Charter School or District: Belchertown Public School District

MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION

COORDINATED PROGRAM REVIEW

Charter School or District: Belchertown Public School District

Corrective Action Plan Forms

Program Area: Special Education

Prepared by: Patricia W. Susen

CAP Form will expand to as many lines as necessary. Before completing and emailing to pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans.

All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final

Report to the school or district.

Mandatory One-Year Compliance Date: April 20, 2011


CORRECTIVE ACTION PLAN

(To be completed by school district/charter school)

Criterion & Topic: SE 1 – Assessments are appropriately selected and interpreted for students referred for evaluation

Rating: Partially Implemented

Department CPR Finding: District documentation and a review of student records demonstrated that the district does not meet all of the required elements of this criterion. District documents showed that there is an assessment team that meets weekly to discuss appropriate assessments, however many of the reviewed student records included consent to evaluate for areas that were not appropriately selected to assess specific areas of educational need. In particular, the records included vision and hearing screenings on the consent to evaluate, which in many instances was not related to the suspected area of disability.

The student records did not reflect any testing in the native language even for those students identified as limited English proficient, which may not therefore have been administered in a language and form most likely to yield accurate results.

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Narrative Description of Corrective Action: 1.c: The district no longer includes the “vision and hearing screening” option on the “Consent to Evaluate” forms. The Assessment Team will develop a process/procedure for obtaining necessary information in the event that it is not included on the referral. The Assessment Team will train the individual building-based

Educational Support Teams on the collection/submission of information needed to determine appropriate assessments.

1.f: The district will contract with an ELL consultant for advice on available assessments for students identified as limited English proficient. The consultant will also provide training to the

Assessment Team on the selection of the appropriate assessments. The district will provide training for the in-district evaluators on the use of the assessments and will contract with outside evaluators as needed. The referral form will be revised to include the native language of the student. Information requested will include a copy of the Home Language Survey.

Title/Role of Person(s) Responsible for Expected Date of Completion for Each

Implementation: 1.c: Director, Assessment

Team, Building Administration

Corrective Action Activity: 1.c: The revised procedure will be completed by Sept. 28,

1.f: Director, Assessment Team, Educational

Support Team

2010. The copies of the referrals and consents will be completed by Jan. 12, 2011. The trainings will be completed by Jan. 12, 2011.

1.f: The consultant will be in place by Sept.

28, 2010. The referral form will be revised by Sept. 28, 2010. All trainings will be completed and assessments chosen by Jan,

12, 2011.

Evidence of Completion of the Corrective Action: 1.c: 5 randomly selected referrals and

“Consent to Evaluate” forms, training agendas, training dates, training sign-in sheets, outline of procedure developed

1.f: Copy of the revised referral form, copy of contract with consultant, training dates, sign-in sheets

Description of Internal Monitoring Procedures: 1.c: Director will attend at least one Assessment

Team meeting per month to observe assessment selection process and provide feedback as needed. The Assessment Team will do a statistical comparison by month of the number of times that additional information needs to be obtained.

1.f: Director will attend trainings, meet with consultant, and monitor by monthly attendance at

Assessment Team meetings.

CORRECTIVE ACTION PLAN APPROVAL SECTION

(To be completed by the Department of Elementary and Secondary Education)

Criterion: SE 1 – Assessments are appropriately selected and interpreted for students referred for evaluation

Status of Corrective Action:

Approved Partially Approved Disapproved

Basis for Partial Approval or Disapproval: NOT APPLICABLE

Department Order of Corrective Action: NOT APPLICABLE

Required Elements of Progress Report(s):

By September 30, 2010, submit a narrative description of the process adopted by the Assessment

Team, as described above for determining appropriate assessments for eligibility and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for ensuring that assessments are appropriately selected in compliance with all elements of this criterion.

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By September 30, 2010 submit evidence of training for appropriate staff regarding assessments for eligibility determination so that assessments are appropriately selected to assess specific areas of educational need. Include the dates of the training, the agenda and signed attendance sheets.

By February 19, 2011 conduct an administrative review of a sample of student records from each grade level (elementary, middle, and high) for the use of appropriate assessments for eligibility determination. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.

The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures.

Progress Report Due Date(s): September 30, 2010 and February 19, 2011




Criterion & Topic: SE 2 - Required and optional assessments


Department CPR Finding: Student records and interviews with staff indicated that educational assessments are not always completed, particularly at the elementary level.

Narrative Description of Corrective Action: 1.b: The district will develop a procedure to ensure that all educational assessments are completed by the appropriate building-level staff prior to the

Team meeting. The district will ensure that the procedure is followed consistently across all buildings, particularly at the elementary level.

Title/Role of Person(s) Responsible for

Implementation: 1.b: Director, Team Leaders,

Building Administrators

Expected Date of Completion for Each

Corrective Action Activity: 1.b: The entire process will be fully implemented by Sept.

28, 2010. Documentation will be provided by

Jan. 12, 2011.

Evidence of Completion of the Corrective Action: 1.b: Copy of the procedure, logs, results of the check of student records, notifications to building administrators

Description of Internal Monitoring Procedures: 1.b: Maintenance of log documenting receipt date of assessments, log of reminder phone calls/emails/memos, bi-weekly check of randomly selected student records, notification to building administrator of missing assessments



Criterion: SE 2 - Required and optional assessments






By September 30, 2010, submit a narrative description of the process adopted by the District, as

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described above, for assuring assessments for eligibility are completed as consented to and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for ensuring that assessments are completed in compliance with all elements of this criterion.

By September 30, 2010 submit evidence of training for appropriate staff regarding assessments for eligibility determination so that assessments are completed as consented to and in compliance with the requirements of this criterion. Include the dates of the training, the agenda and signed attendance sheets.

By February 19, 2011 conduct an administrative review of a sample of student records from each grade level (elementary, middle, and high) for the completion of appropriate assessments, as consented to, for eligibility determination. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 5 - Participation in general

State and district-wide assessment


Department CPR Finding: District documentation indicated that the district has procedures to assure compliance with the requirements of this criterion. The district administrators stated that they send appropriate staff to DESE provided training regarding MCAS Alternative and assures that Team chairpersons discuss MCAS accommodations at IEP Team meetings; however, interviews and student records for students age 18 and over do not reflect any MCAS information or documentation.

Specifically there was no evidence in the record of MCAS, MCAS Alternative or MCAS performance appeal.

Narrative Description of Corrective Action: Copies of the results of each student’s MCAS,

MCAS Alternative, or MCAS performance appeal will be kept in the student’s individual records in the Office of Special Education. The Office of Special Education will send yearly reminder notices to building administrators and out-of-district schools requesting copies of all of the above.


Implementation: Director, Building

Administrators


Corrective Action Activity: Results of 2009-

2010 will be in student records by Sept. 28,

2010.

Evidence of Completion of the Corrective Action: Copies of records for all students 18 years of age and older

Description of Internal Monitoring Procedures: Log documenting receipt will be kept in each student’s binder. End-of-the year master log will be used to cross reference receipt and any missing documentation will be requested.

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Criterion: SE 5 - Participation in general State and district-wide assessment


Approved Partially Approved


Disapproved



By September 30, 2010, submit a copy of the master log for all students age 18 and over indicating status of MCAS alternative or MCAS performance appeal.

By February 19, 2011, submit the results of an administrative review of student records for all special education students age 18 and over. Indicate the number of records reviewed and the number that had appropriate documentation of MCAS results or status (alternative or MCAS performance appeal).

Explain the root cause for any continued non-compliance and indicate any action taken if all documentation as required by this criterion was not in any student record.






Criterion & Topic: SE 7 - Transfer of parental rights at age of majority and student participation and consent at the age of majority


Department CPR Finding: District documentation included a description of the local procedure relative to the transfer of rights at the age of majority, which is not consistent with the requirement of this criterion to inform the student one year prior to reaching age 18. Interviews and student record review demonstrated that although notice is provided it is not always provided one year prior to the student reaching the age of majority.

Narrative Description of Corrective Action: 1. The district has developed a “Transfer of

Parental Rights” notification letter to send to each student in September of the year that he/she turns 17. A copy of the notification will be maintained in the student records.


Implementation: Director, Team Leaders Corrective Action Activity: Sept. 28, 2010

Evidence of Completion of the Corrective Action: Results of bi-weekly internal monitoring of randomly selected student records, copy of letter and number sent

Description of Internal Monitoring Procedures: Bi-weekly review of randomly selected student records

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Criterion: SE 7 - Transfer of parental rights at age of majority and student participation and consent at the age of majority




Disapproved



By September 30, 2010, submit a copy of the revised transfer of parental rights notification letter described above.

By February 19, 2011, submit the results of an administrative review of student records for those students age 17 and older specifically indicating the number of records reviewed, and the number that had evidence of proper notice of transfer of rights. Explain the root cause for any continued noncompliance and indicate any action taken where notice was not given one year prior to the student turning 18.






Criterion & Topic: SE 9 Timeline for determination Rating: Partially Implemented of eligibility and provision of documentation to parent

Department CPR Finding: District documents, student records, and staff interviews indicated that the district does not always meet the timeline for the determination of eligibility

Narrative Description of Corrective Action: The district has procedures and protocols designed to ensure the completion of all evaluations and eligibility determinations within state-mandated timelines. The district will continue internal monitoring and will conduct an investigation to determine and document the reason for any situation that results in exceeding the timelines.


Implementation: Director, District Indicator coordinator


Corrective Action Activity: Jan. 12, 2011

(using data from Sept and Oct 2010 data)

Evidence of Completion of the Corrective Action: Completed Indicator 11-style form

Description of Internal Monitoring Procedures: The district will conduct a yearly evaluation of initial and re-evaluation timelines based on the format used in Indicator 11 will be conducted.

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Criterion: SE 9 Timeline for determination of eligibility and provision of documentation to parent






By September 30, 2010, submit a narrative description of the process adopted by the District, as described above, for assuring compliance with timeline requirements for eligibility determination and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for monitoring timelines in compliance with all elements of this criterion.

By February 19, 2011 conduct an administrative review of a sample of student records from each grade level (elementary, middle, and high) for the timeliness of eligibility determination. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 10 - End of school year evaluations


Department CPR Finding: District documents indicated that the district complies with the requirements of this criterion; however not all student records included evidence of the provision of a proposed IEP no later than 14 days after the end of the school year, when applicable.

Narrative Description of Corrective Action: The district will continue to conduct all meetings within the required end-of-the-year timeline. The district has a procedure to ensure that all

IEPS go out within 3 -5 days of the Team meeting. The district has re-organized Central Office to ensure that appropriately trained staff will be available at the end of the year to complete this process.


Implementation: Director, Team Leaders,

Central Office staff

Evidence of Completion of the Corrective Action: Copies of all N1s that apply to the end-of-theyear evaluations/Team meetings.


Corrective Action Activity: Sept. 28, 2010

Description of Internal Monitoring Procedures: Review current log of consents received between

30 and 45 school working days and cross-reference with the N1s.

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Criterion: SE 10 - End of school year evaluations






By September 30, 2010, submit a narrative description of the process adopted by the District, as described above, for assuring end of school year evaluations are completed in compliance with the requirements of this criterion and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for continued and on-going monitoring.

By September 30, 2010 submit evidence of training for appropriate staff regarding end of school year evaluations so that the proposed IEP is provided to the parent no more than 14 days after the end of the school year. Include the dates of the training, the agenda and signed attendance sheets.

By February 19, 2011 conduct an administrative review of a sample of student records from each grade level (elementary, middle, and high) for the completion of end of school year evaluations in compliance with the requirements of this criterion. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 12 - Frequency of re-evaluation Rating: Partially Implemented

Department CPR Finding: District documentation demonstrated that there is a procedure in place to address the requirements of this criterion; however, student records indicated that not all reevaluations are completed in accordance with the requirements of this criterion, specifically not all re-evaluations are conducted every three years as required except when the parent and district agree that it is unnecessary

Narrative Description of Corrective Action: 1a: The district will ensure that the established procedures are followed by completing the internal monitoring on a more frequent basis. If consent to evaluate has not been received after two written attempts, the district will contact the parent by phone. If consent is not received after this attempt, the district will notify the BSEA and request assistance. The N1 form will be used to document an agreement between the parent and district that the reevaluation is unnecessary.

