (OSP)
Monthly SIS report of OSS data
Quarterly Report
Oct 30, 2012
Dec. 15,2012
March 30, 2013
June 15, 2013
RSD Type 5 Charters, New Orleans, Updated ICAP May 2012
Page 3
1.
2.2 LEA/School review monthly
discipline data (ISS, OSS, expulsion) to
monitor students suspended/expelled
to confirm appropriate actions are
taken to ensure provision of FAPE.
Aug. 2012
School Leaders/CMO
RSD Office of School
Performance (OSP)
Monthly Spreadsheet documenting
actions taken for students w/ OSS, ISS,
expulsions
Quarterly Report
Oct. 30, 2012
Dec. 15, 2012
March 30, 2013
June 15, 2013
2.3 LEA/School - Students identified
with 4+ removals/cumulative days
(ISS/OSS) will be identified for specific
action, e.g., reconvene and identify
specific intervention, revisit FBA, BIP.
Aug. 2012
School Leaders/CMO
RSD Office of School
Performance (OSP)
Copy of records reviewed –documents
that have been addressed in this process
(e.g., amended IEP, revised FBA/BIP, ISS,
OSS, MDR).
Quarterly Report –
submit 5% of records
reviewed
Oct. 30,2012
Dec. 15, 2012
March 30, 2013
June 15, 2013
RSD Type 5 Charters, New Orleans, Updated ICAP May 2012
Page 4
REGULATION REFERENCE§530.E.I-3-Manifestation Determinations were not conducted within 10 days of change of placement
DESCRIPTION/SUMMARY OF NON-COMPLIANCE: FAPE: Discipline Procedures – students were removed > 10 days resulting in a
change in placement without the benefit of a Manifestation Determination Review (MDR)
RSD holds that this is a systemic finding at schools operated by New Orleans College Prep and New Beginnings, as well as the 9th
Grade of Clark HS (operated by FirstLine).
GOAL #3. LEA shall ensure that Manifestation Determination(s) is conducted when change of placement is a consideration.
BARRIERS TO GOAL #3: 1) Lack of knowledge special education procedures by school staff, administrators, teachers, etc.; 2) lack of codified
school practices related to implementation of special education discipline procedures; 3) lack of accountability for schools
ACTIVITIES TO ACHIEVE GOAL
DATE
ACTIVITY
BEGINS
PERSONNEL
RESPONSIBLE FOR
IMPLEMENTATION
PERSONNEL
RESPONSIBLE FOR
OVERSIGHT/
DATA DUE TO RSD
(LEA/School
Responsibility)
VERIFICATION
3.1 LEA/School will follow already
established compliant IDEA Discipline
Policies and Procedures
Aug. 2012
School Leaders
CMO Leader
RSD Office of School
Performance (OSP)
Monthly SIS data and
documentation of any
change in placement(s) and
action/interventions taken
DATA DUE TO
LDOE
(RSD
Responsibility)
Quarterly Report
Oct. 30.2012
Dec. 15, 2012
March. 30, 2013
June 15, 2013
3.2 Review ISS & OSS and ensure data
based decision making, FBA, BIP, progress
monitoring are in place for students and
MDR’s are conducted as appropriate
Aug. 2012
School Leaders
CMO Leader
RSD Office of School
Performance (OSP)
Copy of records reviewed –
documents that have been
addressed in this process
(e.g., amended IEP, revised
FBA/BIP, ISS, OSS, MDR).
Quarterly Report –
submit 5% of
records reviewed
Oct. 30, 2012
Dec. 15, 2012
March 30, 2013
June 15, 2013
RSD Type 5 Charters, New Orleans, Updated ICAP May 2012
Page 5
REGULATION REFERENCE: FAPE Discipline Procedures §530.D.1.b. -Functional Behavioral Assessments (FBAs) and Behavioral
Intervention Plans (BIPs) were not developed and/or implemented to address targeted behavior and ensure access to and
benefit from the general education curriculum.
DESCRIPTION/SUMMARY OF NON-COMPLIANCE: Students did not benefit from appropriate FBAs, BIPs, and progress monitoring to
adjust programming and ensure a Free and Appropriate Public Education (FAPE)
GOAL #4. LEA will ensure FAPE is provided to students who exhibit challenging behavior(s) (i.e., current FBA, BIP, and progress
monitoring).
BARRIERS TO GOAL #4: 1) Lack of knowledge special education procedures by school staff, administrators, teachers, etc.; 2) lack of
coordinated practice between special education and general education staff to implement plans
ACTIVITIES TO ACHIEVE
GOAL
4.1 LEA/School accountability for
student success: limited use of
OSS, ISS, recommendations for
expulsion, and increased academic
success
DATE
PERSONNEL
PERSONNEL RESPONSIBLE
ACTIVITY RESPONSIBLE FOR
FOR
BEGINS IMPLEMENTATION OVERSIGHT/VERIFICATION
Aug. 2012
School Leaders
CMO Leader
RSD Office of School Performance
(OSP)
Ensure
FBA,
BIP,
progress
monitoring are in place for
students w/ challenging behaviors
as indicated
4.2 LEA/School - Students
identified with 4+
removals/cumulative days
(ISS/OSS) will be identified for
specific action, e.g., reconvene and
identify specific intervention,
revisit FBA, BIP.
Aug. 2012
School Leaders
CMO Leader
RSD Office of School Performance
(OSP)
DATA DUE TO RSD
(LEA/School
Responsibility)
DATA DUE TO
LDOE
(RSD
Responsibility)
Monthly Spreadsheet
documenting actions
taken for students w/
OSS, ISS, expulsions
Quarterly report
Administrative summary
detailing BIP monitoring
findings and actions
taken for noncompliance.
March 30, 2013
Copy of records
reviewed –documents
that have been
addressed in this process
(e.g., amended IEP,
revised FBA/BIP, ISS,
OSS, MDR).
Quarterly report 5%
sample of record
reviewed
Oct. 30, 2012
Dec. 15, 2012
June 30, 2013
Oct. 30, 2012
Dec. 15, 2012
March. 30, 2013
June 30, 2013
RSD Type 5 Charters, New Orleans, Updated ICAP May 2012
Page 6
4.3 RSD Superintendent will send
letter at the beginning of the 201213 schools/LEAs regarding
compliance with IDEA Discipline
procedures and needed
professional development (e.g.,
training for school staff to
complete FBAs, BIPs, progress
monitoring, MDR, other topics as
appropriate).
4.4 TIERS will provide
professional development that will
be available to all Type 5 charter
schools. Individual charter schools
will provide professional
development in the areas where
they determine there is a need for
further education.
August 2012
RSD Superintendent
RSD Office of School Performance
(OSP)
Assurance signed by
School/CMO Board and
school leader
Oct. 30, 2012
August 2012
TIERS
RSD Office of School Performance
(OSP)
Copies of agenda and
sign-in sheets for all
professional
development
opportunities offered by
TIERS and schools
Quarterly report
School Leader
CMO Leader
RSD Type 5 Charters, New Orleans, Updated ICAP May 2012
Oct. 30, 2012
Dec. 15, 2012
March 30, 2013
June 30, 2013
Page 7