MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Chelsea CPR Onsite Year: 2009-2010 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 04/05/2011. Mandatory One-Year Compliance Date: 04/05/2012 Summary of Required Corrective Action Plans in this Report Criterion SE 3 SE 6 Criterion Title Special requirements for determination of specific learning disability Determination of transition services SE 13 Progress Reports and content SE 14 Review and revision of IEPs SE 17 SE 18A Initiation of services at age three and Early Intervention transition procedures IEP development and content SE 18B Determination of placement; provision of IEP to parent CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 19 Criterion Title Extended evaluation SE 22 IEP implementation and availability SE 24 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 Parental consent SE 25 SE 29 SE 43 SE 46 Communications are in English and primary language of home Behavioral interventions SE 51 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 Appropriate special education teacher licensure SE 53 Use of paraprofessionals SE 55 Special education facilities and classrooms CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 3 Special requirements for determination of specific learning Partially Implemented disability Department CPR Findings: Student records and staff interviews indicated that the district does not consistently complete all of the required specific learning disability determination forms for students suspected of having a specific learning disability. Description of Corrective Action: The district will conduct a training with all team chairs to review the use of the required specific learning disability forms. The district will conduct a follow-up administrative review, i.e. random sampling. Anticipated Results: The district will complete all of the required SLD determination forms for all students who are suspected of having a specific learning disability. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct & submit evidence of training on the above SE Criterion #3 (dated agenda, attendance sheet). The district will conduct random reviews of files of students who were suspected of having SLD (between April - September 2011). It will submit: (1) the number of records reviewed, (2) the number of records that were consistent with the criterion, (3) a description of further steps to be taken if non compliance is found. Description of Internal Monitoring Procedures: The district will conduct biannual reviews of student files for compliance of the above SE Criterion #3 in June 2011 and again in September 2011. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 3 Special requirements for Status Date: 04/22/2011 determination of specific learning disability Basis for Partial Approval or Disapproval: The district will provide Team Chairs with training on completing the SLD forms for eligibility determination of any student suspected of having a learning disability. An administrative review will be conducted to determine whether the SLD forms are completed. The administrative review report will identify the number of records reviewed at each level, the root cause of any non-compliance and the steps the district will take to reach compliance. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide a copy of the training agenda, date(s) the training was MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 3 conducted and the sign-in sheet with staff person's title/role. By October 26, 2011, conduct an administrative review of a sampling of student records to determine whether all the requirements including parent signature have been completed and are on file. Submit the results of the review including the number of students evaluated and suspected of having a SLD subsequent to staff training, the number of records in compliance and for all records not in compliance, indicate the root cause(s) of the noncompliance and provide the specific corrective action taken with regard to each file. *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 6 Determination of transition services Partially Implemented Department CPR Findings: Student records and staff interviews indicated that at the high school level transition planning forms are not always reviewed and updated annually as required. Description of Corrective Action: The district will conduct a training of SE Criterion #6 with the high school special education staff so that transition planning forms are reviewed and updated annually. The district will conduct a follow-up administrative review, i.e. random record sampling. Anticipated Results: The district will review and update all high school transition planning forms on an annual basis. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training on the above SE Criterion # 6 (dated agenda, attendance sheet). The district will conduct random reviews of files of high school students who have team meetings between April-September 2011. It will submit: (1) the number of records reviewed, (2) the number of records that were consistent with the criterion, (3) a description of further steps if noncompliance is found. Description of Internal Monitoring Procedures: The district will conduct biannual reviews of student files for compliance of the above SE Criterion #6 in June 2011 and again in October 2011. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 6 Determination of transition services Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district will train appropriate high school special education staff to update and complete the transition planning form (TPF) annually. The district will conduct an administrative review of high school student records to determine that the transition planning forms are updated and completed annually. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide a copy of the training agenda, date(s) the training was conducted and the sign-in sheet with staff person's title/role. By October 26, 2011, conduct an administrative review of high school records from each grade level for completed transition planning forms. Submit the results of the review of student records for compliance related to transition. Include the number of student MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 5 records reviewed, the number of records in compliance, and for all records not in compliance indicate the root cause(s) of the noncompliance and provide the specific corrective action taken with regard to each file. *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 13 Progress Reports and content Partially Implemented Department CPR Findings: Student records and staff interviews indicated that progress reports were not consistently written for each goal within a student’s IEP. Record review also demonstrated that progress reports are not always translated for parents with a primary language other than English. Additionally, students with IEPs who are at the Browne Middle School alternative program were not provided progress reports at all. Description of Corrective Action: The district will conduct a training with all special education staff to review SE Criterion #13 so that progress reports will be written for all goals within a student's IEP. The district will review with team chairs the policy to translate progress reports for parents whose primary language is other than English. The district will conduct a training with the Browne Alternative Program so that progress reports will be provided to all special education students who attend that program. Anticipated Results: All students in all programs will be provided with progress reports that address all goals with in their IEPs. Progress reports will be translated for parents with a primary language other than English. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training/review of the above SE Criterion #13 (dated agenda, attendance sheets). The district will conduct random reviews of student files for progress reporting periods in April and June 2011. It will submit: (1) the number of records reviewed, (2)the number of records that are consistent with the criterion, (3) a description of further steps to be taken if noncompliance is found. The district will track all progress reports that are translated for parents with a primary language other than English and compare these requests with the original IEP re: translation request. Description of Internal Monitoring Procedures: The district will conduct quarterly reviews of student files for compliance of the above SE Criterion #13 in April 2011, June 2011, October 2011, January 2012. If noncompliance is found, the root cause will be determined and additional trainings will be conducted to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 13 Progress Reports and content Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district will provide training to special education staff regarding progress reports and the translation of the progress reports. An administrative review will be conducted to determine whether progress reports are written for each goal on the IEP and that progress reports are translated for the parents who need translation. The district has developed an internal monitoring process to ensure compliance. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 7 Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide a copy of the training agenda, date(s) the training was conducted for special educators and related service staff for each building and the sign-in sheet with staff person's title/role. By October 26, 2011, conduct an administrative review of student records from each building for those students who had progress reports issued subsequent to staff training. Include the number of students who had progress reports issued for all IEP goals and translated, if appropriate, the number of records in compliance and for all records not in compliance indicate the root cause(s) of the noncompliance and provide the specific corrective action taken with regard to each file. *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: Student records and staff interviews indicated that the district did not consistently schedule IEP meetings on or before the anniversary date of the IEP, resulting in gaps between the end date of the last IEP and the start date for the new IEP. Description of Corrective Action: The district will conduct a training with all team chairs and clerks to review the procedures regarding the timely scheduling of IEP meetings to eliminate gaps between the end date of the last IEP and the start date of the new IEP. Anticipated Results: The district will consistently schedule IEP meetings on or before the anniversary date of the IEP. Title/Role(s) of responsible Persons: Expected Date of Special education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training on the above SE Criterion #14 (dated agenda, attendance sheet). The district will conduct random reviews of student records March - September 2011. It will submit: (1) the number of records reviewed, (2) the number of records that wee consistent with the criterion, (3) a description of further steps to be taken if noncompliance is found. Description of Internal Monitoring Procedures: The district will conduct biannual reviews of student files for compliance of the above SE Criterion #14 in the spring and early fall of 2011. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district will train special education Team Chairs and clerks to schedule IEP meetings on or before the anniversary date of the IEP. An administrative review of student records to determine whether IEPs are held before the anniversary date of the IEP will be conducted. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide a copy of the training agenda, date(s) the training was conducted and the sign-in sheet with staff person's title/role. By October 26, 2011, conduct an administrative review of student records for compliance related to IEP timelines. Include the number of students who are/were scheduled for an MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 9 IEP meeting since the training, the number of records in compliance and for all records not in compliance indicate the root cause(s) of the noncompliance and provide the specific corrective action taken with regard to each file. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address 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: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 17 Initiation of services at age three and Early Intervention Partially Implemented transition procedures Department CPR Findings: Student records indicated that the district accepts referrals from early intervention when a child is two and a half years old, however the district does not consistently complete the evaluation and eligibility determination process by the child’s third birthday. Additionally, staff interviews indicated that the district does not participate in transition planning conferences arranged by the early intervention program. Description of Corrective Action: The district will document the date a referral is received from the early intervention program as well as all attempts to contact the parent re: consent to evaluate and scheduling of evaluation appointments. The district will develop a procedure to ensure that evaluations and eligibility determinations as well as transition planning meetings are conducted in a timely manner: (1) EI will notify the Early Childhood Special Education Coordinator when they are referring a child. (2) The EC Sped Coordinator will confirm with the Parent Information Center (PIC) Director that the child will be registering. (3) EI will accompany the Parent to PIC to facilitate the registration process. (4) The EC Sped Coordinator will meet the with the parent and EI at PIC and based upon information provided by EI will obtain consent from the parent to begin the evaluation process. Anticipated Results: The district will complete the eligibility determination by the child's third birthday or provide detailed documentation as to efforts to do so. The district will continue to participate in transition planning meetings with the early intervention program. Title/Role(s) of responsible Persons: Expected Date of Special Education Director, Early Childhood Special Education Completion: Coordinator. 10/30/2011 Evidence of Completion of the Corrective Action: The district will submit evidence of implementation of the above SE Criterion #17 (dated referrals from EI, dated written notices sent to parents, documentation of other efforts to contact parents - phone calls, home visits, collaboration with EI caseworker). It will submit: (1) the number of records reviewed, (2) the number of records that were in compliance, (3) a description of further steps if noncompliance is found. The district will also document all meetings with EI for transition planning and will submit this schedule. Description of Internal Monitoring Procedures: The district will conduct biannual reviews of student files for compliance of the above SE Criterion # 17 in April 2011 and again in October 2011. If non compliance is found, the root cause will be determined and a review of policies and procedures will be conducted, amended as necessary, and more frequent administrative review will occur to ensure 100% compliance. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 11 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 17 Initiation of services at age three Approved and Early Intervention transition Status Date: 04/22/2011 procedures Basis for Partial Approval or Disapproval: The district needs to train early childhood staff at the Parent Information Center (PIC) and at the Early Childhood Center on the procedures and timelines for early childhood. The district will coordinate with early intervention staff to participate in the 90 day transition meetings. Procedures will be developed to secure parental consent for evaluation at the time a parent registers with Parent Information Center so that children who are eligible will be served by their third birthday. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Provide training to appropriate staff on the transition meeting with early intervention and the procedures to meet the timelines to determine eligibility and have the IEP completed so the child can receive services by the third birthday. Required Elements of Progress Report(s): By May 25, 2010, provide a copy of the procedures for participation in early intervention transition meetings and evidence of training on early transitions and timelines, the training agenda, date(s) the training was conducted and the sign-in sheet with staff persons' title/role. By October 26, 2011, conduct an administrative review to determine whether transition meetings, held subsequent to the staff training, were attended by district personnel and whether the IEP's were completed by the third birthday. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address 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: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18A IEP development and content Partially Implemented Department CPR Findings: Student records and staff interviews demonstrated that IEPs are not consistently completed addressing all elements of the most current IEP format as required. Specifically, the Present Level of Performance B (PLEP B) page was inconsistently completed for students with age related issues, who are English language learners or that receive related services. Description of Corrective Action: The district will conduct a training with all team chairs to review the development of IEPs. Specifically the completion of the PLEP B page for students with age related issues, who are English language learners, or who receive related services. The district will conduct a follow-up administrative review, i.e.random sampling. Anticipated Results: The district will consistently complete all required elements of the IEP. The district will consistently complete PLEP B for students with age related issues, who are English language learners, or who receive related services. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training on the above SE Criterion #18A (dated agenda, attendance sheets). The district will conduct random reviews of files of students who have team meetings between April-September 2011. It will submit: (1) the number of records reviewed, (2) the number of records that were consistent with the criterion, (3) a description of further steps if noncompliance is found. Description of Internal Monitoring Procedures: The district will conduct biannual reviews of student files for compliance of above SE Criterion #18A in June 2011 1nd again in October 2011. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18A IEP development and content Corrective Action Plan Status: Approved Status Date: 02/11/2011 Basis for Partial Approval or Disapproval: The district will train Team chairs to write a complete IEP with special attention directed to Present Level of Performance B (PLEP B). An administrative review of IEPs will be conducted. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011 provide evidence of IEP training for Team chairs that includes the attendance sheet with name, role and signature. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 13 By October 26, 2011, submit the results of an administrative review of student records for compliance related to complete IEPs. Indicate the number of records reviewed who had IEP's developed or reviewed post-training at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address 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: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 14 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18B Determination of placement; provision of IEP to parent Partially Implemented Department CPR Findings: Student records and staff interviews indicated that decisions regarding placement were not always based on student need, but rather availability of programming. Records demonstrated that in some instances students transitioning from elementary school to middle school or from middle school to high school received a more or less restrictive placement setting without reconvening the Team, providing notice to the parent or seeking consent for the change in placement. Also, student records and interviews indicated that immediately following the development of the IEP the district does not consistently provide parents with two copies of the proposed IEP, placement and notice as required. It was noted in some instances that there were delays of more than one month between the date of the Team meeting and the provision of the IEP to the parent. Description of Corrective Action: The district will conduct a a training with all team chairs to consider all aspects of the student's proposed special education program as specified in the student's IEP and determine the appropriate placement to provide the services. The placement decision will be based on the identified needs of the student as specified in the IEP, the types of services that are to be provided, the type of settings in which those services are to be provided, and the least restrictive environment consistent with the needs of the student. No changes in placement will be made without reconvening the team and obtaining parent consent. Since 2000, an IEP provided to the parent within 3-5 days of the Team meeting fulfills the requirement for "immediate" delivery of the IEP to the parent. At a minimum, the parents will leave the IEP development meeting with a "summary". This summary of the decisions and agreements reached during the Team meeting will include: (a) a completed services delivery grid describing the types and amounts of special education and/or related services proposed by the district, and (b) a statement of the major goal areas associated with these services. The district may then take no more than two calendar weeks to prepare the completed IEP for the parent's signature and for the student's records. Anticipated Results: The district will base placement decisions on student need. The district will determine all placement decisions in the context of a team meeting, provide notice to the parent, and seek consent for any change in placement. The district will provide parents with 2 copies of the proposed IEP, placement and notice as required under SE Criterion #18B. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training on the above SE Criterion #18B (dated agenda, attendance sheet). The district will conduct random reviews of files of students who have team meetings between April-September 2011. It will submit: (1)the number of records reviewed, (2) the number of records that were consistent with the criterion, (3) a description of further steps if noncompliance is found. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 15 Description of Internal Monitoring Procedures: The district will conduct biannual reviews of student files for compliance of above SE Criterion #18B in June 2011 and again in September 2011. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 18B Determination of placement; Status Date: 02/18/2011 provision of IEP to parent Basis for Partial Approval or Disapproval: The district provided procedures for determination of placement for eligible students. The timelines and procedures for placement will be reviewed with Team Chairs during a training session. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide evidence of training (agenda, attendance with name and role, and handouts) on placement and the provision of the IEP to parents. By October 26, 2011, conduct an administrative review of student records for compliance with placement and provision of the IEP to parents subsequent to staff training. Include records of students who are transitioning from elementary school to middle school or from middle school to high school. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing noncompliance and a description of additional corrective actions to be taken by the district to address 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: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 16 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 19 Extended evaluation Partially Implemented Department CPR Findings: Student records and staff interviews indicated that the district routinely proposes and places students in a 45 day interim alternative educational setting in the local collaborative program and considers these placements an extended evaluation. In these instances, parents are asked to sign a new consent for evaluation and revisit eligibility determination, however, it was noted that some records had no parental consent in place for the extended evaluation or placement with the collaborative program. Description of Corrective Action: The district will conduct a training with all team chairs to review: (1) the appropriate use of a 45 day interim alternative educational setting (2) the appropriate use of an extended evaluation period when evaluation information is inconclusive. Parent consent will be obtained for these proposed actions when either is deemed appropriate. Anticipated Results: The district will appropriately use the 45 day IAES for students who carry or possess a weapon on school premises, possess or use or sell illegal drugs on school premises,or inflict serious bodily injury upon another person. The district will appropriately use an extended evaluation period when evaluation information is not sufficient to identify some necessary objectives and services. In such cases, the team will write a partial IEP that, if accepted by the parent, will immediately be implemented while the extended evaluation is occurring. Parent consent will be obtained for all proposed evaluations or placement in an IAES. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training on the above SE Criterion #19 (dated agenda, attendance sheet). The district will conduct reviews of files of students who (1) participated in an extended evaluation, (2) were referred for placement in an IAES between February- October 2011. It will submit: (1) the number of records reviewed, (2) the number of records that wee consistent with the criterion, (3) a description of further steps if noncompliance is found. Description of Internal Monitoring Procedures: The district will conduct reviews of student files for compliance of above SE Criterion #19 in June 2011 and again in October 2011. If noncompliance is found, the root cause will be determined and additional trainings and more frequent administrative review will be conducted to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 19 Extended evaluation Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district will train Team Chairs on the appropriate use of the Interim Alternative Educational Setting (IAES) placement and the appropriate use and procedures for an MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 17 extended evaluation. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide evidence of training that includes the requirements for an Interim Alternative Educational Setting (IAES) and the revised procedures for an extended evaluation. Submit the agenda, the handouts and the attendance sheet with the date, names and roles by May 26, 2011. By October 26, 2011, conduct an administrative review of any IAES placements and any extended evaluations subsequent to staff training to determine whether appropriate procedures were followed. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing noncompliance and a description of additional corrective actions to be taken by the district to address 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: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 18 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 22 IEP implementation and availability Partially Implemented Department CPR Findings: Staff interviews indicated that at the high school alternative program, the general education teaching staff does not always have access to a student’s IEP, nor are they consistently informed of their specific responsibilities related to each student’s IEP implementation. Description of Corrective Action: As of August 2010 a full time special educator is assigned to the high school alternative program. She is the liaison between the special education department and the general education teaching staff. The district will review the effectiveness of her role by interviewing staff regarding their awareness of students' IEPs, their responsibilities related to IEP implementation, and the support provided by the special education teacher. Anticipated Results: All teachers who work with students in the high school alternative program have access to students' IEPs and are informed of their responsibilities related to implementation of each student's IEP. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will submit evidence of implementation of the above SE Criterion #22 (information from staff interviews / surveys). Documentation that they have received copies of all students' IEPs. Description of Internal Monitoring Procedures: The district will perform the above corrective action steps in March 2011 and October 2011. If noncompliance is found, the root cause will be determined and additional procedures detailing collaboration between the special education and general education staff will be implemented to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 22 IEP implementation and Status Date: 04/22/2011 availability Basis for Partial Approval or Disapproval: The district has added a full time special educator to the high school alternative program. The district also has a procedure in place at the high school to have teachers confirm their responsibilities for each IEP by documenting that they have reviewed and received the IEP. The district has a monitoring system in place for IEP implementation and availability. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide evidence of an orientation for the new special education teacher assigned to the alternative high school staff on the responsibilities for IEP implementation. Develop and provide a description of the district's internal monitoring process to ensure MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 19 compliance. By October 26, 2011, submit the results of a administrative review of the high school alternative program staff who have students with disabilities for compliance related to knowing their responsibilities for implementation of IEPs. Indicate the number of staff who indicated they had been informed of the needs of the students consistent with IEPs, and the number who indicated that they were not informed. Provide an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address 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: a) List of staff names with job title who were interviewed, b) Date of the interview(s); c) Name of