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Implementation: 1a: Director, Team Leaders,

Assessment Team


Corrective Action Activity: 1a: Sept.28, 2010,

Jan. 12, 2011

Evidence of Completion of the Corrective Action: 1a: Results of internal monitoring, copies of

N1s

Description of Internal Monitoring Procedures: 1a: The district will conduct bi-weekly checks of randomly selected records. In addition, in December, April, and August of each year, the district will cross-reference all re-evaluations due during that time period and ensure that the process has been initiated.



Criterion: SE 12 - Frequency of reevaluation






By September 30, 2010, submit a narrative description of the process adopted by the District, as described above, for assuring compliance with timeline requirements for re-evaluation and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for monitoring timelines in compliance with all elements of this criterion.

By February 19, 2011 conduct an administrative review of a sample of student records from each grade level (elementary, middle, and high) for the timeliness of re-evaluations. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 13 - Progress Reports and content


Department CPR Finding: District documentation included a policy to ensure progress reports are completed and sent as often as parents are informed of the progress of non-disabled students; however student records did not always include a copy of progress reports and those that were included did not always have a date to reference the progress period and did not always reflect information on progress toward a specific goal.

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Narrative Description of Corrective Action: 1: The district will ensure that the established procedures will be followed by assigning a person to log the receipt date, the date sent home, and the date filed on a master list of students. This person will also notify the director of any missing progress reports so that a letter to the responsible party’s immediate supervisor will follow.

The use of the web-based progress report attached to the student data tracking system will ensure that the appropriate dates are noted on all progress reports.

2: The district has begun a series of trainings that will extend through the end of school year

2010-2011 to address the appropriateness of individual goals, objectives, related progress reports, referral documents, and IEP development.


Implementation: 1. Director, Central Office staff, Building Administrators

2. Director,


Corrective Action Activity:

1: Sept. 28, 2010, Jan. 12, 2011

2: June 2011

Evidence of Completion of the Corrective Action: 1: Copy of June log sheet for Sept. 28, 2010 – copy of the Nov. log sheet for Jan. 12, 2011

2:Training agendas, sign-in sheets, 25 randomly selected progress reports which reflect the diversity of student needs and services

Description of Internal Monitoring Procedures: 1: Log sheet (see narrative)

2: Dec., April, and August monitoring reviews will include review of progress reports



Criterion: SE 13 - Progress Reports and content






By September 30, 2010, submit a description of the district mechanism to monitor progress report content and delivery to parents and to assure that a copy of progress is filed in the student record.

Include person(s) responsible for the oversight, for continued and on-going monitoring and a copy of the log described above and additional steps taken, if any, to address concerns identified in the log.

By September 30, 2010, submit a copy of the agenda and sign in sheets for the training of appropriate staff responsible for the completion of progress reports with information related to progress on each goal and on the delivery of progress reports to parents, as well as the filing of progress reports in the student record.

By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for the appropriate completion of progress reports. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.



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Criterion & Topic: SE 14 - Review and revision of

IEPs


Department CPR Finding: Documents included a copy of an internal procedure to comply with the requirements of this criterion; however, interviews and student records indicated that not all IEPs are reviewed on or before the anniversary date.

Narrative Description of Corrective Action: 1: The district will ensure that the established procedures will be followed on a consistent basis.


Implementation: 1: Director, Team Leaders,

Assessment Team


Corrective Action Activity: 1: Sept.28, 2010,

Jan. 12, 2011

Evidence of Completion of the Corrective Action: 1: Results of internal monitoring, copies of N1s

Description of Internal Monitoring Procedures: 1: The district will conduct bi-weekly checks of randomly selected records. In addition, in December, April, and August of each year, the district will cross-reference all annual reviews due during that time period and ensure that the process has been initiated.



Criterion: SE 14 - Review and revision of IEPs



Basis for Partial Approval or Disapproval: The district plan relies on previously established procedures that have not resulted in full compliance with the requirements of this criterion. The district must determine the root cause of the problem and develop a mechanism or modify its established procedures to achieve compliance and assure administrative oversight for continued compliance.

Department Order of Corrective Action: Determine the root cause of the problem and design and implement a mechanism to assure that the review and revision of IEPs are completed on or before the anniversary date. The Description of Internal Monitoring Procedures as described above is acceptable as proposed.


By September 30, 2010, submit a narrative description of the root cause of the problem and the mechanism designed by the district to assure that IEPs are reviewed and revised on or before the anniversary date. Include a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for continued and on-going monitoring.

By September 30, 2010, submit the agenda and sign-in sheets for the training of appropriate staff regarding the district mechanism to assure the IEPs are written and revised on or before the anniversary date. Also submit the results of the internal monitoring as described above and any additional steps taken to address areas of concern.

By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for the timely review and revision of IEPs. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of

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concern, if any.






Criterion & Topic: SE 15 - Outreach by the School

District (Child Find)


Department CPR Finding: The district documentation included a newspaper outreach and letters mailed to local early child care programs and private schools; however, there was no evidence of outreach made to clinical/health care organizations, professionals in the community, group homes, parent organizations, other agencies/organizations, or agencies serving migrant and/or homeless persons pursuant to McKinney-Vento

Narrative Description of Corrective Action: In addition to the outreach currently taking place, the district will conduct outreach to area physicians, parent organizations, and community groups etc. as required by law.


Implementation: Director


Corrective Action Activity: Spet. 28, 2010

Evidence of Completion of the Corrective Action: List of persons and organizations to whom we have sent outreach information.

Description of Internal Monitoring Procedures: Director’s calendar of annual timelines



Criterion: SE 15 - Outreach by the

School District (Child Find)






By September 30, 2010, submit a copy of the out reach notice sent and the list of persons and places including addresses to whom it was sent in compliance with the requirements of this criterion.

Progress Report Due Date(s): September 30, 2010

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Criterion & Topic: SE 18A - IEP development and content


Department CPR Finding: District documentation and the student record review indicated that the district does not meet all of the required elements of this criterion. Specifically, not all Present Level of Educational Performance A (PLEP A) and Present Level of Educational Performance B (PLEP B) pages are completed as appropriate or are in some instances left blank in IEPs where the student is identified as limited English proficient and for those students who are identified as having a social, emotional or behavioral disability. Additionally not all service delivery grids were completed appropriately; in particular some IEP service grids listed the frequency and duration of services as ongoing and were without further clarification as to what specifically was being provided to the student.

Narrative Description of Corrective Action: 2: The district has begun a series of trainings that will extend through the end of school year 2010-2011 to address the appropriateness of individual goals, objectives, related progress reports, referral documents, and IEP development.


Implementation: Director, Team Leaders,


Corrective Action Activity: June, 2011

Evidence of Completion of the Corrective Action: Agendas, sign-in sheets, training dates, 25 randomly selected IEPs

Description of Internal Monitoring Procedures: Bi-weekly check of randomly selected IEPs, Dec.,

April, and August monitoring reviews will include IEP review



Criterion: SE 18A - IEP development and content



Basis for Partial Approval or Disapproval: Although the district proposal includes training for staff regarding the requirements of this criterion, the proposal does not specify how the district will accomplish full compliance and it does not address the root cause of the problem.

Department Order of Corrective Action: The district must determine the root cause of the problem and must develop a procedure to assure that IEPs are completed in full compliance with all of the requirements of this criterion. Specifically, the procedure must address the completion of the Present

Levels of Educational Performance (PLEP A and PLEP B) and must further address appropriate completion of the service delivery grid. Finally, the internal monitoring as proposed above must include a tracking system to assure on-going compliance.


By September 30, 2010, submit a copy of the district procedure for assuring compliance with the requirements of this criterion, including the internal monitoring and tracking of IEPs to verify that each

IEP has completed PLEP A and PLEP B pages and that the service delivery grid specifies the frequency and duration of services.

By September 30, 2010, submit a copy of the agenda and sign-in sheets for the training of appropriate staff regarding the completion of the IEP in compliance with the requirements of this criterion.

Specifically, the completion of the PLEP A and PLEP B as well as the service delivery grid.

By February 19, 2011, submit the results of an administrative review of a sample of student records

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from each level (elementary, middle, high) for the appropriate completion of IEPs. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 18B - Determination of placement; provision of IEP to parent


Department CPR Finding: Student records and interviews indicated that student placement in some instances was determined prior to the Team meeting specifically at the middle school level where students with social, emotional, or behavioral disabilities are transitioning to high school.

Narrative Description of Corrective Action: The district will hold discussions regarding the development of a high-school level alternative program to meet the needs of students with behavioral and emotional disabilities. In addition, the middle school Teams will discuss the possible need for an outside placement for each of these students as well as appropriate services available at the high school.


Implementation: Director, Superintendent,

Middle School and High School Administrators,

School Committee



Evidence of Completion of the Corrective Action: Committee meeting notes/dates

Description of Internal Monitoring Procedures: Review of Team meeting notes



Criterion: SE 18B - Determination of placement; provision of IEP to parent



Basis for Partial Approval or Disapproval: The district proposal to hold discussions to investigate a possible new program at the high school or possible outside placement does not specify a corrective action measure that will lead to full compliance as to appropriate placement decisions made pursuant to the Team process.

Department Order of Corrective Action: The district must develop a plan to assure that placement decisions are not made prior to the Team meeting and that decisions made at the Team meeting are made on the basis of the individual student's need or identified disability.

Also, the district must train appropriate staff as to the requirements of this criterion, and the district mechanism to assure compliance. Finally, the district must establish an internal monitoring and oversight system to assure on-going compliance.


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By September 30, 2010 , submit a description of the district mechanism to assure that Team decisions as to placement are made in full compliance with all of the elements of this criterion. Specifically, identify how the mechanism will assure that the Team process occurs to make placement decisions and that placement decisions are based on the student's need or disability. Also, conduct training for appropriate staff as to the requirement of this criterion and to the district mechanism for compliance.

By September 30, 2010, submit the agenda and sign-in sheets for the training held for appropriate staff as to the requirements of this criterion and the district mechanism to assure compliance.

By September 30, 2010, establish and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for ensuring that the determination of placement is made in accordance with the Team process and is designed to meet the need of the individual student.

By February 19, 2011 , submit the results of an administrative review of a sample of student records from the middle and high school level for placement determinations made through the Team process.

Include the number of records reviewed from each level, the number found to be compliant, explain the root cause for any continued non-compliance and summarize additional steps taken by the district to correct areas of concern, if any.






Criterion & Topic: SE 20 - Least restrictive program selected


Department CPR Finding: Student record review demonstrated that the district did not always clearly state in the IEP why the removal is considered critical to the student’s program and the basis for the Team conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. Additionally, interviews with staff and a review of student records indicated that at the high school level in particular, students may be removed from a general education classroom when modifying the curriculum might have been sufficient.

Narrative Description of Corrective Action: see SE 18A


Implementation:



Evidence of Completion of the Corrective Action:

Description of Internal Monitoring Procedures:

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Criterion: SE 20 - Least restrictive program selected



Basis for Partial Approval or Disapproval: The district proposal to hold discussions to investigate a possible new program at the high school or possible outside placement does not specify a corrective action measure that will lead to full compliance as to non-participation justification or removal form the general education setting in the high school where modification of the curriculum may have been sufficient.

Department Order of Corrective Action: The district must not only discuss and plan programming options to meet the needs of its students as it stated in SE18B, but must establish a mechanism to assure continued compliance as to program placement in the least restrictive environment. In determining how to best meet the requirements of this criterion, the district must determine the root cause of the problem that has lead to non-compliance here and the district must provide staff training on the implementation of its mechanism as to non-participation and least restrictive environment to correct areas of concern. Finally, the district plan must provide for on-going monitoring and administrative oversight of implementation.


By September 30, 2010, submit a narrative description of the root cause of the problem and the district mechanism to assure compliance with the requirements to select the least restrictive environment and adequately justify in writing removal from the general education setting as appropriate. The district mechanism must include the name/role of the person(s) responsible for monitoring for continued compliance.

By September 30, 2010, submit the agenda and sign-in sheets indicating the name(s) and role(s) of attendees for the training regarding the requirements of this criterion and the district plan to assure compliance.

By February 19, 2011, submit a narrative description of the results of an administrative review of student records from each level (elementary, middle, high) for appropriate use of non-participation justification statements. Include the number of records from each level, the number found to be compliant, explain the root cause for any continued non-compliance and summarize any further action taken to address areas of concern.






Criterion & Topic: SE 21 - School day and school year requirements


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Department CPR Finding: Interviews with staff members and the review of student records demonstrated that the Team did not routinely consider the need for an educational program that is less than or more than the regular school day or school year, including extended day, or year, and/or residential services and the Team did not indicate on the IEP why the shorter or longer program may be necessary.

