MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Bridgewater-Raynham CPR Onsite Year: 2010-2011 Program Area: Special Education 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 dated 05/26/2011. Mandatory One-Year Compliance Date: 05/25/2012 Summary of Required Corrective Action Plans in this Report Criterion SE 8 Criterion Title IEP Team composition and attendance SE 9 Timeline for determination of eligibility and provision of documentation to parent Review and revision of IEPs SE 14 SE 24 SE 39A SE 39B Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Procedures used to provide services to eligible students enrolled in private schools at private expense whose parents reside in the district Procedures used to provide services to eligible students who are enrolled at private expense in private schools in the district and whose parents reside out of state CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 46 SE 54 Criterion Title 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; responsibilities of the Team; responsibilities of the district Procedural requirements applied to students not yet determined to be eligible for special education Professional development SE 56 Special education programs and services are evaluated SE 47 CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 8 IEP Team composition and attendance Partially Implemented Department CPR Findings: Parents surveys and interviews indicate that the Team chairperson is not always able to commit the resources of the district at the Team meeting and, at times, must check with a higher authority. Description of Corrective Action: On the first day of the school year, hand out a copy of SE Criterion #8 and remind staff that the chairperson of every team meeting has the authority to commit the resources of the district. Follow this up with staff meetings at every building within the first month of school further explaining how this should be accomplished by anticipating how each team meeting will go and having possible answers to different scenarios. Hold multiple meetings throughout the year to assess implementation of IEP based on reducing reconvenes. Staff will be trained and monitored at team meetings. Anticipated Results: The anticipated results are to reduce the number of meetings that require further action due to the uncertainty of offering services. This will be done through staff training. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, Team Chairs 10/30/2012 Evidence of Completion of the Corrective Action: The evidence of completion will be the data collected on the reduced number of meetings needed to be reconvened due to requests for services that could not be answered at the time. Staff meeting agendas and sign-in sheets will be provided. Description of Internal Monitoring Procedures: An internal monitoring sheet will be developed to provide documentation to Central Office. A key component of the information to be requested will be whether or not there is a need to reconvene. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 8 IEP Team composition and Approved attendance Status Date: 07/19/2011 Basis for Partial Approval or Disapproval: The district will train staff on the requirement to have a representative of the school district who has the authority to commit the resources of the district present at the Team meeting. The district submitted a monitoring plan, however, the anticipated result was not to achieve 100% compliance but rather to reduce the number of meetings that require further action due to the uncertainty of offering services. Department Order of Corrective Action: Develop appropriate procedures to ensure that there is a representative of the school district present at each Team meeting who has the authority to commit resources of the district for the services agreed to by the Team. Required Elements of Progress Report(s): By November 1, 2011 submit a copy of the revised procedures to ensure that an individual with the authority to commit the resources of the district is present at the Team MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 3 meeting and submit as evidence of training on these procedures the following: (1) agenda; (2) signed attendance sheet (indicating role of staff); (3) training materials; (4) date of the training(s). Also submit a revised internal oversight and tracking system that reflects the goal of 100% compliance and identify the person(s) responsible for the oversight. By March 16, 2012 submit a summary report of the internal monitoring of records reviewed subsequent to the implementation of corrective actions for evidence of an individual with the authority to commit resources of the district at the Team meeting. Include the following: (1) the number of records reviewed, (2) rate of compliance, (3) description of root cause(s) of any non-compliance, (4) and the specific actions taken to remedy any identified non-compliance. Please note when conducting internal monitoring the district must 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): 11/01/2011 03/16/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: Student records indicate that the district does not always determine whether a student is eligible for special education and provide the parent with an IEP or a written explanation of a finding of no eligibility within forty-five school working days after receipt of the parent?s written consent to an initial evaluation or a re-evaluation. Description of Corrective Action: Best practice guidelines for writing the N2 form will be reviewed at the meeting on the first day of school. Discussions with School Psychologists, Team Chairs will follow to ensure a coordinated approach. Guidelines will be developed to help teams understand the requirements when a student is found to have a disability but does not qualify for special education or related services. Procedures will be implemented immediately. Anticipated Results: Staff will better understand the regulations and be instructed to follow best practice guidelines when writing N2's. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, Team Chairs 11/30/2011 Evidence of Completion of the Corrective Action: Reviews of N2's in student filles will demonstrate compliance. Staff meeting agendas and sign-in sheets will be provided. Description of Internal Monitoring Procedures: Using ESPED search tools, reviews will be completed by the Director of Special Education, Assistant Director of Special Education on a monthly basis to ensure compliance. Documentation of these reviews will be kept on file by the Director of Special Education. Staff meeting agendas and sign-in sheets will also be kept on file. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: SE 9 Timeline for determination of Disapproved eligibility and provision of documentation Status Date: 07/19/2011 to parent Basis for Partial Approval or Disapproval: The district did not propose a corrective action that addresses the requirement to determine whether a student is eligible for special education and provide the parent with an IEP or a written explanation of a finding of no eligibility within forty-five school working days after receipt of the parent's written consent to an initial evaluation or a reevaluation. Department Order of Corrective Action: Review the timelines of initial evaluations and re-evaluations that have been conducted this past school year and analyze this data to establish the root cause(s) for noncompliance. Based on this root cause analysis, indicate the specific corrective actions taken to remedy the non-compliance. Develop an internal oversight and tracking system to ensure that an IEP or a written explanation of a finding of no eligibility is provided within forty-five school working days MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 5 after receipt of the parent's written consent. The tracking system should include supervisory oversight at the school level and periodic reviews to ensure compliance. Develop a report of the results of an internal review of student records from all grades in which an initial or re-evaluation was conducted since the implementation of all of the district's corrective actions for evidence of compliance with issuing an IEP or a written explanation of a finding of no eligibility within forty-five school working days after receipt of the parent's written consent. Required Elements of Progress Report(s): By November 1, 2011 submit the outcomes of the root cause analysis with the specific proposal(s) for remedying the non-compliance. Submit a description of the internal oversight and tracking system including the date of the system's implementation and the person(s) responsible for the oversight for ensuring that an IEP or a written explanation of a finding of no eligibility is provided within forty-five school working days after receipt of the parent's written consent. By March 16, 2012 submit a report of the results of an internal review of records in which an initial evaluation or re-evaluation was conducted since implementation of the oversight and tracking system for compliance with timelines. Include the following: (1) number of records reviewed; (2) number of records in compliance; (3) results of the root cause analysis of any records not in compliance; (4) and specific corrective actions taken by the district to remedy any non-compliance. Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 11/01/2011 03/16/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: Student record review indicates that the IEP Team does not consistently meet annually, on or before the anniversary date of the IEP, to consider the student?s progress and to review, revise, or develop a new IEP or refer the student for a re-evaluation, as appropriate. Description of Corrective Action: Regulations regarding reviewing, revising, or developing a new IEP annually will be reviewed at an upcoming staff meeting, with specific instruction against extending the IEP annniversary date. Training of staff (including special ed secretaries) will occur at or before September staff meetings. Implementation will occur immediately and a random sampling will occur throughout the year. Anticipated Results: Annual meetings to consider the student's progress and to review, revise, or develop an IEP will occur within the one-year IEP period. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, Team Chairs 11/30/2011 Evidence of Completion of the Corrective Action: Review (or re-evaluation) of all IEP's will occur within the mandatory 12-month period. A random sampling across all grade levels will occur. Staff meeting agendas with sign-in sheets will be submitted. Description of Internal Monitoring Procedures: Using ESPED search tools, monthly reports will be generated to monitor the coordination of Annual Review (or re-eval) meeting dates with IEP expiration dates. Discrepancies will be investigated and corrections made as needed. Copies of staff meeting agendas and sign-in sheets will be filed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Approved Status Date: 07/19/2011 Basis for Partial Approval or Disapproval: The district will train staff on the requirements of this criterion and conduct an internal review to ensure that the IEP Team meets annually to consider the student's progress and to review, revise or develop a new IEP. Please note, once the district conducts an internal review of the IEP Team meeting dates from the 2010-2011 school year, it may establish a root cause of the non-compliance and determine that additional corrective action is required in addition to the staff training. Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 review the dates of the IEP Team meetings that have been held this past school year and analyze this data to establish the root cause(s) for the noncompliance. Based on this root cause analysis, provide the specific corrective actions taken to remedy the non-compliance. Indicate the specific person(s) responsible for the MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 7 internal monitoring of this criterion. By March 16, 2012 submit a report of the results of an internal review of records in which an annual review was conducted since implementation of the oversight and tracking system for compliance with timelines. Include the following: (1) number of records reviewed; (2) number of records in which an annual review was conducted before the anniversary date of the IEP; (3) results of the root cause analysis of any records not in compliance; (4) and specific corrective actions taken by the district to remedy any noncompliance. Please note when conducting internal monitoring the district must 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): 11/01/2011 03/16/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 24 Notice to parent regarding proposal or refusal to initiate or Partially Implemented change the identification, evaluation, or educational placement of the child or the provision of FAPE Department CPR Findings: Student records indicate that the Notice of Proposed School District Action (N1) does not meet all of the content requirements, as not all questions on page 2 of the N1 form are always addressed. Description of Corrective Action: The district will conduct a training with all team chairs to review the requirement as to answering all questions on page 2 of the N1 form. The district will conduct a follow-up administrative review, i.e. random sampling Anticipated Results: Assurance that all questions on page 2 of N1 are answered, even if the question doesn't apply. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, Team Chairs 10/30/2011 Evidence of Completion of the Corrective Action: Team Review and sampling of student records. Staff meeting agendas with sign-in sheets will be provided. Description of Internal Monitoring Procedures: Team Review and sampling of student records. Staff meeting agendas with sign-in sheets will be filed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 24 Notice to parent regarding Status Date: 07/19/2011 proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Basis for Partial Approval or Disapproval: The district will train staff on the requirements to address all questions on page 2 of the N1 form.The district has developed procedures to track and monitor student records to ensure that the forms are correctly completed. Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit the following as evidence of training: (1) sign-in sheet; (2) training materials; (3) name of the instructor; (4) date of the training. By March 16, 2012 submit a summary report of the internal monitoring of records in which an N1 form was developed since the training. Include the following: (1) the number of student records reviewed; (2) the rate of compliance; (3) the root cause(s) of any non-compliance; (4) and the steps taken to address any identified non-compliance. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 9 Please note when conducting internal monitoring the district must 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): 11/01/2011 03/16/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 39A Procedures used to provide services to eligible students Partially Implemented enrolled in private schools at private expense whose parents reside in the district Department CPR Findings: Documentation and interviews indicate that the district is not calculating the proportionate share of Federal Special Education Entitlement funds required to be spent on eligible private school students and documenting the spending of at least this amount of federal entitlement funds on one or more eligible private school students attending private school in the district whose parents reside in the district or out of state. Description of Corrective Action: A spreadsheet of students attending private schools will be kept and monitored. The district will calculate the proportionate share of Federal Special Education Entitlement Funds used to be spent on eligible private school students. Anticipated Results: Completed and accurate documentation of federal entitlement funds will be provided. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education 04/25/2012 Evidence of Completion of the Corrective Action: Completed and accurate documentation of federal entitlement funds will be filed. Description of Internal Monitoring Procedures: Tracking form sent to private schools at the beginning and end of the academic school year to monitor student activity. Copies of the calculations of proportionate share of special education entitlement funds will be filed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 39A Procedures used to provide Status Date: 07/19/2011 services to eligible students enrolled in private schools at private expense whose parents reside in the district Basis for Partial Approval or Disapproval: The district will calculate the proportionate share of Federal Special Education Entitlement funds required to be spent on eligible private school students and documenting the spending of at least this amount of federal entitlement funds on one or more eligible private school students attending private school in the district whose parents reside in the district or out of state. Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit a copy of the completed Proportionate Share Worksheet. Progress Report Due Date(s): 11/01/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 11 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 39B Procedures used to provide services to eligible students Partially Implemented who are enrolled at private expense in private schools in the district and whose parents reside out of state Department CPR Findings: See SE 39A above. Description of Corrective Action: A spreadsheet of students attending private schools will be kept and monitored. The district will calculate the proportionate share of Federal Special Education Entitlement Funds used to be spent on eligible private school students. Anticipated Results: Completed and accurate documentation of federal entitlement funds will be provided. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education 04/25/2012 Evidence of Completion of the Corrective Action: Completed and accurate documentation of federal entitlement funds will be provided. Description of Internal Monitoring Procedures: Tracking form sent to private schools at the beginning and end of the academic school year to monitor student activity. Copies of the calculations of proportionate share of special education entitlement funds will be filed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 39B Procedures used to provide Status Date: 07/19/2011 services to eligible students who are enrolled at private expense in private schools in the district and whose parents reside out of state Basis for Partial Approval or Disapproval: See SE 39A. Department Order of Corrective Action: Required Elements of Progress Report(s): See SE 39A. Progress Report Due Date(s): 11/01/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 46 Procedures for suspension of students with disabilities Partially Implemented when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Department CPR Findings: Documentation indicates that the student codes of conduct do not contain information that is consistent with federal requirements in reference to the discipline of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days.  Information was missing in the procedures pertaining to the manifestation determination and placement in an interim alternative educational setting. Description of Corrective Action: A new procedure will be implemented that indicates that a student who has been suspended for 8 days will automatically trigger a Manifestation Determination. An FBA will also be completed for any student who presents with significant behavioral challenges. Training will be provided to the districts administrative team to review all fesderal and state regulations during the handbook committees' annual meetings to revise the handbooks. Anticipated Results: Full Compliance. Special Education representation will be present at building based handbook committee meetings. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, Building Principals 04/25/2012 Evidence of Completion of the Corrective Action: Student records will include completed behavioral manifestation forms for any student who has been suspended for 8 or more days. In addition FBA's will be completed for students who have been referred to the school administration because of significant behavioral infractions. Staff meeting agendas and sign-in sheets will be provided. Description of Internal Monitoring Procedures: The Special Education Director and Assistant Director will select records for review and ensure that behavioral manifestations and FBA's are included. Copies of handbooks will be provided showing codes of conduct containing information that is consistent with federal requirements. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 46 Procedures for suspension of Approved students with disabilities when Status Date: 07/19/2011 suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Basis for Partial Approval or Disapproval: The district's proposal does not address placement in an interim alternative educational MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 13 setting. Department Order of Corrective Action: Include procedures for placement in an interim alternative educational setting in the student codes of conduct. Required Elements of Progress Report(s): By November 1, 2011 submit a copy of the student code of conduct from each school and evidence of staff training on the procedures for the suspension of students with disabilities, including the agenda, training materials and sign-in sheets. Progress Report Due Date(s): 11/01/2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 47 Procedural requirements applied to students not yet Partially Implemented determined to be eligible for special education Department CPR Findings: Documentation indicates that student handbooks and codes of conduct do not contain the procedural requirements applied to students not yet determined to be eligible for special education. Description of Corrective Action: Training will be provided to the districts administrative team to review all federal and state regulations during the handbook committees' annual meetings to revise the handbooks. Documentation will be inserted into the handbooks identifying procedural requirements applied to students not yet determined to be eligible for special education. Anticipated Results: Full Compliance with procedural requirements applied to students not yet determined to be eligible for special education. Special education representation at building based handbook committees' annual revision meetings. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, Building Principals 04/25/2012 Evidence of Completion of the Corrective Action: Letters informing both students and parents of their rights composed by the principal. Evidence of special education participation in handbook committee meetings through agendas and sign in sheets. Copies of handbooks documenting procedural requirements applied to students not yet determined to be eligible for special education. Description of Internal Monitoring Procedures: Review of letters informing both students and parents of their rights composed by the principal and review of student records. Copies of agendas and sign in sheets showing representation of special education at handbook committee revision meetings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 47 Procedural requirements applied to students not yet determined to be eligible for special education Corrective Action Plan Status: Approved Status Date: 07/19/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 14 Basis for Partial Approval or Disapproval: Information indicated that student handbooks for the 2011-2012 school year will contain the revised codes of conduct with information pertaining to the procedural requirements applied to students not yet determined to be eligible for special education. Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit a copy of the student handbook from each school in the district and evidence of staff training on these requirements, including the agenda, training materials and sign-in sheet(s). Progress Report Due Date(s): 11/01/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 15 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 54 Professional development Partially Implemented Department CPR Findings: Documentation and interviews indicate that general education staff and paraprofessionals have not received training in the required special education topics: a. state and federal special education requirements and related local special education policies and procedures; b. analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; c. methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate diverse learning styles of all students in the regular classroom. Description of Corrective Action: Professional development will be provided for paraprofessionals, general and special education teachers in accommodating all students in the classroom regardless of their disability. Professional development will also be provided in an ongoing basis. Professional development activities will be posted on the website. Anticipated Results: Anticipated results will be 100% participation in professional development opportunities. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Assistant Director of Special Completion: Education, District PD Committee 10/30/2011 Evidence of Completion of the Corrective Action: Description of professional development activities. Sign-in sheets for all participants. Description of Internal Monitoring Procedures: Description of professional development activities. Sign-in sheets for all participants. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 54 Professional development Corrective Action Plan Status: Partially Approved Status Date: 07/19/2011 Basis for Partial Approval or Disapproval: The district did not propose that it would provide general education staff and paraprofessionals training in state and federal special education requirements and related local special education policies and procedures. Department Order of Corrective Action: Provide general education staff and paraprofessionals training in state and federal special education requirements and related local special education policies and procedures. Required Elements of Progress Report(s): November 1, 2011 submit the following as evidence of training on the topic listed above: (1) sign-in sheets (2) training materials (3) name of instructor (4) dates of training. Progress Report Due Date(s): 11/01/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 16 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 56 Special education programs and services are evaluated Partially Implemented Department CPR Findings: Documentation and interviews indicate that the district has not regularly evaluated the effectiveness of its special education programs. Description of Corrective Action: An evaluation process of the effectiveness of the district's special education programs will be developed and instituted. A cross-sectional committee will be developed to gather data and determine the effectiveness of special education programs. This will be done on a rotating basis and a schedule will be followed. Anticipated Results: Throughout the evaluation process, committee members will have a chance to assist in strengthening the effectiveness of special education programs accross the district. Surveys may be one tool used to gather documentation. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Asst. Director of Special Education, Completion: Parent Advisory Council 04/30/2012 Evidence of Completion of the Corrective Action: Copies of the evaluation tool used to determine the effectiveness of special education programs will be filed and provided. Committee agendas, sign in sheets and notes will be provided. The documentation gathered will be utilized to measure the effectiveness and efficiency of programs. Description of Internal Monitoring Procedures: Copies of the evaluation tool used to determine the effectiveness of special education programs will be filed and provided. Committee agendas, sign in sheets and notes will be provided. The documentation gathered will be utilized to measure the effectiveness and efficiency of programs. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 56 Special education programs and Status Date: 07/19/2011 services are evaluated Basis for Partial Approval or Disapproval: Additional information indicated that a program evaluation was completed during the 2010-2011 school year. Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit the evaluation report for special education programs and services. Progress Report Due Date(s): 11/01/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 17 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Bridgewater-Raynham Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Donna Dixon Paolini 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: May 25, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 3 Access to a full range of education programs Rating: Partially Implemented Department CPR Finding: See ELE 5 and ELE 11 for equal access to programs and services for limited English proficient students. Narrative Description of Corrective Action: The Dir of Admin, Curriculum & Grants will ensure that all students have equal access to all academic programs and services. Bridgewater Raynham has created policies and procedures regarding the rights of all students to having equal access to academic programming. These are fully described in the Corrective Action Response in the ELL program review and included in the ELE program booklet. In addition, the classroom environment for instruction in ESL will be comparable to that of general education programming. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Administration, Corrective Action Activity: September 2011 Curriculum & Grants Evidence of Completion of the Corrective Action: Upon surveys given to students, staff and parents, the data will show that all students have the opportunity to participate with equal access. Description of Internal Monitoring Procedures: Periodic checks of student schedules, surveys will provide with the information. Conversations with building administrators and staff to determine if there is equal access will occur during the school year. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 18 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 3 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See ELE 5 and ELE 11 for equal access to programs and services for limited English proficient students. Department Order of Corrective Action: Required Elements of Progress Report(s): See ELE 5 and ELE 11 Progress Report Due Date(s): See ELE 5 and ELE 11 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 9 Hiring and employment practices of prospective employers of students Rating: Partially Implemented Department CPR Finding: Documentation and interviews indicate that employers of students in work-study programs are not required to sign a statement indicating that the employer complies with applicable federal and state laws prohibiting discrimination in hiring or employment practices on the basis of race, color, national origin, sex, handicap, religion and sexual orientation. Narrative Description of Corrective Action: The District will review the current forms used when students participate in any work related project. New language will be included in the revised forms stating that prospective employees comply with all applicable federal and state laws prohibiting discrimination based on race, color, national origin, sex, handicap, religion or sexual orientation. Staff members will be advised of this new language at the beginning of each school year and reviewed with any new staff member as needed. Forms will be revised to comply with appropriate language Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Guidance counselors, sped Corrective Action Activity: September 2011 staff, Asst. Dir of Sped. Evidence of Completion of the Corrective Action: The District will maintain copies of the forms in the appropriate office and in the students files. Minutes from sped meetings and guidance dept meetings will document utilization of the new forms Description of Internal Monitoring Procedures: Periodic checks of student records will provide evidence that the appropriate forms are being utilized. These checks will be made by both the guidance dept head and assistant sped director. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 9 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 19 Required Elements of Progress Report(s): By November 1, 2011 submit a copy of the updated form that will be signed by the prospective employer of a student in a work-study program. By March 16, 2012 submit copies of forms signed by employers of students in work-study programs. Progress Report Due Date(s): November 1, 2011 and March 16, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 10A Student handbooks and codes of conduct Rating: Partially Implemented Department CPR Finding: Documentation indicates that the following are missing from codes of conduct and student handbooks: a) Reference to M.G.L. c. 76, s. 5 (all handbooks except that of Raynham Middle School); b) Appropriate procedures for the discipline of students with disabilities that are consistent with IDEA 2004, including students not yet determined eligible. Procedures in the handbooks cite outdated state regulations; c) Appropriate procedures for the discipline of students protected under Section 504; and d) Reference to sexual orientation in the high school handbook’s policy statement of nondiscrimination. Narrative Description of Corrective Action: The District has reviewed all handbooks for evidence of noncompliance. Meetings were held with the individual responsible for handbook language and the omissions were added to the FY12 handbooks. This information will be reviewed with both students and staff in August 2011 when the school year begins. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin, Curriculum & Corrective Action Activity: September 2011 Grants Evidence of Completion of the Corrective Action: The corrected language has been inserted into the handbooks. This information was provided to the assistant principals at monthly meetings and was reflected in the minutes of the meetings. Description of Internal Monitoring Procedures: The District Civil Rights Compliance Officer will review with administrators on a regular basis the student handbooks and codes of conduct for appropriate language. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 10A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 provide a copy of the revised codes of conduct and student handbooks. Progress Report Due Date(s): November 1, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 20 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion Rating: Partially Implemented Department CPR Finding: Documentation and interviews indicate that the notice to students leaving school without a high school diploma, certificate of attainment or certificate of completion does not contain the required information regarding the right to meet with a representative of the district within ten days from the date the notice was sent. Documentation and interviews indicate that the district has not sent notice to former students who have not yet earned their competency determination and who have not transferred to another school to inform them of the availability of publicly funded post-high school academic programs and to encourage them to participate in those programs. Narrative Description of Corrective Action: The District reviewed the current notices sent to students and inserted the required information. In addition, a new letter was drafted to be sent to former students who have not yet met their competency determination. During this process, conversations were held with the Dir of Guidance, principals and assistant principals to inform them of these procedures. The high school assistant principal was instrumental in drafting the letter. This form will be used beginning in September 2011 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Principal/Dir of Corrective Action Activity: September 2011 Guidance Evidence of Completion of the Corrective Action: The District sent memos to the principal and Dir of Guidance to investigate the noncompliance. A letter was drafted to correct this. Description of Internal Monitoring Procedures: The District(through the assistant principal and Director of Guidance) will periodically review that the appropriate notices are sent to the students in question. These reviews will be discussed at monthly meetings with the Director of Guidance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 16 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit to the Department the revised notice to students leaving school without a high school diploma, certificate of attainment or certificate of completion informing them of the right to meet with a representative of the district within ten days from the date the notice was sent. By November 1, 2011 submit a copy of the letter sent to former students who have not yet earned their competency determination and who have not transferred to another school. By March 16, 2012 submit a list of students, by initials, to whom these letters were sent. Progress Report Due Date(s): November 1, 2011 and March 16, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 21 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 20 Staff training on confidentiality of student records Rating: Partially Implemented Department CPR Finding: Interviews indicate that staff are trained on the confidentiality of student records at the time they are hired. Interviews indicate that staff members have not received periodic training on the confidentiality of student records and many staff indicated that they do not recall receiving training on this subject. Narrative Description of Corrective Action: Information regarding the confidentiality of student records will be inserted into the FY12 staff handbook. At the opening day staff meetings with principals, each principal will review these regulations with the staff. Principals will be instructed to review this information with their staff on a daily basis. All new hires to the District throughout the year will receive this training from their respective building administrator as well as a review with their mentor teacher , if applicable. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Building Administrator Corrective Action Activity: September 2011 Documentation in staff handbooks and minutes of opening day staff meetings. In addition, notes from meetings with new teachers/staff will reflect this Description of Internal Monitoring Procedures: Principals will review minutes of staff meetings and review information with the new hires during the year. Copies of minutes of staff meetings will be reviewed for compliance of this CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 20 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit the following as evidence of training on the confidentiality of student records: (1) sign-in sheets (2) training materials (including information in the handbooks) (3) name of instructor (4) dates of trainings. Progress Report Due Date(s): November 1, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 25 Institutional self-evaluation Rating: Partially Implemented MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 22 Department CPR Finding: Interviews and documentation indicate that the district does not evaluate all aspects of its K-12 program annually to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities. Narrative Description of Corrective Action: The District will develop a survey to be given to students, parents, and staff to determine their perception on the accessibility to students of all PK-12 programs. The survey will be developed by members of the Administrative Council(Principals, Special Education Director and Assistant, Human Resources Manager, Dir of Administration, Curriculum, and Grants) The survey will be distributed in both an online and paper format. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Administration, Corrective Action Activity: May 1, 2012 Curriculum & Grants Evidence of Completion of the Corrective Action: Results of the survey and data analysis will provide a description of the needs of the District and adjustments/revisions to its programs that may be needed. Description of Internal Monitoring Procedures: The District will distribute annual surveys to determine compliance and also a data analysis to further improve its programming. These surveys and analysis will be completed by the Director of Administration, Curriculum and Grants in conjunction with the Administrative Council and building principals CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: 25 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011 submit a copy of the survey developed to complete the institutional self-evaluation. By March 16, 2012 submit to the Department a copy of the district’s institutional self-evaluation. Progress Report Due Date(s): November 1, 2011 and March 16, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 26A Confidentiality and Rating: Partially Implemented student records Department CPR Finding: Student record review indicated that the records of English language learners contained other students’ information. Narrative Description of Corrective Action: The District will review all records of ELL students to make sure that all information in the records pertains only to that individual student. Principals, ELL staff, and other individuals responsible for student records will be notified of the need for confidentiality and accuracy of student records. This information will be discussed at meetings with the principals, assistant principals, etc. and noted in their minutes. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 23 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Administration, Corrective Action Activity: September 2011 Curriculum & Grants Evidence of Completion of the Corrective Action: The files of all ELL students will contain only information pertaining to the selected student Description of Internal Monitoring Procedures: Periodic checks of the ELL files in each building will be conducted by the Director of Administration Curriculum and Grants CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 26A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By November 1, 2011, provide evidence of a review of records for misfiled information. Report on the number of records reviewed, how many were found in compliance, and actions taken to remedy any identified non-compliance. Progress Report Due Date(s): November 1, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 24 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Bridgewater-Raynham Regional School District Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Donna Dixon Paolini 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: May 25, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 3 Initial Identification Rating: Partially Implemented Department CPR Finding: Documentation and interviews indicate that the home language survey is in English only and student records indicate that parents are often not completing all sections of the form so that students who may require initial identification assessments are not always identified. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 25 Narrative Description of Corrective Action: Under the direction of the Dir of Admin, Curriculum, Grants , and ELL Programming, several steps have been enacted to ensure a more effective identification process. These include the following activities: 1. The home language survey will be distributed to all families for completion. Translated version of the survey will also be made available, when needed as will translators. 2. The elem. School secretary or secondary guidance counselor and the school principal will review each Home Language Survey. A copy of any Home Language Survey that indicated that a language other than or in addition to English is spoken will be sent to the Dir of Admin, Curr, Grants, ELL. In addition a copy will be placed in the ELE folder in each student’s cumulative record. 3. The director will perform 4 duties to ensure that the initial testing is completed properly: a. translators will be secured when the need for a translator is indicated. B. the director or designee will assign identification testing to be completed by the district’s ESL teacher(s) C. the director and/or ESL teacher(s) will review all of the identification testing and findings D. the director will work closely with the ESL staff and school principals to ensure that students are properly identified, parents are informed of the findings, recommendation and their rights, and that appropriate services are provided. 4. The district’s parents/guardians will be informed about the initial assessment process. We have created a procedure and documents book for this purpose. These may be found in the Process for Identifying English Language Learners section of the ELE program booklet. (this booklet is being sent under separate cover) a. Testing Instruments and Process: under the direction of the Dir.of Admin, Curr, Grants & ELL, trained professional ESL teaching staff will provide initial assessment. The assessments include the IDEA Proficiency Test, an English proficiency test of listening, speaking, reading and writing. In addition, any future changes in testing protocols that are required by DESE will be implemented. B. A student will be assessed during hi/her first 5 days of school when it is indicated on the Home Language Survey that a language other than English is used or when a teacher believes that a students might be an ELL. A determination as to whether the student is or is not an ELL will be made at this time. Details about identification procedures may be found in the ELE program booklet. C. Testing will be documented on the form entitled Bridgewater Raynham Regional School District ELL Assessment Form. A copy of this form may be found in the ELE program booklet. D. Parents will be informed about identification testing and recommendations and their right to apply for a waiver and to opt out. See program booklet. 5. Registration procedure for identified ELL: An ELL and his/her/parent/guardian will be afforded every opportunity to understand Bridgewater Raynham’s registration process and to become active members of the BR student and parent community. 6. Translators will be employed when there is a parent/guardian or student who cannot communicate effectively in English. 7. As a corrective action, during the summer months, the Director with support from school secretaries and guidance counselors will also: A. review all previously identified ELL as well as every student record to ensure that the Home Language Surveys are completed and that any student whose parents indicated that they speak a language other than or in addition to English is tested during the first week of the 2011-12 school year to determine if he/she is an ELL. B. Follow step #4 in this section C. Furnish parents of students who previously enrolled and were not tested, with a letter indicating that their child will be assessed during the first five days of school. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin, Curriculum & Corrective Action Activity: Sept 9, 2011 Grants Evidence of Completion of the Corrective Action: Students will be assessed during the first 5 days of school and identified appropriately. Documentation of this will be in the student folders and also copies will be filed with the Dir of Admin, Curriculum & Grants. Refer to ELE booklet for district’s process and plans Description of Internal Monitoring Procedures: Periodically there will be a review with the building administrators and ELL staff of students in the program. A periodic review of all student folders will also take place and corrective action will be taken if needed . CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 3 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By January 27, 2012 submit sample home language surveys translated into the major languages of the district. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 26 By a Date to Be Determined (pending review of the first Progress Reports) provide evidence of a review of student records for completed home language surveys. Report the number of records reviewed, the number in compliance, and actions taken to remedy any identified non-compliance. Progress Report Due Date(s): January 27, 2012 and TBD COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 4 Waiver Procedures Rating: Partially Implemented Department CPR Finding: Documentation and student records indicate that parents are not informed of their right to apply for a waiver. Narrative Description of Corrective Action: The district has developed procedure that ensure that parents are informed about their child’s identification and annual assessment findings and recommendations as well as their right to “opt out” and for a waiver for alternative programming. The Dir of Admin, Curriculum & Grants will ensure that a letter is sent to parents informing them of their rights. The director will also ensure that a translated version of the letter is sent to the parents that indicate that this is needed. The director, school principal and ESL teacher wil review the outcomes of all parent letters and note whether parents request a waiver or opt their child out of the programming. Title/Role of Person(s) Responsible for Implementation: Dir of Admin,Curriculum & Grants, Expected Date of Completion for Each Corrective Action Activity: September 2011 principals, ESL staff Evidence of Completion of the Corrective Action: Review of the students folders and conversations with building administrators/ESL staff Description of Internal Monitoring Procedures: On an annual basis, a review of the outcomes of these recommendations will be conducted and modifications will be made where needed. For example, if there is a trend in parents requesting that theyopt out their child or request a waiver, we will convene a study group to consider the reasons why parents are engaging in these outcomes. The study group would consist of the Director, principal, ESL staff and parents of ELL’s to determine next steps for strengthening the ELL programming and considering any parent concerns CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 4 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): See ELE 10 Progress Report Due Date(s): See ELE 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 Program Placement and Structure Rating: Partially Implemented MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 27 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 make the subject matter concepts comprehensible while promoting the LEP students’ English language development. Bridgewater-Raynham Regional is a low incidence district. In documents submitted, the district reports between 22 – 27 English Language Learners (ELLs) enrolled. A SIMS report submitted shows that about a third of the students (7) should be receiving sheltered content instruction. However, documents show that ELLs are not receiving sheltered content instruction, as the majority of teachers instructing ELLs have not completed all of the required training in all four categories of SEI professional development; such training focuses on the skills and knowledge necessary for sheltering instruction as described in the Commissioner’s Memorandum of June 2004. In the elementary schools, some teachers have completed Categories 1 and 2, in middle school only one teacher has completed Category 1; and in high school three teachers have completed Category 4. The district did not submit an ESL curriculum, therefore, the district did not document that the ESL curriculum is based on the Massachusetts Curriculum Frameworks. Documents submitted show that ELLs are not receiving sufficient hours of ESL instruction for levels 1-3 in both elementary and middle schools and levels 1-2 in high school; for all other levels the district meets the minimum requirements, consistent with the recommended hours as outlined in the Department’s 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 ELLs to succeed, it is critical they receive adequate number of hours of ESL instruction. Due to the lack of classroom teachers who are appropriately trained to shelter content and the lack of appropriate levels of ESL instruction provided to ELL students, the district is not offering a program that meets the requirements of Chapter 71A. Narrative Description of Corrective Action: The Dir of Admin,Curriculum& Grants will work with school principals, guidance counselor and ESL staff to ensure that the following activities are completed by May 25, 2012 in addition to the ones described in sections ELE 3 and 4 in this corrective action response. There are 5 levels of ESL instruction provided by the BRRSD: 1. Beginner 2. Advanced beginner 3. Early intermediate 4. Intermediate and 5. Transitioning. These levels parallel the MA DESE document Guidance on Using MEPA results to plan Sheltered English Immersion Instruction and Make Reclassification Decisions for Limited English Proficienct Students and are fully described in the BRRSD ELE program booklet. Every identified ELL is assigned one of these 5 ESL levels. Every identified ELL is provided with a program of study in English that addressed their particular English learning needs. We have an inclusionary program whereby ELL are placed in content classes with native speakers of American English. In these classrooms lessons are planned that are: 1. Appropriate for ELL’s at all level of proficiency 2. Aligned with the MA Frameworks and ELPBO. Our goal is to provide students with a program of study that is inclusive of all of the BRRSD’s students and that honors their various language and cultural experiences. Students progress from one level to the next as they acquire more proficiency in English. Progress is determined through the use of various assessments including student performance in class, on the IPT, MEPA and MCAS. In addition, students are provided with instruction in ESL until they are proficient in English in the the areas of listening, speaking, reading and writing at which time they are transitioned to grade level English instructed classed that do not use a sheltered English immersion approach to instruction. Title/Role of Person(s) Responsible for Implementation: Dir of Admin, Curriculum & Grants Expected Date of Completion for Each Corrective Action Activity: May 25, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 28 Evidence of Completion of the Corrective Action: There will be a written comprehensive curriculum in documented form. Student schedules will be reflective of their proficiency levels and data from various assessments will show student progress. Description of Internal Monitoring Procedures: Documentation of student work, conversations with the ESL staff and administration as well as with teaching staff to maintain student progress. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval Although the district was responsive to the Department’s comment concerning issues in Program Placement and Structure (submission of content-based ESL Curriculum, adequate hours of instruction consistent with the MEPA levels of English proficiency, and SEI category training), it did so in an unsystematic manner. The district referenced the submission of a written comprehensive curriculum (see Evidence of Completion of the Corrective Action section), but did not specify that it must be a content-based ESL curriculum. The district should note that the ELPBO will be phased out in the coming months, and any curricula development designed for ELLs that the district engages in going forward should be able to stand alone and be able to withstand changes as requested by the Department The provision of hours of instruction that are consistent with the students’ MEPA levels of English proficiency were specified in ELE 9 (Instructional grouping), instead of in this section. The provision of SEI category training for the teaching staff must be embedded in a long term plan to ensure compliance (see ELE 15 for additional comments on Professional Development). Department Order of Corrective Action: Please submit the following: Content-based ESL curriculum Evidence that students at all English proficiency levels and grade levels are receiving hours of instruction that are consistent with the Department’s recommended hours of instruction. Evidence that ELE students are placed with teachers who are qualified –who have completed SEI Category training. Institute internal monitoring procedures that include the following and take place minimally on a semiannual basis: Hours of ESL instruction services for all ELLs that are consistent with students’ English proficiency levels. Teachers providing content instruction to ELLs are trained in SEI. Students are grouped by similar English proficiency levels when receiving ESL/ELD instruction. Teachers complete all SEI Category trainings. ESL curriculum is implemented. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 29 Required Elements of Progress Report(s): Please submit the following by January 27, 2012: Progress to date on the development of an ESL curriculum. A spreadsheet listing ELE students in each school along with their level of English proficiency and corresponding hours of instruction Samples of ELL schedules: 5 schedules of ELLs in the elementary grades; 5 in middle school, and 5 schedules of ELLs in high school. Summary of findings resulting from internal monitoring and actions taken to remedy any noncompliance issues. Please submit the following by a Date to Be Determined A complete ESL curriculum for all grades. Progress Report Due Date(s): January 27, 2012 and TBD COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 9 Instructional Grouping Rating: Partially Implemented Department CPR Finding: From the documentation submitted, it could not be determined how ELLs are grouped to receive ESL instruction. Narrative Description of Corrective Action: The Dir of Admin, Curriculum & Grants will oversee the process by which teachers are trained to provide lessons thar are specifically designed for the teaching of English and content. In accordance with DESE Guidance for Planning Sheltered English Immersion Instruction, the following number of hours for instruction will be provided: Level 1 beginner and Level 2 Advanced beginner 2.5 hours/day Level 3 early intermediate 1-2 hours/day Level 4 intermediate and level 5 transitioning 2.5 hours/week Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin, Curriculum & Corrective Action Activity: May 25, 2012 Grants, building principals, ESL staff Evidence of Completion of the Corrective Action: Student schedules and staff schedules will reflect the appropriate times Description of Internal Monitoring Procedures: A review by the Dir of Admin, Curriculum & Grants along with the ESL staff periodically during the school year to make sure that all students are progressing and receiving the correct amount of service delivery time. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 9 Status of Corrective Action: Approved Partially Approved MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan Disapproved 30 Basis for Partial Approval or Disapproval: The district does not specify if or how English language learners are grouped to receive ESL/ELD instruction. Concerning instructional groupings, the district should note that for any grouping of ELLs in the teaching of ESL, the student’s English proficiency level must be considered. For instance, the district can mix students by grade levels, but care must be taken that the students’ English proficiency levels are similar. For example, ELLs in levels 1 and 2 can be grouped together as well as ELLs in levels 4 and 5. However, ELLs in level 3 should be mixed only with other level 3 English proficient students. Thus, the district can mix students by up to three grade levels as long as long as students’ levels of English proficiency are similar. Other factors could also be considered for grouping ELLs, such as the students’ maturity, literacy levels, and/or cultural backgrounds. Department Order of Corrective Action: Please provide the following: Evidence of appropriate grouping of students (English proficiency level or mixed grades and similar English proficiency level) ELL student and staff schedules Required Elements of Progress Report(s): Please submit the following by January 27, 2012: An Excel spreadsheet listing ESL services (individual or group) ELLs are receiving, as well as their grades and English proficiency levels. Provide three to five samples of student group schedules and name(s) of ESL staff. Include group(s) in the early grades, middle school, and high school. See ELE 5 for comments on internal monitoring. Progress Report Due Date: January 27, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 10 Parental Notification Rating: Partially Implemented Department CPR Finding: Documentation indicates that the parent notification letter does not include the parent’s right to apply for a waiver, the reasons for identification of the student as LEP, and is in English only. Narrative Description of Corrective Action: School principals, guidance counselors and ELE staff will work with the Dir of Admin, Curriculum & Grants to ensure that parents are informed about their child’s education and participation in school related activities. The district has revised the current letter to provide the appropriate language. We have created policies and procedures to address these and they may be found in the ELE program booklet. Additional responses may be found in ELE Corrective Responses #3 and #4 found in this document. Title/Role of Person(s) Responsible for Implementation: Dir of Admin,Curriculum & Grants Expected Date of Completion for Each Corrective Action Activity: September 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 31 Evidence of Completion of the Corrective Action: Corrected notification letter and copies in various languages Description of Internal Monitoring Procedures: Periodic review of the students files, conversations with the ESL staff and surveys of parents CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By January 27, 2012 submit a copy of the revised parent notification letter and a sample of letters translated into the major languages of the district. Progress Report Due Date(s): January 27, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal Access to Academic Programs and Services Rating: Partially Implemented Department CPR Finding: A review of the documentation indicated that classroom teachers are not sufficiently trained in sheltering English content. Therefore, students with limited English proficiency are not taught to the same academic standards and curriculum as all students and are not provided with the same opportunities to master such standards. In addition, information in notices such as activities, responsibilities, and academic standards provided to all students is not consistently provided to students with limited English proficiency in a language and mode of communication that they understand. Narrative Description of Corrective Action: The BRRSD has created policies and procedures regarding the rights of English Language Learners to having equal access to academic programming. These are fully described in the Corrective Action responses provided in this document, specifically ELE response 3 and 4 and included in the program booklet. Included in these responses and policies is information about translators and translated services. In addition, the classroom environment for instruction in ESL will be comparable to that of general education programming. Sheltered content instruction in math, science/technology, social studies/US history will be in the general education classroom with teachers that have been trained in sheltered instruction. Title/Role of Person(s) Responsible for Implementation: Dir of Admin, Curriculum, & Grants Expected Date of Completion for Each Corrective Action Activity: September 2011 Evidence of Completion of the Corrective Action: All student schedules will reflect the appropriate programming. Documentation will be in student folders for translators and translations if necessary Description of Internal Monitoring Procedures: Periodic review of student records and minutes of meetings with ESL staff reminding them of these procedures CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 11 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district submitted the procedures for obtaining a translator for parents who require such services. The district did not indicate how information in notices would be provided to students with limited English proficiency in a language and mode of MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 32 communication that they understand. Department Order of Corrective Action: Develop procedures for ensuring that students with limited English proficiency receive information on academic programs and services in a language and mode of communication that they understand. Required Elements of Progress Report(s): By January 27, 2012 submit the procedures for the provision of information in notices, such as activities, responsibilities, and academic standards, to students with limited English proficiency in a language and mode of communication that they understand. See ELE 15 regarding SEI professional development. Progress Report Due Date: January 27, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 12 Equal Access to Nonacademic and Extracurricular Programs Rating: Partially Implemented Department CPR Finding: Although documentation of procedures indicates that interpreters would be provided to inform a student about nonacademic and extracurricular programs, interviews and student records indicate that interpreters and translated notices are not provided to inform limited English proficient students about these opportunities. Narrative Description of Corrective Action: The BRRSD has created policies and procedures regarding the rights of ELL’s to having equal access to this programming. These are fully described in the Corrective Action responses provided in this document, specifically ELE 3 and 4 and included in the ELE program booklet. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin, Curriculum & Corrective Action Activity: Sept 2011 Grants/ESL staff Evidence of Completion of the Corrective Action: Student schedules will be reflective of the appropriate programming. Documentation will be evident in the student folders. Description of Internal Monitoring Procedures: Periodic review of student schedules as well as documented meeting minutes with ESL staff to make sure all students have equal access and opportunity CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 12 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district submitted procedures for obtaining a translator for parents who require such services. The district did not indicate how information in notices would be provided to students with limited English proficiency in a language and mode of communication that they understand. Department Order of Corrective Action: Develop procedures for ensuring that students with limited English proficiency receive information on nonacademic and extracurricular programs in a language and mode of communication that they understand. Required Elements of Progress Report(s): By January 27, 2012 submit the procedures for the provision of information about nonacademic and extracurricular programs to students with limited English proficiency in a language and mode of communication that they understand. By a Date to Be Determined submit the results of a review of records of limited English proficient students who require interpreting services. Report how many records were reviewed, how many were MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 33 found in compliance with evidence of interpreter services, and actions taken to remedy any identified non-compliance. Progress Report Due Date(s): January 27, 2012 and TBD COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 13 Follow-up Support Rating: Partially Implemented Department CPR Finding: Documentation indicates that procedures are in place to monitor students who have exited the English learner education program for two years, however, the student record review did not contain evidence of monitoring activities. Narrative Description of Corrective Action: Procedures have been established in the ELE program booklet in the section entitled Monitor Procedures for Former English Language Learners. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin, Curriculum & Corrective Action Activity: May 25, 2012 Grants Evidence of Completion of the Corrective Action: Documentation of student records Description of Internal Monitoring Procedures: Before Oct 1 of each school year, the Director will assemble a master list of students that have been reclassified. This will include ELL’s that were reclassified during the past 2 years. 2. A monitor process will be enacted for these students and include the following activities; a. each school principal and ESL teacher will be given a copy of the master list of reclassified students b. data about reclassification will be included in the district’s data programming system (Rediker) c. principals or designees will disseminate the monitor forms found in the ELE booklet to the ELA, math, science and social studies teachers of all reclassified ELL’s d. teachers will complete the monitor form according to the schedule detailed in the ELE booklet. When it is complete, it will be furnished to the ESL teacher who will make 2 copies, one for the principal and the second for the director e. any student who is not performing successfully will be reevaluated to determine if they are an ELL and should continue to receive ELE programming. In the event that this occurs, ELE services will be recommended to parents, the student will be reidentified as an ELL, MEPA testing will resume and when a student exhibits proficiency in English, he/she will be reclassified as a former ELL CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 13 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By January 27, 2012 submit a copy of the monitoring form. By a Date to Be Determined, provide evidence of a review of records of formerly limited English proficient students. Report the number of records reviewed, the number in compliance with evidence of monitoring activities, and actions taken to remedy any identified non-compliance. Progress Report Due Date(s): January 27, 2012 and TBD MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 34 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 14 Licensure Requirements Rating: Partially Implemented Department CPR Finding: Although the district documented two ESL teachers licensed in ESL (5-12 and 7-12 grade levels), neither of them is licensed to teach ESL at the elementary grade levels. Narrative Description of Corrective Action: BRRSD teachers of English Language learners will obtain the requisite licensure to teach at all levels Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin, Curriculum & Corrective Action Activity: Sept 2011 Grants Evidence of Completion of the Corrective Action: appropriate DESE licensure Description of Internal Monitoring Procedures: annual review of license status CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 14 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): No additional documentation needed. Progress Report Due Date(s): None COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Development Requirements Rating: Partially Implemented Department CPR Finding: See ELE 5 concerning professional development training in the 4 categories of SEI. Narrative Description of Corrective Action: The district will provide ongoing professional development for all staff members through the utilization of the Center for English Language Education at the Hampshire Educational Collaborative and other collaborative. Training will be offered in Categories 1, 2, 3, and 4 during the academic year. We are making every effort to build capacity within this time period. Further, as required by the MADESE, two licensed ESL teachers will provide our ELL students with instruction in English. It is our intent that we will have teachers of math, science, and social studies traing as soon as possible. Title/Role of Person(s) Responsible for Implementation: Dir of Admin, Curriculum & Grants Expected Date of Completion for Each Corrective Action Activity: May 25, 2012 Evidence of Completion of the Corrective Action: Documentation in staff files of professional development activities MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 35 Description of Internal Monitoring Procedures: The Dir of Admin, Curriculum & Grants will monitor staff members taking part in professional development activities and maintain appropriate records. Professional staff will have discussions with those members participating in these activities. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 15 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district intends to provide ongoing professional development for all teaching staff through a Collaborative; however, the district did not submit a long-term plan to ensure that all teachers working with ELLs are indeed trained. The district should note that the Department will be phasing out the MELA-O, therefore the district is required to have only sufficient numbers of trained MELA-O staff to meet the assessment needs of current and incoming ELLs, but is no longer required to train all teachers in Category 3. The district should continue to train teachers in Categories 1, 2 and 4. Department Order of Corrective Action: Please submit the following; A two-year SEI category training plan specifying timelines for the district to have qualified teachers to provide sheltered content to ELL students. Evidence that teachers are being trained in the required SEI categories. Samples of students’ schedules showing placement with content area teachers who are SEI trained. Required Elements of Progress Report(s): Please submit the following by January 27, 2012 and an update by a Date to Be Determined: 1) A long-term plan to provide SEI professional development training to all staff, starting with teachers who have ELLs placed in their classroom. 2) A spreadsheet listing SEI categories and dates teachers received their training. Organize spreadsheet by schools and grade level (elementary, middle and high school). Please specify the teachers’ content areas in the upper grades. 3) Samples of student schedules that show their placement with SEI trained teachers: five samples from the early grades, three from the middle grades and three from high school. 4) See ELE 5 for comments on internal monitoring. Progress Report Due Date(s): January 27, 2012 and TBD MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 36 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 17 Program Evaluation Rating: Partially Implemented Department CPR Finding: Documentation indicates that a survey has been developed to gather information regarding the ELE program, but documentation and interviews indicate that the district has not as yet collected and analyzed information to complete an evaluation of the effectiveness of the program. Narrative Description of Corrective Action: Each fall and spring the Dir of Admin, Curriculum & Grants will meet with ESL staff and school principals to review ELL’s performance on: a. progress reports b. report cards c. two year monitor report of former ELL’s d. district annual testing used to measure student’s English proficiency (IPT testing) e. state wide assessments including the MEPA and MCAS The review will include an analysis of individual as well as groups of students to determine the effectiveness of the program. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dir of Admin Curriculum & Corrective Action Activity: May 25, 2012 Grants Evidence of Completion of the Corrective Action: survey results and additions and/or modifications to the current program Description of Internal Monitoring Procedures: Discussion of the results of the evaluation with District entities to ensure that all constituents have a voice. This will provide the opportunity again for additions or modifications to the program CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 17 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By a Date to Be Determined (second set of Progress Reports) submit a copy of the district’s evaluation of the effectiveness of its ELE program. Progress Report Due Date: TBD MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 37 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 Records of LEP Students Rating: Partially Implemented Department CPR Finding: The student record review indicates that student records were missing some or all of the following elements: MCAS, MEPA and MELA-O results Home language survey Evidence of follow-up monitoring, where applicable. Narrative Description of Corrective Action: Records will be maintained for every identified ELL and former ELL. These will be housed in 2 areas; copies of all records will be kept in the office of the Dir of Admin, Curriculum & Grants. In addition, these will e filed in a designated ELE folder in each student’s cumulative records. The Process and procedures for this record keeping may be found in the BRRSD ELE booklet. Individual student success plans and EPP plans for students who have failed the MCAS will also be included. Title/Role of Person(s) Responsible for Implementation: Dir of Admin, Curriculum & Grants Expected Date of Completion for Each Corrective Action Activity: Sept 2011 Evidence of Completion of the Corrective Action: Student files are properly kept and the appropriate forms are in them Description of Internal Monitoring Procedures: Periodic checks by the Dir of Admin, Curriculum & Grants as well as periodic notices to ESL staff reminding them of the materials that should be filed CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 18 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By January 27, 2012 provide the results of a review of records for all required elements. Report the number of records reviewed, the number in compliance, and actions taken to remedy any identified non-compliance. Progress Report Due Date: January 27, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Bridgewater-Raynham CPR Corrective Action Plan 38