Narrative Description of Corrective Action: see 18A


Implementation:







Criterion: SE 21 - School day and school year requirements



Basis for Partial Approval or Disapproval: Although the district proposal includes training for staff regarding the requirements of this criterion, the proposal does not specify how the district will accomplish full compliance and it does not address the root cause of the problem.

Department Order of Corrective Action: The district must determine the root cause of the problem and must develop a procedure to assure that IEPs are completed in full compliance with all of the requirements of this criterion. Specifically, the procedure must address the completion of the IEP page indicating that a longer or shorter school day/year was considered at the Team meeting and if required, the reason that the longer/shorter school day/year is necessary for the individual student. Finally, the internal monitoring as proposed above must include a tracking system to assure on-going compliance.


By September 30, 2010, submit a copy of the district procedure for assuring compliance with the requirements of this criterion, including the internal monitoring and tracking of IEPs to verify that each

IEP has a completed extended school day/year or shortened school day/year page.

By September 30, 2010, submit a copy of the agenda and sign-in sheets for the training of appropriate staff regarding the completion of the IEP in compliance with the requirements of this criterion; specifically, the discussion at the Team meeting and the notation on the IEP of longer/shorter school day/year.

By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for the appropriate completion of IEPs. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.


Progress Report Due Date(s): September 30, 2010 and February 19, 2011.

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Criterion & Topic: SE 22 - IEP implementation and availability


Department CPR Finding: District documentation indicated that new students register at the individual school buildings and that if a student enrolls and already has an IEP in place from another district, the IEP records must be forwarded, received and reviewed by the special education office prior to implementation of any services. Because the IEP records must first be forwarded to the special education office for review before implementation, there is a gap in time which, based on staff interviews, leads to delays in providing IEP service. Additionally it was also noted that the district does not provide appropriate notice to the parents of newly enrolled students that there will be a delay in IEP services or if the district is proposing an alternate method or plan for services.

A review of student records indicated that not all students have an IEP in place at the beginning of each school year. For example, four student records had an IEP that expired in June 2009, there was no notice or documentation in the files addressing why an annual review was not being conducted on or before the IEP expiration date and the Team did not convene to draft a new IEP until several weeks into September 2009 and, as a result, the district did not have an IEP in place at the beginning of the school year.

Narrative Description of Corrective Action: The district will review current intake procedures and update to ensure that IEPs are implemented immediately or parent is notified using an N1 that there will be a delay.

The district will review all IEPs on or before the annual review date.


Implementation: Director, Team leaders


Corrective Action Activity: Sept. 28, 2010,

Jan. 12, 2011

Evidence of Completion of the Corrective Action: N1s and IEP distribution charts

Description of Internal Monitoring Procedures: Bi-weekly check of records for students who have entered the district during that time period.

The April records monitoring check will ensure that all IEPs either extend into the following school year or an annual review has been scheduled. This year’s check for this criterion will be conducted in June.



Criterion: SE 22 - IEP implementation and availability



Basis for Partial Approval or Disapproval: The narrative description of corrective action provides only a statement of assurance, but not sufficient detail to explain how the district will accomplish full compliance and it does not address the root cause of the problem that lead to noncompliance even where there was a local mechanism previously in place to address the requirements of this criterion.

Department Order of Corrective Action: The district must establish a procedure to assure that there is an IEP in place for each student at the beginning of each school year and further, that there is no delay in the implementation of services for each accepted IEP. In the event that a delay in the provision of services is unavoidable, the procedure must account for notice to be sent to the parent.

The procedure must establish how all requirements of this criterion will be accomplished by the

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district, how staff will be trained, and must include the person(s) responsible for implementation and oversight for continued compliance.


By September 30, 2010, submit a narrative description of the root cause of the problem and a description of the district mechanism that will assure that IEPs are implemented and available in full compliance with the requirements of this criterion. The mechanism must detail how the district will meet the standard and must identify the person(s) responsible for oversight and on-going monitoring for compliance.

By September 30, 2010, conduct a training for appropriate staff regarding the requirements of this criterion and the method of implementation of the district mechanism to assure compliance. Submit a copy of the agenda and sign-in sheets for the training.

By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for the implementation of services and availability of IEPs in compliance with the requirements of this criterion. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued noncompliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 25 - Parental consent Rating: Partially Implemented

Department CPR Finding: District documentation indicated that there are clear procedures in place to ensure that the district conducts outreach to the parent in order to obtain written parental consent, however the review of student records and interviews with staff demonstrated that the district is not utilizing those procedures and there is no evidence of a variety of efforts to obtain consent as required by this criterion in the student records. Student records did not reflect other means to include parents by phone, email, certified mail, home visits or any other identified efforts enumerated in this criterion.

Narrative Description of Corrective Action: The district will ensure that our procedure is followed by requiring contacts to be logged in student binders. Copies of emails, certified mail receipts, or notation of how parent was encouraged to participate will be placed in binders.


Implementation: Director, Team leaders Corrective Action Activity: Sept. 28, 2010,

Jan. 12, 2011

Evidence of Completion of the Corrective Action: Copies of logs and attempt documents

Description of Internal Monitoring Procedures: Bi-weekly checks of randomly selected records

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Criterion: SE 25 - Parental consent Status of Corrective Action:


Basis for Partial Approval or Disapproval: The narrative description of corrective action provides only a statement of assurance, but not sufficient detail to explain how the district will accomplish full compliance and it does not address the root cause of the problem that lead to noncompliance even where there was a local mechanism previously in place to address the requirements of this criterion.

Department Order of Corrective Action: The district must establish a procedure to assure that outreach to parents is conducted in order to obtain written parental consent. The district mechanism must include a variety of efforts to obtain parental consent and those efforts should be documented in the student record. The district must train staff on the requirements of this criterion and on the district procedures to accomplish compliance, and must include the person(s) responsible for implementation and oversight for continued compliance.


By September 30, 2010, submit a narrative description of the root cause of the problem and a description of the district mechanism that will assure parental consent or document the district's use of a variety of methods to obtain consent in full compliance with the requirements of this criterion. The mechanism must detail how the district will meet the standard and must identify the person(s) responsible for oversight and on-going monitoring for compliance.


By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for obtaining parental consent in compliance with the requirements of this criterion. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 25A - Sending of copy of notice to Special Education Appeals


Department CPR Finding: Student records and interviews indicated that the district does not always send notice to the Bureau of Special Education Appeals within five calendar days of receiving a notice that a parent is requesting a hearing or has rejected an IEP, proposed placement, or finding of no eligibility for special education.

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Narrative Description of Corrective Action: The district will ensure that its procedures are followed consistently.


Implementation: Director, Team leaders Corrective Action Activity: Sept. 28, 2010,

Jan. 12, 2011

Evidence of Completion of the Corrective Action: copy of letters sent

Description of Internal Monitoring Procedures: The director will be given a copy of all notices to the BSEA along with a copy of any rejected/partially rejected IEPs or requests for heaerings.



Criterion: SE 25A - Sending of copy of notice to Special Education Appeals



Basis for Partial Approval or Disapproval: The narrative description of corrective action provides only a statement of assurance, but not sufficient detail to explain how the district will accomplish full compliance with the requirements of this criterion. Also, it does not address the root cause of the problem that lead to noncompliance even where there was a local mechanism previously in place to address the requirements of this criterion.

Department Order of Corrective Action: The district must establish a procedure to assure that notice is sent the Bureau of Special Education Appeals within five calendar days of receiving a notice that a parent is requesting a hearing or has rejected an IEP, proposed placement, or finding of no eligibility for special education. The district must train staff on the requirements of this criterion and on the district procedures to accomplish compliance, and must include the person(s) responsible for implementation and oversight for continued compliance.


By September 30, 2010, submit a narrative description of the root cause of the problem and a description of the district mechanism that will assure parental consent or document the district's use of a variety of methods to obtain consent in full compliance with the requirements of this criterion. The mechanism must detail how the district will meet the standard and must identify the person(s) responsible for oversight and on-going monitoring for compliance.


By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for obtaining parental consent in compliance with the requirements of this criterion. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.



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Criterion & Topic: SE 25B - Resolution of disputes Rating: Partially Implemented

Department CPR Finding: See SE 25A

Narrative Description of Corrective Action: see 25 A


Implementation:







Criterion: SE 25B - Resolution of disputes



Basis for Partial Approval or Disapproval: See 25A

Department Order of Corrective Action: See 25A

Required Elements of Progress Report(s): See 25A





Criterion & Topic: SE 29 - Communications are in

English and primary language of home


Department CPR Finding: Documents indicated that the district has procedures in place to meet the requirements of this criterion; however, student records did not reflect that the district follows its own procedures. Specifically, there was no evidence in any record of communications in languages other than English. (At least 4 records of children who are identified as limited English proficient and special needs were reviewed and the administrative data sheets did not always provide information transferred from the Home Language Survey form identifying the primary language of the home as district procedure outlines.) In one record there was a statement that a Team meeting was convened and interrupted/rescheduled because the parent did not speak English and could not participate without the assistance of an interpreter. The district does not have a mechanism to provide notices orally or in some other mode of communication that is not written language.

Narrative Description of Corrective Action:


Implementation:





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Criterion: SE 29 - Communications are in English and primary language of home



Basis for Partial Approval or Disapproval: The district did not provide a description of corrective action and did not provide a description of internal monitoring to assure continued compliance.

Department Order of Corrective Action: The district must establish a mechanism to consistently provide communication in English and the primary language of the home if that language is other than

English. Also, the district must establish a mechanism to provide oral communication in a language understandable to the home and must document in writing that (a) notice was made in an alternate manner, (b) the content of the notice and (c) the steps the district took to ensure that the parent understood the content of the notice.


By September 30, 2010, submit a copy of the mechanism adopted by the district to consistently provide communication in English and the primary language of the home if that language is other than

English. Include a description of how the district will provide oral communication in a language understandable to the home and how the district will document in writing that (a) notice was made in an alternate manner, (b) the content of the notice and (c) the steps the district took to ensure that the parent understood the content of the notice. Include a description of the internal oversight and tracking system, including person(s) responsible for the oversight.

By September 30, 2010, submit evidence of training for special education staff on the requirement to provide communications in a language other than English and the district mechanism adopted to assure compliance with the requirements of this criterion. Include the dates of the training, the agenda, training materials used, and the signed attendance sheets of staff attendance that include staff role and building.

By February 19, 2011 , submit a narrative description of the results of an administrative review of special education student records selected from all schools to ensure that IEPs and accompanying notices, as well as other special education documentation, are provided in English and the primary language of the home, if requested by the parent. Report on the number of records reviewed in which parents require translated materials, the number of records in which IEPs, notices, and other special education documents were translated, , explain the root cause for any continued non-compliance and report on corrective action taken by the district to remedy any issues identified. If oral interpretation was provided submit a copy of the written documentation of the notice as required by this criterion and described above.



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Criterion & Topic: SE 32 - Parent advisory council for special education


Department CPR Finding: A review of documentation submitted by the district and interviews with staff and PAC members indicated that although the district has a PAC and meets with the PAC regularly, there is no mechanism to demonstrate that the PAC meets regularly with school officials to participate in the planning, development, and evaluation of the district's special education programs.

Narrative Description of Corrective Action: The district, in conjunction with PAC, will continue to send surveys to parents of students with special needs in order to get their input on district programs, services, and Team meetings. The results of the surveys will be shared at PAC meetings. PAC will be invited to School Committee meetings that focus on issues directly related to Special Education.


Implementation: Director, PAC officers



Evidence of Completion of the Corrective Action: Surveys and tabulated results, meeting dates and notes

Description of Internal Monitoring Procedures: Tabulation of results of surveys (director’s calendar of evants)



Criterion: SE 32 - Parent advisory council for special education






By September 30, 2010, submit a copy of the survey that will be sent to PAC members to solicit input in assisting the district in the planning, development, and evaluation of the district's special education programs. Also, if available, submit a proposed date and agenda for the School Committee meeting in

January when the PAC will be scheduled to appear.

By February 19, 2011 , submit a narrative description of the results of the PAC survey. Include the number of surveys that were sent, the number returned, and the tabulation of results with comments, if any, made by the PAC.

By February 19, 2011 , submit the agenda and meeting minutes for the School Committee meeting where the PAC was invited to speak and the agenda identified issues related directly to special education and PAC concerns or suggestions.


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Criterion & Topic: SE 34 - Continuum of alternative services and placements


Department CPR Finding: Documents, student records and interviews indicated that there is a gap in the continuum of services for students with social, emotional, and behavioral disabilities at the high school level. Specifically, the district has programs from grades K-8 to address children with social, emotional or behavioral disabilities ranging from substantially separate to supported inclusion, but offers no program at the high school level for that population. Also for the students who are ages 18 –

21 the district does not always comply with all elements of the IEP, including vocational education.

Narrative Description of Corrective Action: see 18B


Implementation:







Criterion: SE 34 - Continuum of alternative services and placements



Basis for Partial Approval or Disapproval: The district proposal under SE 18B to hold discussions to investigate a possible new program at the high school or possible outside placement does not specify a corrective action measure that will lead to full compliance as to continuum of alternative services and placements.

Department Order of Corrective Action: The district must develop a plan to assure that there is a continuum of services for students with social, emotional, and behavioral disabilities at the high school level and to assure that it complies with all elements of the IEP, including vocational education for students who are 18+ at the high school.

Also, the district must train appropriate staff as to the requirements of this criterion, and the district mechanism to assure compliance. Finally, the district must establish an internal monitoring and oversight system to assure on-going compliance.


By September 30, 2010 , submit a description of the district mechanism to assure that that there is a continuum of services for students with social, emotional, and behavioral disabilities at the high school level and to assure that it complies with all elements of the IEP, including vocational education for students who are 18+ at the high school.

By September 30, 2010, submit the agenda and sign-in sheets for the training held for appropriate staff as to the requirements of this criterion and the district mechanism to assure compliance.

By September 30, 2010, establish and submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight, for ensuring that the continuum of services and programs for students with disabilities in the district.

By February 19, 2011 , submit the results of an administrative review of a sample of student records from the high school level for services and programs to meet the educational and vocational needs of

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all. Specifically select from those records of students who have been identified with social or emotional disabilities and from those students who are age 18 or over as to vocational opportunities. Include the number of records reviewed for each category, the number found to be compliant, explain the root cause for any continued non-compliance and summarize additional steps taken by the district to correct areas of concern, if any.






Criterion & Topic: SE 36 - IEP implementation, accountability and financial responsibility


Department CPR Finding: Documents, interviews and student records indicated that the district does not always oversee in an ongoing manner the full implementation of each in-district and each out-ofdistrict IEP it proposes which has been consented to by a child’s parents. In particular, there is no evidence of monitoring forms for out-of-district placed students in the student records and for those students at the high school level who participate in school to work opportunities, there is no evidence of district oversight for any off campus activities participated in as part of the student's consented to

IEP.

Narrative Description of Corrective Action: District has developed a monitoring form for out-ofdistrict programs and one for off-campus activities that will be completed annually and placed in student binders.





Evidence of Completion of the Corrective Action: copies of completed forms

Description of Internal Monitoring Procedures: Dec. record review for students in out-of-district placements and those participating in off-campus activities



Criterion: SE 36 - IEP implementation, accountability and financial


Approved Partially Approved Disapproved responsibility

Basis for Partial Approval or Disapproval: Although the district plan includes a mechanism for monitoring out-of-district and school-to-work IEPs, it is not fully developed. The proposed plan does not detail the content of the form sufficiently to allow the Department to approve its use alone as complying with the requirement to oversee in an on-going manner the full implementation of each indistrict and out-of-district IEP proposed by the district. Also, the proposal is to use the form annually, which of itself is not sufficient to meet the minimum standard of this criterion which requires on-going supervision of IEP implementation. The plan also does not identify the person(s) responsible for oversight, and does not indicate training as to the requirements of this criterion or the use of the proposed form will occur for such person(s).

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Department Order of Corrective Action: The district must specify the proposed content of the form it will use to satisfy the requirement of this criterion that the district oversee in an on-going manner each in-district and out-of-district IEP it proposes. Identify who will complete the form, by their role in the district, what information will be recorded as evidence of on-going district oversight of the IEP, and provide training as to the requirements of this criterion and further training on the district plan to assure compliance.


By September 30, 2010, submit a copy of the form to be used by the district and specify who will be responsible for oversight and how and when that will be accomplished in full compliance with the requirements of this criterion.

By September 30, 2010, submit the agenda and sign-in sheets for the training of appropriate staff regarding the requirements of this criterion and the district mechanism to achieve compliance.

By February 19, 2011, submit the results of an administrative review of a sample of student records for those students in out-of-district placements and those who participate in school-to-work or other community based programs. Identify the number of records reviewed, the program or placement of the student, the number that had evidence of on-going supervision of IEP implementation and the district means of verifying that. Also, indicate the number found to be non-compliant, explain the root cause for any continued non-compliance and summarize additional steps taken by the district to remedy concerns. Finally, include the name and role of the person conducting the review.






Criterion & Topic: SE 37 - Procedures for approved and unapproved out-of-district placements


Department CPR Finding: Documents indicated that although the district has a contract in place for students in approved programs, there is no evidence of Department approval through authorization of pricing for those students placed in unapproved programs. Additionally, documentation and interviews demonstrated that the district maintains a master log of comments on school visits to approved and unapproved programs; however, there was no evidence in the student records reflecting individual student program oversight.

Narrative Description of Corrective Action: see SE 36 and: District has created a timeline for request of contracts, monitoring plans, and appropriate paperwork for authorization of unapproved placements in order to ensure that the district has all necessary documentation in order to file in time to meet regulations.


Implementation: Director, Central Office staff



Evidence of Completion of the Corrective Action: Approved paperwork from the DESE

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Description of Internal Monitoring Procedures: Director’s activity calendar, record review



Criterion: SE 37 - Procedures for approved and unapproved out-of-district placements



Basis for Partial Approval or Disapproval: See SE 36. In addition, the district proposal of corrective action for this criterion does not address all the required elements of this standard, or the mechanism to meet the required timelines for district action, or the district plan to monitor for on-going compliance.

Finally, the evidence of completion of corrective action must rest with the district and its proper and timely completion and submission of required forms to the Department for use of unapproved out-ofdistrict programs.

Department Order of Corrective Action:

See SE 36. In addition, the district must establish procedures consistent with the requirements of this criterion and must submit: a list of all public and private day and residential programs (approved and unapproved by ESE) contracted by the district; sample contract with out-of-district programs (approved and unapproved/public and private); notifications and information sent to ESE as required under this criterion, including 28M3 form "Notice of intent to seek approval for individual student program", completed pricing forms, a signed written contract, and a monitoring plan; evidence of actual monitoring activities; evidence of host state approval of all out-of-district placements if not otherwise approved by the Department. Finally, the district must train staff on the requirements of this criterion and the district procedures to achieve compliance.


By September 30, 2010, submit all items identified above in the Department order of Corrective

Action and specify the person by name and role responsible for oversight.

By September 30, 2010, submit the agenda and sign-in sheets for the training of appropriate staff regarding the requirements of this criterion and the district mechanism to achieve compliance.

By February 19, 2011, submit the results of an administrative review of a sample of student records for those students in out-of-district. Identify the number of records reviewed, the program or placement of the student (approved or unapproved), the number that had all required documents including contracts, Department approval, and evidence of on-going monitoring of programs and services. Also, include the number found to be non-compliant, explain the root cause for any continued non-compliance and summarize additional steps taken by the district to remedy concerns.

Identify by name and role the person conducting the review.



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Criterion & Topic: SE 41 - Age span requirements Rating: Partially Implemented

Department CPR Finding: Documentation submitted by the district and interviews with staff members indicated that they had an age span exceeding 48 months for students in the only substantially separate program at the high school. The district also included in its documentation an assurance that they would apply for a waiver with the Department, but it had not done so at the time of this review.

Narrative Description of Corrective Action: Although there was an age-span exceeding 48 months at the time of review, a student left that program, eliminating the need to apply for the waiver. The district will process the waiver request when notified by teachers and/or Team

Leaders. Special education teachers will be asked to submit student groupings containing birthdates.





Jan. 12, 2011

Evidence of Completion of the Corrective Action: Class rosters containing birthdates

Description of Internal Monitoring Procedures: Review submitted information



Criterion: SE 41 - Age span requirements






By September 30, 2010, submit a copy of the special education groupings for all groups that are comprised solely of student's with disabilities. Identify the class by content, teacher name(s), and room number and time it meets. Include the initials of students, gender and disability of student and the birthdates for each in chronological order.

By September 30, 2010, submit a copy of the written request for approval of a wider age range for any grouping that exceeds 48 months difference in age from the oldest to the youngest student.

By February 19, 2011, submit the results of an administrative review of the special education groupings for all groups that are comprised solely of student's with disabilities. Include the number of groups that are comprised solely of students with disabilities, and the number where the age span is less than 48 months. If any group is over 48 months difference in age between the oldest and youngest child, submit the details for that group (initials of students, name of teacher(s), number of paraprofessionals, type of class, hour of class, birthdates in chronological order for each student assigned to the group) and a copy of the written request for approval of a wider range.


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Criterion & Topic: SE 43 - Behavioral interventions Rating: Partially Implemented

Department CPR Finding: Interviews and student records indicated that the district does not meet all of the required elements of this criterion. Student records did not always include evidence of functional behavioral assessments or positive behavioral interventions even where the IEP and related documents indicated that the student’s behavior impedes learning.

Narrative Description of Corrective Action: Positive behavior intervention plans will be attached to the IEPs. FBAs will be placed in the assessment section of the student’s record.


Implementation: Director, Team leader



Jan. 12, 2011

Evidence of Completion of the Corrective Action: copies of plans and report of the results of monitoring

Description of Internal Monitoring Procedures: bi-weekly record review



Criterion: SE 43 - Behavioral interventions



Basis for Partial Approval or Disapproval: The district's narrative description of corrective action does not provide sufficient detail as to the mechanism to reach full compliance. Specifically, the district has not identified local procedures that include activities for determining the root cause of the problem, a plan or workgroup to revise current procedures, dissemination of the revised procedures that address all required elements of this criterion, staff training on effective implementation, and internal oversight or monitoring to assure continued compliance.

Department Order of Corrective Action: The district must identify the root cause of the problem and specify an action plan that will address all the required elements of this criterion by establishing a local procedure to assure that student records include evidence of functional behavioral assessments or positive behavioral interventions where the IEP indicates that the student’s behavior impedes learning.

Also, the district must provide training to staff as to the requirements of this criterion and the effective implementation of the local procedures. Finally, the district must specify the administrative oversight to assure on-going compliance.


By September 30, 2010, submit a narrative description of the root cause of the problem and a detailed mechanism to be implemented locally that will assure compliance. The mechanism must establish the roles and responsibilities of staff as to effective implementation and oversight. How will the district assure that functional behavioral assessments are completed if and when required? How will the district assure that positive behavioral interventions are implemented for those students whose behavior impedes learning? Who will be responsible for the initial identification, implementation, and monitoring of FBAs and BIPs and how will FBAs and BIPs be documented in the student record?

Finally, include a description of how continued administrative oversight will occur within the district

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and who will be responsible for monitoring for on-going compliance.

By September 30, 2010, submit the agenda and sign-in sheets for the training regarding the requirements of this criterion and the district procedures, as identified above, to assure compliance.

By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for conducting functional behavioral assessments and implementing positive behavioral intervention plans and for documenting assessment results and intervention plans in the student record in compliance with the requirements of this criterion. Indicate the number of records reviewed from each level, the number found to be in compliance, explain the root cause for any continued non-compliance and summarize steps taken to address further areas of concern, if any.






Criterion & Topic: SE 44 - Procedure for recording suspensions


Department CPR Finding: The district submitted a series of procedures from each building that reflect inconsistent levels of compliance with the requirements of this criterion. Some building level administrators, particularly at the elementary level, have complete procedures in full compliance while others do not and there is no district-wide procedure in place.

Narrative Description of Corrective Action: The district will create a uniform procedure for all building administrators to follow which specifies when to notify the Office of Special Education, how to notify the office, and what documentation to include.



Administrators, Team Leaders



Evidence of Completion of the Corrective Action: Sample notification form all levels

Description of Internal Monitoring Procedures: Bi-weekly record review



Criterion: SE 44 - Procedure for recording suspensions






By September 30, 2010, submit a copy of the district procedures, described above, that specify how

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building administration will coordinate with the Special Education Office to assure consistent implementation of district-wide recording of suspensions in compliance with the requirements of this criterion.

By September 30, 2010, submit the agenda and sign-in sheets for the training of appropriate staff regarding the requirements of this criterion and the district procedure to assure compliance.

By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for compliance with the required elements of this criterion for the recording of suspensions of students with disabilities. Include the number of records reviewed, by level, and indicate the number found to be compliant, explain the root cause for any continued noncompliance and identify steps taken, if any, to address areas of concern. Also include the name and role of the person responsible for conducting the review.






Criterion & Topic: SE 45 - Procedures for suspension up to 10 days and after 10 days: General requirements


Department CPR Finding: Documents indicated that although the district has some procedures in place regarding suspension up to ten days and after ten days, not all building administration follow the stated process and the procedures are not consistent throughout the district.

Student records and stated district procedures do not include evidence of additional procedural safeguards for students with disabilities prior to any suspension beyond 10 consecutive days or more than 10 cumulative days (if there is a pattern of suspension) in any school year.

Narrative Description of Corrective Action: see SE 44, CR 10A


Implementation:







Criterion: SE 45 - Procedures for suspension up to 10 days and after 10


Approved Partially Approved Disapproved days: General requirements

Basis for Partial Approval or Disapproval: Although the proposed corrective action stated in CR

10A and SE 44 address some of the required elements of this criterion, specific procedures must be adopted and implemented regarding suspensions up to 10 days and after 10 days as specified in this

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criterion.

Department Order of Corrective Action: Expand the stated proposal of corrective action under CR

10A and SE 44 to specifically include procedures regarding suspension up to ten days and after ten days. Also, include training for appropriate staff regarding effective implementation of the district procedures to assure compliance with the requirements of this criterion.


By September 30, 2010, submit a copy of the district procedures, described above and expanded from

SE 44 and CR 10A, that specify district procedures for suspension up to 10 days and after 10 days in compliance with the requirements of this criterion.


By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for compliance with the required elements of this criterion for suspension up to 10 days and after 10 days. Include the number of records reviewed, by level, and indicate the number found to be compliant, explain the root cause for any continued non-compliance and indicate steps taken, if any, to address areas of concern. Also include the name and role of the person responsible for conducting the review.






Criterion & Topic: SE 46 - Procedures for suspension of students with disabilities when suspensions exceed

10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days;

Rating: Partially Implemented responsibilities of the Team; responsibilities of the district

Department CPR Finding: Documentation, interviews and a review of student records indicated that the district does not always comply with all requirements of this criterion. Specifically, there is no evidence in the student records that manifestation determination meetings were held prior to a suspension of longer than 10 consecutive days or when a series of suspensions shorter than 10 consecutive days but constituting a pattern occurred or when a suspension constituted a change in placement of a student with disabilities

Narrative Description of Corrective Action: The district will provide training for building administrators and Team leaders on the responsibilities of the district related to this criterion.

Also, see SE44, CR 10A

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Implementation: Director



Jan. 12, 2011

Evidence of Completion of the Corrective Action: Training agendas, dates, sign-in sheets, completed forms

Description of Internal Monitoring Procedures: Bi-weekly record reviews



Criterion: SE 46 - Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days…




10A and SE 44 address some of the required elements of this criterion, specific procedures must be adopted and implemented regarding suspension of students with disabilities when suspensions exceed

10 consecutive school days.


10A and SE 44 to specifically include procedures regarding suspension of students with disabilities when suspensions exceed 10 consecutive school days. Also, include training for appropriate staff regarding effective implementation of the district procedures to assure compliance with the requirements of this criterion.



SE 44 and CR 10A, that specify district procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days in compliance with the requirements of this criterion.


By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for compliance with the required elements of this criterion for suspension of students with disabilities when suspensions exceed 10 consecutive school days.

Include the number of records reviewed, by level, and indicate the number found to be compliant, explain the root cause for any continued non-compliance and indicate steps taken, if any, to address areas of concern. Also include the name and role of the person responsible for conducting the review.



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Criterion & Topic: SE 47 - Procedural requirements applied to students not yet determined to be eligible for special education


Department CPR Finding: Interviews and a review of district documentation demonstrated that the district does not always meet the requirements of this criterion. Specifically, several interviewees, including building administration, were unaware of the procedural requirements applied to students not yet determined to be eligible for special education detailed in this criterion.

Narrative Description of Corrective Action: see SE 44, CR 10A


Implementation:







Criterion: SE 47 - Procedural requirements applied to students not yet determined to be eligible for special education




10A and SE 44 address some of the required elements of this criterion, specific procedures must be adopted and implemented regarding procedural requirements applied to students not yet determined to be eligible for special education.


10A and SE 44 to specifically include procedures regarding procedural requirements applied to students not yet determined to be eligible for special education. Also, include training for appropriate staff regarding effective implementation of the district procedures to assure compliance with the requirements of this criterion.



SE 44 and CR 10A, that specify district procedures to address the procedural requirements applied to students not yet determined to be eligible for special education in compliance with the requirements of this criterion.


By February 19, 2011, submit the results of an administrative review of a sample of student records from each level (elementary, middle, high) for compliance with the required elements of this criterion for procedural requirements applied to students not yet determined to be eligible for special education.

Include the number of records reviewed, by level, and indicate the number found to be compliant, explain the root cause for any continued non-compliance and summarize steps taken, if any, to address areas of concern. Also include the name and role of the person responsible for conducting the review.

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Criterion & Topic: SE 53 - Use of paraprofessionals Rating: Partially Implemented

Department CPR Finding: A review of district documentation and staff interviews indicated that at times paraprofessional staff members are designing instruction for students with disabilities.

Interviews also demonstrated that the Supported Inclusion paraprofessionals are not always supervised by an appropriately certified or licensed professional who is proximate and readily available.

Narrative Description of Corrective Action: The district has assigned a specific appropriately certified and/or licensed professional who is proximate and readily available to supervise each supported inclusion paraprofessional. The assigned supervisor will also be responsible for designing the instruction for the students with disabilities.





Administrators Jan. 12, 2011

Evidence of Completion of the Corrective Action: Rosters of paras and their supervisor, copies of meeting notes from supervisory meetings, copies of lesson plans from assigned supervisors.

Description of Internal Monitoring Procedures: Monthly review of lesson plans and meeting notes



Criterion: SE 53 - Use of paraprofessionals



Basis for Partial Approval or Disapproval: Although the district plan addresses appropriate supervision of paraprofessionals, it does not specify training for paraprofessionals as to their role, responsibilities, and conditions of supervision consistent with the requirements of this criterion.

Department Order of Corrective Action: In addition to the above district proposed corrective action, the district must provide training for paraprofessionals as to their role, responsibilities, and conditions of supervision consistent with the requirements of this criterion.


By September 30, 2010, submit a copy of the agenda and sign-in sheets for the training of paraprofessionals regarding the requirements of this criterion.

By September 30, 2010, submit a description of the current use of paraprofessional staff, including the roster of paraprofessionals, and the name of each paraprofessional's supervisor. Also, submit copies of certificates, licenses, current waivers, or other relevant credentials of all supervisors of paraprofessionals.

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By February 19, 2011, submit a narrative description of an administrative review of district use of paraprofessionals include level of compliance found, explain the root cause for any continued noncompliance and identify changes in placement or use of paraprofessionals, if any, since the first progress report.





Criterion & Topic: SE 55 - Special education facilities and classrooms


Department CPR Finding: An observation of the middle school building facilities and interviews with staff demonstrated that the space provided for resource room students at the middle school for both seventh and eighth grade (rooms 111 and 212) is not comparable to that offered to other students in the district. Specifically, a single classroom space is divided by movable blackboards and two separate teachers with two separate groups of special needs students utilize that space at the same time to teach distinct subject matter. The space is not conducive to specialized instruction where noise and activities of one group may by proximity alone disrupt the learning and attention of the other group

Narrative Description of Corrective Action: This issue was remedied immediately. For the future, the district has created a “Principal’s Assurance Document”. This document indicates that all space for students with special education needs are conducive to specialized instruction.



Administrators



Evidence of Completion of the Corrective Action: Assurance documents

Description of Internal Monitoring Procedures: Walk-through



Criterion: SE 55 - Special education facilities and classrooms






By September 30, 2010, submit copy of the principal's assurance document described above and a narrative description of a review of each principal's assurance. Include any recommendations made by the building administration related to the physical re-organization of the special education facilities and classrooms.

By September 30, 2010, submit a copy of the revised floor plan for the middle school that identifies the space provided for special education classrooms, related services, special education academic support space, and any other areas specifically used for students identified with special needs.

By February 19, 2011, the Department will schedule an on-site visit to verify compliance with the elements of this criterion.

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Program Area: Civil Rights









Rating: Partially Implemented Criterion & Topic: CR 3 - Access to a full range of education programs

Department CPR Finding: See ELE 5 and ELE 11.

Narrative Description of Corrective Action: see responses to ELE 5 and ELE 11


Implementation:







Criterion: CR 3 - Access to a full range of education programs






By September 30, 2010, submit a copy of the ESL curriculum as outlined in ELE 5 that aligns with the

ELPBO standards. Also, submit a copy of teacher category training for all teachers of content area to limited English proficient students. Identify the name, grade level, and content area certification for each teacher and each category training completed. Submit copies of student schedules for limited

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English proficient students that demonstrate that students are enrolled in classes with SEI trained content teachers and have direct English language development instruction for appropriate amounts of time based on proficiency level as outlined by OELAAA.

By February 19, 2011, submit a narrative description of a review of a sample of limited English proficient student records from each grade level (elementary, middle, high) for compliance with the access requirements of this criterion. Indicate the number of records reviewed, the number from each grade level, the number found in compliance; explain the root cause for any continued non-compliance and summarize any steps taken to address areas of concern.






Criterion & Topic: CR 7 - Information to be translated into languages other than English


Department CPR Finding: A review of documentation demonstrated that the district has access to translation services and has made copies of some student handbooks into languages other than English in the past (Spanish and Mandarin Chinese for one elementary school); however, current handbooks for the 2009-2010 school year have not been translated into the major languages of the district at any level. Also, interviews and district documentation demonstrated that there is no process or system of oral interpretation to assist parents/guardians with limited English skills, including those who speak low-incidence languages. See SE 29 and ELE 10.

Narrative Description of Corrective Action: 1:The district is in the process of a total revision of building-based student handbooks. Handbook revisions are scheduled to be completed by midsummer, 2010. Copies of all of the building-based handbooks will be forwarded to the University of Massachusetts Translation Center in Amherst for translation into the currently identified major languages of the district and will be available for the start of the school year. Also, the district will access the services of the Translation Center to translate the forms and notices that are provided to parents/guardians at the beginning of every school year so that they will be available at the beginning of the school year. The district will continue to use the Translation

Center at the University of Massachusetts to provide interpreters for IEP meetings and to translate legal documents.

2: The district will continue to use the Translation Center at the University of Massachusetts to provide oral interpretation as needed and will add a statement to all documents (in the major languages of the district) that notifies parents/guardians of that option. (see attached)


Implementation: 1 & 2:Superintendent,

Director, Building Administrators


Corrective Action Activity: 1 & 2: Sept. 28,

2010

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Evidence of Completion of the Corrective Action: 1: Copies of Handbooks in all designated languages, copies of building-based forms in each language

2: Copies of communication with statement regarding assistance in oral translation

Description of Internal Monitoring Procedures: 1: Log of receipt of documents from building administration, bills from the Translation Center

2: check of letterheads and other formats for home communication, log of requests for oral tranaslation



Criterion: CR 7 - Information to be translated into languages other than



English

Basis for Partial Approval or Disapproval: The district has not included plans to train staff on its process to identify parents who may need translated materials and to follow through to distribute materials, such as handbooks, to limited English proficient parents, or its process to identify and provide oral interpretation to assist parents/guardians with limited English skills, including those parents who speak low-incidence languages.

Department Order of Corrective Action: Develop a mechanism to identify and track those parents who require assistance (both written and oral) in a language other than English to assure continued compliance with the requirements of this criterion. The mechanism must: 1. identify the language requested for translation (The district may use the Home Language Survey as its primary source for determining when communication with the home in a language other than English is required.);

2. outline the protocol staff will follow to consistently communicate with the home and provide written translation of all important materials distributed by the district (How will all staff become aware of which important documents must be translated and for whom must it be translated? How will staff access such translated material and distribute it appropriately?); 3. account for in-district communication between schools and departments (Special Education and general education) to share parent requests for translated materials; 4. provide for a system of oral interpretation for low incidence languages.

In developing a mechanism for compliance, please note under ELE 7, ELE 10, and SE 29 the district plan must include a mechanism for the translation of report cards and progress reports on English language development and also progress reports on IEP goals, and translation of required notices related to English language learners and Special Education programs and services.


By September 30, 2010, submit a narrative description of the mechanism the district has developed to assure compliance with all elements of this criterion.

By September 30, 2010, submit a copy of the important material being distributed to students in languages other than English. Also submit sign-in sheets and agenda for training of staff on the local process for identifying the need for translated materials or oral interpretation and on distributing or providing oral interpretation assistance of translated materials.

By February 19, 2011, conduct an administrative review of enrollment forms and student records for evidence of requests for translation and for translated materials or use of interpreters at Team meetings for those students with disabilities whose parents requested communication in languages other than

English. Identify the number of records reviewed, level (elementary, middle, high) of each record, the number of requests for translation or interpretation assistance, and the number of records that included translated materials in compliance with this criterion, explain the root cause for any continued non-

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compliance and summarize any steps taken to address areas of concern.






Criterion & Topic: CR 9 - Hiring and employment Rating: Partially Implemented practices of prospective employers of students

Department CPR Finding: District documentation included a statement that the district requires employers recruiting at the school to sign a statement of assurance that the employer complies with applicable federal and state laws prohibiting discrimination in hiring or employment practices; however, there was no evidence in the district’s documentation submission or through interviews with staff at the high school that the form is distributed to and completed by prospective employers who are recruiting within the district.

Narrative Description of Corrective Action: The district has a form to be completed by the employers of students in the “School-to-Career” program. That form will be revised so that it can also be used for the employers of students in the “Transitions” program.


Implementation: Director, High School

Principal, Team leader, School-to-Career

Coordinator


Corrective Action Activity: Sept.28, 2010,

Jan.12, 2011

Evidence of Completion of the Corrective Action: copies of forms for all employed students

Description of Internal Monitoring Procedures: Monthly internal review



Criterion: CR 9 - Hiring and employment practices of prospective employers of students






By September 30, 2010, submit a copy of the revised form to be signed by prospective employers of students that meets the requirements of this criterion.

By February 19, 2011, submit the results of an administrative review of a sample of student records from the secondary level for those students participating in any school-to-work program to verify signed statements of non-discrimination by employers. Identify the number of records reviewed, the number found in compliance with the requirements of this criterion, explain the root cause for any continued non-compliance and summarize any steps taken to address areas of concern.

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Criterion & Topic: CR 10A - Student handbooks and codes of conduct


Department CPR Finding: Documentation and interviews indicated that the district does not meet all the required elements of this criterion. Specifically, the code of conduct does not include: language for the disciplining of students with 504 Accommodation Plans; reference to M.G.L. c. 76, s.5; the school’s procedure for accepting, investigating and resolving complaints alleging discrimination; or the disciplinary measures that the school may impose if it determines that discrimination has occurred.

Also, there is no indication that the district translates the code of conduct if and when requested by a parent or student whose primary language is not English.

Narrative Description of Corrective Action: The district is currently undergoing a complete revision of all policies and building-based handbooks. Also, see CR7


Implementation: Superintendent, School

Committee, Director, Building Administrators


Jan. 12, 2011

Evidence of Completion of the Corrective Action: Copies of revised policies and handbooks

Description of Internal Monitoring Procedures: School Committee Review dates have been scheduled



Criterion: CR 10A - Student handbooks and codes of conduct






By September 30, 2010, submit a copy of the revised handbook as distributed at the beginning of the

2010 – 2011 school year for each school/grade level that includes the required language consistent with all elements of this criterion.


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Criterion & Topic: CR 11A - Designation of coordinator(s); grievance procedures


Department CPR Finding: Documentation and interviews indicated that although the district has designated a coordinator for compliance with its responsibilities under Title IX, Section 504, and Title

II, it has not published procedures for students and for employees providing for prompt and equitable resolution of complaints alleging discrimination based on sex or disability.

Narrative Description of Corrective Action: see CR 10A


Implementation:







Criterion: CR 11A - Designation of coordinator(s); grievance procedures






By September 30, 2010, submit a copy of the revised handbook as distributed at the beginning of the

2010 – 2011 school year for each school/grade level that includes the required language consistent with all elements of this criterion.





Criterion & Topic: CR 13 - Availability of information and academic counseling on general

Rating: Partially Implemented curricular and occupational/vocational opportunities

Department CPR Finding: Documentation and interviews indicated that the district does not provide information and academic counseling to students from linguistic minorities on the full range of general curricular and any occupational/vocational opportunities available to them.

Narrative Description of Corrective Action: The district has revised its form regarding this area.


Implementation: Director, ELL Dept. Chair,

Guidance Departments, Building Administrators



Jan 12., 2011

Evidence of Completion of the Corrective Action: copies of completed forms

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Description of Internal Monitoring Procedures: Internal review of randomly selected records in

Dec., April, August



Criterion: CR 13 - Availability of information and academic counseling on general curricular and occupational/vocational opportunities




Disapproved



By September 30, 2010, submit a copy of the revised form distributed to students regarding the availability of information and academic counseling in languages other than English for limited

English proficient students.

By February 19, 2011 , submit the results of the administrative review of student records noted in the district corrective action plan for evidence of the availability of information and counseling in languages other than English. Identify the number of records reviewed, the level (elementary, middle, high) the number found in compliance with the requirements of this criterion, explain the root cause for any continued non-compliance and summarize any additional steps taken to address areas of concern.






Criterion & Topic: CR 14 - Counseling and counseling materials free from bias and stereotypes


Department CPR Finding: A review of documentation and staff interviews indicated that the district does not have a procedure to examine testing materials for bias and counteract any found bias when administering tests and interpreting test results. Also, the district did not provide evidence of efforts to communicate effectively with limited-English-proficient students and facilitate their access to all programs and services offered by the district. Finally, the district did not provide evidence that limited-English-proficient students have the opportunity to receive guidance and counseling in a language they understand.

Narrative Description of Corrective Action: see CR 10A and CR7


Implementation:




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Criterion: CR 14 - Counseling and counseling materials free from bias and stereotypes



Basis for Partial Approval or Disapproval: Although the district proposed corrective action for CR

10A and CR 7 addresses the requirement to make important materials and counseling available in languages other than English, the elements of this criterion require that the district establish a mechanism to review counseling materials for bias and stereotypes and to counteract any bias found.

Department Order of Corrective Action: The district must establish a mechanism to examine testing materials for bias and counteract any found bias when administering tests and interpreting test results.

Also, the mechanism must enable the district to communicate effectively with limited-Englishproficient students and facilitate their access to all programs and services offered by the district.

Finally, the mechanism must assure that limited-English-proficient students have the opportunity to receive guidance and counseling in a language they understand.

The district must provide training to appropriate staff as to the requirements of this criterion and the district plan to address the requirements.


By September 30, 2010, submit a narrative description of the district mechanism to examine testing materials for bias and counteract any found bias when administering tests and interpreting test results.

By September 30, 2010, submit a narrative description of the district plan to assure that all counselors are able to communicate effectively with limited English proficient students or to provide limited

English proficient students with the opportunity to receive native language counseling.

By February 19, 2011 , submit a copy of the training agenda and sign-in sheets which identify the attendees by name and role for the training held to inform staff of the requirements of this criterion and the district's implementation practices.

By February 19, 2011, submit a narrative description of the results of the review of counseling materials. Identify the persons conducting the review by title/role in the district and specify the materials that were reviewed and the level of compliance found. If non-compliance was found, explain the root cause and submit a narrative description of actions taken to address concerns and include any future action planned.





Criterion & Topic: CR 16 - Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion


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Department CPR Finding: Interviews with staff, student record review and district documentation demonstrated that the district does not comply with the requirements of this criterion. The district provided a sample notice letter, however there was no indication of a policy or process in place to assure that it was sent within ten days from a student's fifteenth consecutive unexcused absence. Also, there was no evidence that the notice was available in languages other than English and the letter did not include information that at the request of the parent the district may consent to an extension of time for the meeting of not more than fourteen days. Finally, interviews with high school staff and the review of student records indicated that the district does not send annual written notice by first class mail to the last known address of each such student who attended a high school in the district within the past two years.

Narrative Description of Corrective Action: see CR 10A, CR7


Implementation:







Criterion: CR 16 - Notice to students

16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion



Basis for Partial Approval or Disapproval: Although the district proposed corrective action for CR

10A and CR 7 addresses the requirement to make important materials and counseling available in languages other than English, it does not address the elements of this criterion that require the district to provide appropriate and timely notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion.

Department Order of Corrective Action: The district must revise the notice sent to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion to meet the requirements of this criterion. Also, the district must establish a mechanism to assure the notice is sent within ten days from a student's fifteenth consecutive unexcused absence.

Finally the district plan must include a tracking system to monitor the appropriate and timely sending of notice in compliance with the requirements of this criterion.

Once the notice has been revised and the mechanism for distribution and oversight has been established, the district must train appropriate staff on its procedure to assure continued compliance.


By September 30, 2010, submit a copy of the revised notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion.

By September 30, 2010, submit a copy of the protocol established by the district to assure compliance with the requirements of this criterion. Also submit a copy of the agenda and sign-in sheets identifying the attendees by title/role for the training provided to appropriate staff as to the requirements of this criterion and the district's implementation practices.

By February 19, 2011, submit a narrative description of the results of an administrative review of student records from the high school level for those students who are over 16 and have had 15 consecutive absences from school. Identify the number of students over 16 who have had 15 consecutive absences, the number of notices sent within ten days of the fifteenth absence, explain the root cause for any continued non-compliance and summarize any additional steps taken by the district

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to address concerns.






Rating: Partially Implemented Criterion & Topic: CR 23 - Comparability of facilities

Department CPR Finding: See SE 55.



Implementation:







Criterion: CR 23 - Comparability of facilities






By September 30, 2010, submit a copy of the Principal’s Assurance Document, described in SE 55 of the district space/facilities survey and include any recommendations made by the building administration related to the physical re-organization of the special education programs and services as well as ELL programs and services to provide equitable facilities throughout the district.

By September 30, 2010, submit a copy of the revised floor plan for each building that identifies the space provided for special education classrooms, related services, special education academic support, and any other areas specifically used for students identified with special needs and further identify all spaces assigned for the use of ELL students for direct English language instruction.

By February 19, 2011, the Department will schedule an on-site visit to verify compliance with the elements of this criterion.


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Criterion & Topic: CR 24 - Curriculum review Rating: Partially Implemented

Department CPR Finding: A review of documentation from the district indicated that the district had a process to ensure that individual teachers review all educational materials for simplistic and demeaning generalizations, lacking intellectual merit, on the basis of race, color, sex, religion, national origin and sexual orientation. However, there was no evidence in the documentation nor through interviews with staff that indicated that the review process had been implemented.

Narrative Description of Corrective Action: The district is currently in year one of a multi-year process to re-align all district curriculum. Due to this process, the district will not be adopting new textbooks and/or materials for at least one year. The district is also currently in the process of reviewing and revising all district policies. While the district has a policy for this area, it may be revised and it will be followed in the future when the district does adopt new textbooks and/or materials.


Implementation: Superintendent, Director,


Corrective Action Activity: April 20, 2011


Evidence of Completion of the Corrective Action: Completed forms

Description of Internal Monitoring Procedures: Forms will be submitted to the responsible parties when textbooks/materials are ordered.



Criterion: CR 24 - Curriculum review Status of Corrective Action:





By September 30, 2010, submit a narrative description of the district's multi-year plan to re-align all district curricula and include the results of current progress in curriculum review. Identify the persons conducting the review by title/role in the district and specify the materials that were reviewed and the level of compliance found. If non-compliance was found, explain the root cause and submit a narrative description of actions taken to address concerns and any future action planned.


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Program Area: English Learner Education









Criterion & Topic: ELE 1 - Annual Assessment Rating: Partially Implemented

Department CPR Finding: Documentation, student record, and interviews indicated that the district does not always administer annual assessments and that such assessments are not always administered by qualified staff.

Narrative Description of Corrective Action: 1: The district will provide initial assessments (LAS) within 5 days of the student entering the district. The district will also administer the Fall MEPA and MELA-Os to new students entering the district who did not take the previous spring MEPA.

The district also administers the MEPA assessments and MELA-Os in March for ELL students in grades K-12. The district will also use LAS in the spring as an annual assessment of proficiency.

2. The district has 8 currently qualified QMAs to administer MELA-Os (names on state website). All other assessments are administered by the district’s ESL-certified teachers.


Implementation: 1 & 2: Director, ELL Dept.

Chair


Corrective Action Activity: 1&2: Initial assessments (LAS) will be completed by Sept.

28, 2010 (if student has entered by 5 days prior to that date). All other assessments will be completed by state-mandated schedules.

Evidence of Completion of the Corrective Action: 1&2: Log of assessments administered and list of administrators, including their certification numbers, assessment scores from the DESE

Description of Internal Monitoring Procedures: Weekly meetings with director and department chair to include review of logs

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Criterion: ELE 1 - Annual Assessment Status of Corrective Action:


Basis for Partial Approval or Disapproval: The district description of corrective action includes assessments for initial identification (LAS) which are not a part of the requirements of this criterion and further, the district's description excludes procedures for MCAS administration which is a part of this criterion.

Department Order of Corrective Action: The district must implement procedures to assure that the

MCAS and MEPA for students in grades 3-12, and MELA-O for students in grades k-12 are administered annually by qualified staff to students who are English language learners, including those students who have opted-out until such student is re-designated as formerly limited English proficient.


By September 30, 2010, submit the district procedures for implementation of all the required elements of this criterion including the qualifications of the persons implementing assessment activities.

By September 30, 2010, submit a copy of the agenda and sign-in sheets for the training of appropriate staff regarding the requirements of this criterion and the district procedures for implementation to assure compliance.

By February 19, 2011, submit a list of all limited English proficient students enrolled in the district who will require annual assessment pursuant to the requirements of this criterion. Identify the proficiency level, grade level, and required assessments, as well as expected dates for administration and groupings divided by the qualified staff who will administer the assessments.





Criterion & Topic: ELE 3 - Initial Identification Rating: Partially Implemented

Department CPR Finding: Documentation, student records and interviews indicated that the district does not always use qualified staff and appropriate procedures and assessments to identify students who are limited-English-proficient and to assess their level of English proficiency in reading, writing, speaking, and listening.

Narrative Description of Corrective Action: see ELE 1


Implementation:





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Criterion: ELE 3 - Initial Identification Status of Corrective Action:


Basis for Partial Approval or Disapproval: The district proposal submitted under ELE 1 regarding annual assessments does not meet the elements of this criterion which is limited to initial identification.

Specifically, initial identification requires the use of an appropriate Home Language Survey, available to parents in the native language, administered by qualified staff, and initial assessments of language proficiency in all four modalities – reading, writing, speaking, and listening. The MELA-O and MEPA cannot be used for this purpose.

Department Order of Corrective Action: The district must establish procedures consistent with the requirements of this criterion to use the Home Language Survey, available in to parents in the native language to determine which students must then be assessed for English language proficiency using appropriate proficiency assessments in all four modalities – reading, writing, listening, and speaking.

The LAS as noted in the district plan for ELE 1 may be used for this purpose, but the district must also include an oral component (which may be the LAS-O) to initial assessment to determine overall proficiency consistent with the requirements of this criterion.


By September 30, 2010, submit a narrative of the procedures adopted by the district to comply with the requirements of this criterion. Specifically, those procedures which involve the administration of an appropriate Home Language Survey made available to parents in the native language and administered by appropriate staff and appropriate proficiency assessments in all four modalities. Also submit copies of the home language survey as available in the district in languages other than English.

By September 30, 2010, submit the agenda and sign-in sheets for the training of relevant staff members as to the district procedures for initial identification which comply with all the requirements of this criterion . Submit also the specific assessment(s) to be used for determining initial proficiency levels.

By February 19, 2011, submit copies of the completed home language surveys from a sample of student records. Submit a list of students who were initially assessed and identify each student's proficiency level, date of enrollment, date of assessment, type of assessment, and person who administered and scored the assessment tool. Also, submit a narrative description of the results of an administrative review of student records from all grade/school levels (Elementary, Middle, and High) for the limited English proficient population. Include the number of records reviewed, the number of

Home Language surveys completed, those completed in languages other than English, and the number that had copies of appropriate assessments used for initial identification. Identify any issues, explain the root cause for those issues and describe further steps taken to resolve noncompliance.

The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures


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Criterion & Topic: ELE 5 - Program Placement and

Structure


Department CPR Finding: Sheltered English immersion (SEI) is a program model for limited English proficient (LEP) students composed of two parts—English as a second language (ESL) and sheltered content instruction. ESL is explicit, direct instruction about the English language, delivered to LEP students only and designed to promote the English language development of LEP students. Sheltered content instruction is an approach for teaching content to LEP students in strategic ways that makes the subject matter concepts comprehensible while promoting the LEP students’ English language development.

A review of district documents shows that the district does not currently have an ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes.

For students who do receive direct ESL instruction, documentation indicates amounts of ESL instruction far below recommended hours as outlined in the Department’s September 2009 guidance document: “Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students." For example, beginners at most every grade level receive approximately 60 minutes per week of direct ESL at the elementary level and up to 60 minutes per week at other proficiency levels.

Content instruction is based on the appropriate Massachusetts Curriculum Framework; however, it is clear that LEP students do not receive sheltered content instruction as no teachers have completed all of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, described in the Commissioner’s Memorandum of June 2004 (see findings ELE 15). In fact, few teachers have completed any of the Category training other than

Category 3 (MELA-O training).

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Narrative Description of Corrective Action: 1a: The district currently has 4 teachers who have completed all four categories. Twenty teachers have completed three categories and 16 teachers have complete two categories. The district will continue to provide category trainings each year, with the goal for school year 2010-2011 to complete the remaining trainings for the 36 teachers who have been trained in more than one category. 3: The district has hired a consultant to assist with the development of a curriculum that is based on the ELPBO. The ESL teachers have taken a DESE-offered course on the development of the ELPBO-based curriculum. In addition, the

ESL teachers will be participating in the year-long district initiative of the re-alignment of ELA curriculum to the new state standards. 4:The district has created ESL classrooms for school year

2010-2011 with certified ESL teachers to meet the mandated instructional times as indicated in the “2009 Instructional Guidance Document” (according to individual student MEPA results).


Implementation: Director, ELL Department

Chair, Building Administrators


Corrective Action Activity: 1a: To be completed during school year 2010-2011.

3. To be completed by the beginning of school year 2011-2012.

4. Classrooms will be set up by Sept. 28,

2010. Instruction will be based on the scope and sequence as prescribed by the DESE

“Content-Based ESL” tool while the curriculum is being written.

Evidence of Completion of the Corrective Action: 1a: Training agendas, teacher sign-in sheets

3. The curriculum document. 4: Class lists and sample lesson plans

Description of Internal Monitoring Procedures: Weekly meetings between director and department chair, bi-weekly meetings between director and building administrators, monthly review of randomly selected student schedules



Criterion: ELE 5 - Program Placement and Structure



Basis for Partial Approval or Disapproval: Although the district has identified some measures of corrective action for the requirements of this criterion, the description of district corrective action does not address all identified areas of non-compliance. Specifically, the district must as a part of its election to implement an SEI model, assure that each limited English proficient student receives direct language instruction from an appropriately licensed ESL teacher for the specifically proscribed amount of time and that such instruction uses a curriculum based on the ELPBO standards. The participation of ESL teachers in aligning the district ELA curriculum is not a measure of corrective action consistent with the requirements of this criterion. Also, as a part of an SEI model, all general education teachers of content areas who have limited English proficient students in class, must have completed all four category trainings to meet the minimum standard of this criterion and the district must have a plan to provide such training or otherwise to assure students are placed in classrooms with category trained teachers.

Department Order of Corrective Action: The district must assign limited English proficient students to classes in direct language instruction with licensed teachers for the OELAAA prescribed amounts as time: 2.5 hours to the whole day for beginners/early intermediate, 1-2 hours per day for intermediate,

2.5 hours per week for transitioning/advanced students. Grouping of students must be according to proficiency level. The curriculum for ESL must align with the ELPBO standards. Limited English proficient students must receive all other content instruction in the general education classroom by content area teachers who have completed all four category trainings.

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By September 30, 2010, submit a description of the district implemented English language learner programs/schedules for each limited English proficient student. Specify the type of program, the amount of direct language instruction per day per student by proficiency level and indicate the licensed

ESL teacher along with that teacher's class schedule, and finally, indicate the amount of category training completed by each content area general education teacher.

By September 30, 2010, submit a copy of the district ESL curriculum that aligns with the ELPBO standards and curriculum maps for direct language instruction. If the curriculum is incomplete, submit those grades that have been completed and an action plan with time-frames for the completion of the curriculum for the remaining grades.

By September 30, 2010, submit a multi-year professional development plan to have all teachers trained in all four categories for sheltered English instruction.

By September 30, 2010, submit a roster of all limited English proficient students broken down by grade level and English proficiency level. Identify the amount of ESL instruction provided (hours/day, days/week), the grouping of students, and the person, with appropriate licensure, who provides ESL instruction.

By February 19, 2011, submit an updated list of category training completed by general education teachers since the first progress report. Submit further advances made in curriculum planning and implementation for the ESL curriculum, if not completed at the time of the first progress report.





Criterion & Topic: ELE 6 - Program Exit and

Readiness


Department CPR Finding: Documentation and interviews indicated that the district did not monitor

FLEP students for two years after re-designation as required

Narrative Description of Corrective Action: The district sends “FLEP” evaluation forms to teachers each quarter to use to monitor individual progress. In addition, the ESL teachers have added a specific time per cycle to meet with students who are being monitored in order to ensure their progress and work with them as needed (teacher request or student request).


Implementation: Director, Department Chair,

ESL teachers, Classroom teachers, Building

Administrators


Corrective Action Activity: Documentation to be collected for submission for Sept. 28,

2010 and Jan. 12, 2011

Evidence of Completion of the Corrective Action: Student records containing correspondence from teachers, logs of meetings w/students and services provided, logs of meetings with teachers and building administrators re: monitor students, “FLEP” evaluation forms, ESL teachers’ schedules

Description of Internal Monitoring Procedures: Weekly meetings between director and dept. chair, bi-weekly meetings between director and building administrators

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Criterion: ELE 6 - Program Exit and

Readiness



Basis for Partial Approval or Disapproval:

Department Order of Corrective Action:


See ELE 13 for related details.





Criterion & Topic: ELE 7 - Parent Involvement Rating: Partially Implemented

Department CPR Finding: Documentation and interviews indicated that the district has not developed a way to include parents of LEP students in matters pertaining to their children’s education.

At the time of this review, there was no indication that any information distributed by the district was sent in the primary language of the home and that there was no procedure in place to assist parents with oral translation for low incidence languages.

Narrative Description of Corrective Action: see CR 7


Implementation:







Criterion: ELE 7 - Parent Involvement Status of Corrective Action:


Basis for Partial Approval or Disapproval: The district has not included plans to train staff on its process to identify parents who may need translated materials and to follow through to distribute materials, such as handbooks, to limited English proficient parents, or its process to identify and provide oral interpretation to assist parents/guardians with limited English skills, including those parents who speak low-incidence languages.

Department Order of Corrective Action: Develop a mechanism to identify and track those parents who require assistance (both written and oral) in a language other than English to assure continued compliance with the requirements of this criterion. The mechanism must: 1. identify the language requested for translation (The district may use the Home Language Survey as its primary source for determining when communication with the home in a language other than English is required.);

2. outline the protocol staff will follow to consistently communicate with the home and provide written translation of all important materials distributed by the district (How will all staff become aware of

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which important documents must be translated and for whom it must be translated? How will staff access such translated material and distribute it appropriately?); 3. account for in-district communication between schools and departments (Special Education and general education) to share parent requests for translated materials; 4. provide for a system of oral interpretation for low incidence languages.

In developing a mechanism for compliance, please note under ELE 7, ELE 10, and SE 29 the district plan must include a mechanism for the translation of report cards and progress reports on English language development and also progress reports on IEP goals, and translation of required notices related to English language learners and Special Education programs and services.


By September 30, 2010, submit a narrative description of the mechanism the district has developed to assure compliance with all elements of this criterion.

By September 30, 2010, submit a copy of the important material being distributed to students in languages other than English. Also submit sign-in sheets and agenda for training of staff on the local process for identifying the need for translated materials or oral interpretation and on distributing or providing interpretation assistance or translated materials.

By February 19, 2011, conduct an administrative review of enrollment forms and student records for evidence of requests for translation and for translated materials or use of interpreters at Team meetings for those students with disabilities whose parents requested communication in languages other than

English. Identify the number of records reviewed, level (elementary, middle, high) of each record, the number of requests for translation or interpretation assistance, and the number of records that included translated materials in compliance with this criterion, explain the root cause if continued noncompliance was found and describe any steps taken to address areas of concern.






Criterion & Topic: ELE 8 - Declining Entry to a

Program


Department CPR Finding: Interviews with staff and a review of district documents indicated that the district does not provide English language support to students who have declined entry into the sheltered English immersion program. Specifically, general education staff members are not trained in sheltered English instruction and the ESL tutors in the district provide sheltered content instruction, not English as a second language instruction or English language development, only to those students in the SEI program

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Narrative Description of Corrective Action: The district will continue to train SEI teachers in all categories and will ensure that students who opt-out are placed in the classrooms of trained teachers. In addition, the district sends a quarterly progress report form to the teachers of “optout” students. Parents of “opt-out” students who are struggling will be notified of their child’s progress and be given the option to meet and reconsider services. This communication will be translated into the language of the home.


Implementation: Director, Dept. Chair,


Corrective Action Activity: Sept. 28, 2010, classroom teachers, ESL teachers, building administrators

Jan. 12, 2011

Evidence of Completion of the Corrective Action: Copies of progress forms, letters to parents, meeting notes

Description of Internal Monitoring Procedures: Weekly meetings between director and dept. chair



Criterion: ELE 8 - Declining Entry to a Program






By September 30, 2010, submit a professional development plan to have all staff trained in all four

SEI Categories. (See ELE 15)

By September 30, 2010, submit a list of limited English proficient students who have opted-out of district programs and services for English language learners.

By February 19, 2011, submit the narrative results of an administrative review of student records for those students who have opted-out of English language learner programs and services. Identify the number of opt-out students, the number making satisfactory progress in the content areas, the number of records found to have evidence of the district notice described above for students who are struggling. Explain the root cause for any continued non-compliance and indicate any additional steps the district has taken, if necessary, to provide support to those children who opted-out of programs.



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Criterion & Topic: ELE 9 - Instructional Grouping Rating: Partially Implemented

Department CPR Finding: A review of district documents showed that the district does not currently have an ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and

Outcomes (ELPBO); therefore, ESL/ELD instruction is not based on the ELPBO at all grade levels.

Since in many cases, students are taught individually, the district cannot ensure that students are grouped by proficiency level for ESL instruction, and therefore cannot meet the recommended number of hours of direct ESL instruction.



Implementation:







Criterion: ELE 9 - Instructional

Grouping



Basis for Partial Approval or Disapproval: The district proposal of corrective action under ELE 5 does not address all the requirements of this criterion. In particular, this criterion requires that instructional grouping be based on proficiency levels.

Department Order of Corrective Action: In addition to those requirements of establishing an approved program (see ELE 5), the district must assure that limited English proficient students are grouped for direct language (ESL) instruction based on similar proficiency levels and for appropriate amounts of time as prescribed by OELAAA for the distinct proficiency levels.


By September 30, 2010, submit the schedules for each limited English proficient student. List the students by proficiency level, assigned instructional group by days and hour(s) per day, and indicate the licensed ESL instructor for each group.

By February 19, 2011, submit the narrative results of an administrative review of limited English proficient student schedules and ESL staff schedules. Indicate the number of students receiving the prescribed amounts of direct language development (ESL) instruction, the number of groups that meet the requirements of this criterion for having similar or same proficiency levels within the group, the number of groups and/or individual students not receiving ESL instruction for the appropriate amount of time or within the appropriate group, and finally any further steps taken by the district to correct non-compliance.



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Criterion & Topic: ELE 10 - Parent Notification Rating: Partially Implemented

Department CPR Finding: Documentation, staff interviews, and student records indicated that the district does not send annual notice in compliance with the required elements of this criterion.

Specifically, notice does not inform parents of the reasons for identification of the student as LEP; the child’s level of English proficiency; program placement and/or the method of instruction used in the program. Also, the district does not provide progress reports and report cards on English language development written in a language understandable to the parent/guardian.

Narrative Description of Corrective Action: 1.a,b,c, g: The district has developed a letter for parents that uses the language and instructional times as prescribed on the DESE 2009 guidelines. This letter describes the reason for evaluation, the student’s proficiency level, and proposed instruction based on the instructional level. It also notifies the parent of the option to

“opt-out”. This letter will be translated in the district’s preferred languages and the option for oral translation will also be offered. 2. The district will translate progress reports and report cards describing their child’s English language development in the language of the home and will also offer oral translation.


Implementation: Director, Dept. chair, ESL teachers


Corrective Action Activity: 1. a,b,c,g: Sept.

28, 2010 2: Jan. 12, 2011

Evidence of Completion of the Corrective Action: Copies of letters to parents in home languages, copies of report cards

Description of Internal Monitoring Procedures: Quarterly review of letters and progress reports



Criterion: ELE 10 - Parent

Notification






By September 30, 2010, submit a copy of the parent notification letter consistent with the requirements of this criterion as described above.

By February 19, 2011, submit the narrative results of an administrative review of student records for parent notification and translation of notice and reports cards or progress reports. Identify the number of records reviewed, the number with appropriate notice and specify type of notice as initial placement letter or annual letter. Also, indicate the number with translated report cards or progress reports, explain the root cause if continued non-compliance was found and describe any additional steps the district has taken, if necessary, to correct non-compliance.

The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of

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person(s) who conducted the review with roles and signatures.





Criterion & Topic: ELE 11 - Equal Access to

Academic Programs and Services


Department CPR Finding: Documentation, staff interviews and student records indicated that the district does not meet all of the requirements of this criterion. Specifically, the district does not ensure that LEP students have the opportunity to receive support services, such as guidance and counseling, in a language that the student understands; and does not ensure that LEP students are taught to the same academic standards and curriculum as all students where there is no ESL curriculum in the district and there are insufficient numbers of trained sheltered English instruction teachers in the general education program. Finally, the district does not have a procedure in place to provide information in notices such as activities, responsibilities, and academic standards to LEP students in a language and mode of communication that they understand.

Narrative Description of Corrective Action: 3: 4: 5: 8:


Implementation:







Criterion: ELE 11 - Equal Access to

Academic Programs and Services



Basis for Partial Approval or Disapproval: The district narrative description of corrective action refers to ELE 3, ELE 4, ELE 5, and ELE 8 which have been partially approved with Department orders of corrective action inserted, see above. However, this criterion has an additional requirement of student support services, such as guidance and counseling in a language understandable to the student which the district has not addressed here.

Department Order of Corrective Action: In addition to the revised corrective action detailed in ELE

3, ELE 4, ELE 5, and ELE 8, the district must establish a mechanism and provide a description of implementation practices to assure that limited English proficient students have equal access to academic programs and services, including guidance and counseling, in a language and mode of communication that they understand.


See ELE 3, ELE 5, ELE 8 regarding corrective action for initial identification procedures, program placement and structure and support for students who opt-out.

By September 30, 2010, submit a description of the district adopted mechanism and implementation practices to assure limited English proficient students have equal access to academic programs and services, including guidance and counseling, in a language and mode of communication that they

61

understand. Include relevant elements of the District Curriculum Accommodation Plan.

By February 19, 2011, conduct training for appropriate staff regarding the district mechanism for compliance with the requirements of this criterion and the district implementation practices. Submit the agenda and sign-in sheets for the training.





Criterion & Topic: ELE 12 - Equal Access to

Nonacademic and Extracurricular Programs


Department CPR Finding: Documentation, staff interviews and student records indicated that the district does not always provide information about extracurricular activities and school events to limited English proficient students in a language they understand



Implementation:







Criterion: ELE 12 - Equal Access to

Nonacademic and Extracurricular

Programs



Basis for Partial Approval or Disapproval: The district did not provide a narrative description of corrective action and did not complete the other sections of the corrective action plan required above.

Department Order of Corrective Action: The district must establish a mechanism and provide a description of implementation practices to assure that limited English proficient students have equal access to nonacademic and extracurricular programs, including provision of information about extracurricular activities and school events in a language and mode of communication that they understand.


By September 30, 2010, submit a narrative description of the district mechanism and implementation practices to assure that limited English proficient students have equal access to nonacademic and extracurricular programs. The district mechanism must include the provision of information about extracurricular activities and school events in a language and mode of communication that limited

English proficient students understand.

By February 19, 2011 , submit a list of all nonacademic programs, services, and school sponsored extracurricular activities. Identify the number of limited English proficient students in each.

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By February 19, 2011 , submit a copy of translated information provided to limited English proficient students about extracurricular programs and services, and school sponsored nonacademic activites.





Criterion & Topic: ELE 13 - Follow-up Support Rating: Partially Implemented

Department CPR Finding: District documentation, staff interviews and student records indicated that the district does not actively monitor students who have exited the English learner education program for two years and that the district does not always provide support to those students, if needed.



Implementation:







Criterion: ELE 13 - Follow-up

Support



Basis for Partial Approval or Disapproval: Although the district narrative description of corrective action in ELE 6 does address the requirement to actively monitor students who have exited the program, the district has not provided follow-up procedures and implementation practices to assure compliance with the requirement to monitor exited students for 2 years and to provide language support services for exited students, if needed.

Department Order of Corrective Action: Submit a description of follow-up procedures and implementation practices to actively monitor exited students for 2 years and to provide language support services to those students if needed.


By September 30, 2010, submit a narrative description of follow-up procedures and implementation practices to actively monitor exited students for 2 years and to provide language support services to those students if needed.

By September 30, 2010, submit a copy of the FLEP monitoring form described in the district response under ELE 6.

By February 19, 2011 , submit a narrative description of the results of an administrative review of student records for active monitoring of students who have exited the English language learner program. Include the number of records reviewed, the number found to be in compliance explain the root cause if continued non-compliance was found and describe additional steps taken, if any, to address areas of concern.

The district will maintain the following documentation and make it available to the Department upon

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request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures.





Criterion & Topic: ELE 14 - Licensure Requirements Rating: Partially Implemented

Department CPR Finding: As required under G.L. c.71, § 38G and 603 CMR 7.04(3), the district must employ at least one ESL teacher. Although appropriately licensed, the district is indicating that both staff members providing ESL services are considered as tutors and neither staff member is teaching ESL.



Implementation:







Criterion: ELE 14 - Licensure

Requirements






See ELE 5.

By September 30, 2010, submit a list of current limited English proficient students and a copy of their schedules for ESL with teachers who meet the licensure requirements of this criterion. Identify the proficiency level of the student and the grouping for each ESL teacher's class assignments.





Criterion & Topic: ELE 15 - Professional

Development Requirements


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Department CPR Finding: Content instruction is based on the appropriate Massachusetts

Curriculum Framework; however, it is clear that LEP students do not receive sheltered content instruction as no teachers have completed all of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, described in the

Commissioner’s Memorandum of June 2004 (see findings ELE 15). In fact, few teachers have completed any of the Category training other than Category 3 (MELA-O training).

Narrative Description of Corrective Action: see ELE 5, ELE 8


Implementation:







Criterion: ELE 15 - Professional

Development Requirements



Basis for Partial Approval or Disapproval: The district did not provide a narrative description of corrective action.

Department Order of Corrective Action: The district must submit a staff list that identifies each general education teacher's level of sheltered English Instruction Category training completed and a plan to have all teacher complete all categories.


By September 30, 2010, submit a staff list of all general educators by building and content area/grade level. Indicate the amount and specific Category training completed by each teacher. Submit evidence of completion of category training for each teacher that corresponds to the master list.

By September 30, 2010, submit a plan (multi-year plan, if necessary) to have all general education faculty receive all four category training in sheltered English instruction.


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Criterion & Topic: ELE 18 - Records of LEP Students Rating: Partially Implemented

Department CPR Finding: A review of student records indicated that the district does not meet all the required elements of this criterion. Specifically, not all student records include copies of the home language survey, results of identification and proficiency testing, information on previous schooling, copies of parent notification, and evidence of follow-up monitoring when applicable

Narrative Description of Corrective Action: The district has created an annual log for student records that indicates the inclusion of each of the above. The district is in the process of creating a set of electronic monitoring documents.


Implementation: Director, Dept. chair



Evidence of Completion of the Corrective Action: Completed logs

Description of Internal Monitoring Procedures: Quarterly internal audit of randomly selected student records



Criterion: ELE 18 - Records of LEP

Students






By February 19, 2011 submit a narrative description of an administrative review of student records for the inclusion of all required documents in the record. Identify the number of records reviewed from each grade/level (Elementary, Middle, and High), the number that contained all required documents, the documents missing from any record reviewed, explain the root cause for continued noncompliance, if found, and describe further steps taken to address areas of concern and correct noncompliance.


Progress Report Due Date(s): February 19, 2011

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