person(s) who conducted the interviews, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 20 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 indicated that written notice is not consistently sent to a child’s parents within five school days of the receipt of the referral. Description of Corrective Action: The district will conduct a training with all team chairs to review the requirement to send a written notice to a child's parents within five days of the receipt of a referral. The district will document the date that a referral is received from a child's parents and the date of the written notice sent in response to the request. The district will conduct a follow-up administrative review, i.e. random sampling Anticipated Results: The district will consistently send a written notice to parent regarding the proposal or refusal to initiate or change the identification, or educational placement of the child or the provision of FAPE. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will submit evidence of implementation of the above SE Criterion #24 (dated agenda, attendance sheet). The district will conduct random reviews of tracking logs documenting the date such a referral was received and a copy of the written notice was sent to the parent. It will submit: (1) the number of tracking logs reviewed, (2) the number of records that were consistent with the criterion, (3) a description of further steps if noncompliance is found. Description of Internal Monitoring Procedures: The district will conduct a review of tracking logs for compliance of the above SE Criterion #24 in September 2011. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 24 Notice to parent regarding Status Date: 04/22/2011 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 provide training to Team Chairs regarding the notice and conduct an administrative review to determine compliance with the notice requirements. Department Order of Corrective Action: Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 21 By May 26, 2011, provide the evidence of training (agenda and attendance sheet that includes date, name, and role) on the provision of written notice five days after referral. By October 26, 2011, conduct an administrative review of student records who were provided notice, subsequent to staff training, five days after referral. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address any identified noncompliance. *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 22 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 25 Parental consent Partially Implemented Department CPR Findings: Student records and staff interviews indicated that the attempts to secure the consent of the parent are not implemented through multiple attempts using a variety of methods and are not consistently documented by the district. Description of Corrective Action: The district will review with team chairs and clerks the policy of documenting all attempts to secure the consent of the parent through a variety of methods. Anticipated Results: The district will consistently document the multiple attempts to secure the consent of the parent using a variety of methods. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training/review on the above SE Criterion #25 (dated agenda. attendance sheet). The district will conduct random reviews of student files. It will submit: Description of Internal Monitoring Procedures: The district will perform random reviews of student files in June 2011 and October 2011. If noncompliance is found, the root cause will be determined, training will be conducted, and additional administrative reviews will occur to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 25 Parental consent Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district will train Team Chairs to document the multiple attempts using a variety of methods to secure parental consent. A review of student records will be conducted by the district with additional administrative reviews to ensure 100% compliance. The plan for internal monitoring needs to be developed. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide agenda and attendance sheet for the training regarding a variety of methods to secure parental consent for evaluations and for IEPs and how to document the multiple attempts. Develop and describe the district's plan for ongoing monitoring to ensure compliance. By October 26, 2011, submit the results of an administrative review of student records for compliance related to securing parental consent. Indicate the number of records reviewed sebsequent to staff training at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address any identified noncompliance. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 23 *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 24 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 29 Communications are in English and primary language of Partially Implemented home Department CPR Findings: Student records and staff interviews indicated that languages other than Spanish and Portuguese are not always translated by the district. The district indicated that they perform many oral translations; however staff interviews indicated that oral translations are not consistently provided or documented. Description of Corrective Action: Please see CR7 for narrative description. Anticipated Results: The district will continue to provide oral translation whenever requested by the parent/guardian for primary languages other than English. Documentation will be oral translations logs maintained by each school. Title/Role(s) of responsible Persons: Expected Date of Special Education Director, ELL Director, or designee Completion: 06/30/2011 Evidence of Completion of the Corrective Action: The district will submit evidence of implementation of the above SE Criterion #29 (copies of contracts and copies of translation request forms). Description of Internal Monitoring Procedures: The district will conduct random auditing of procedures and protocols. If noncompliance is found, the root cause will be determined and procedures/protocols will be reviewed and edited if deemed necessary. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 29 Communications are in English and Approved primary language of home Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district needs to document written and oral translation for low incidence languages. Although the district provides oral translation, a system to document oral translations in individual student records is required. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide evidence of training to student record keepers and individuals who coordinate and document oral translations on the district's oral translation log and procedures for translation. Submit the evidence of training (agenda, oral translation log and attendance sheet). By October 26, 2011, conduct an internal monitoring of student records for students who received oral translation sevices subsequent to staff training. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address any identified non-compliance. Please submit this to the Department by October 26, 2011. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 25 *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 26 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 43 Behavioral interventions Partially Implemented Department CPR Findings: Student records, staff interviews and classroom observations indicated that staff members were not trained in conducting and interpreting functional behavioral assessments and developing positive behavioral intervention plans. Additionally, disabled students who are suspended at the high school are often placed in a more restrictive setting at the Shore Collaborative, instead of conducting a functional behavioral assessment and developing a positive behavioral intervention plan within the district settings. In these instances, the students were placed in what the district called an IAES placement at Shore Collaborative, even though the behavior would not warrant it and even though the practice is not consistent with federal requirements for the discipline of students with disabilities. Description of Corrective Action: (1) See SE #19 (2) On May 5, 2010 two school psychologists, one dean of students, and one special education team chair participated in a training on conducting FBAs. (3) The district has convened a committee to review FBA procedures and protocols and behavior intervention plans. (4)The district provided a PBIS overview to student support staff & all administrators in September 2010. Anticipated Results: The district will implement consistent procedures and protocols for conducting and interpreting FBAs and developing behavior intervention plans. As indicated in SE #19 the district no longer uses Shore Collaborative as an IAES for students whose behavior does not warrant this more restrictive setting. It is our goal to comply with the federal requirements for the discipline of students with disabilities. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will submit evidence of implementation of the above SE Criterion#43: copies of registrations for the FBA training, copies of agendas and attendance sheets for the PBIS overviews, copies of the district-wide procedures and protocols for FBAs and BIPs. Description of Internal Monitoring Procedures: The district will perform biannual reviews of student files in June 2011 and October 2011. If noncompliance is found, the root cause will be determined and a review the procedures and protocols will be conducted, amended if necessary, and more frequent administrative review will occur to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 43 Behavioral interventions Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district has proactively administered training on conducting functional behavioral assessments and will conduct training on the development of positive behavioral MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 27 intervention plans. See SE 19 for the requirements of IAES to which the district will adhere. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide the results of the committee's findings for FBAs and BIPs. Provide evidence of training (agenda, materials, attendance sheet with name and role) for appropriate staff on conducting FBAs and on the development of positive behavioral plans. By October 26, 2011, conduct administrative review of student records of students who, subsequent to staff training, were administered an FBA and/or had a BIP developed. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address any identified noncompliance. *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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 28 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: Student records and staff interviews indicated that students suspended in excess of 10 days receive special education services, but do not have access to the general curriculum. In addition, the district is using an interim alternative educational setting, specifically Shore Collaborative, not as specified by federal regulation for suspensions related to weapons, drugs, assault or dangerousness, but as an extended evaluation related to a variety of behavioral issue instead of conducting a functional behavior assessment within the district and developing a positive behavior intervention plan. Please see SE 43 for additional information. Description of Corrective Action: (1) See SE #43 (2) The district provides tutoring in all core curriculum to all students who are suspended in excess of 10 days. (3) The district will conduct a training for team chairs and deans to review SE Criterion #46 to ensure compliance with the 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. Anticipated Results: The district will comply with the federal regulations for disciplining students with disabilities (see SE #19 and SE #43). Students who are suspended in excess of 10 days will have access to the general curriculum. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee, Principals, Deans Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of trainings on the above SE Criterion #46 (dated agendas, attendance sheets). The district will submit lists of students who meet the above criteria along with documentation of the core content provided to them. Description of Internal Monitoring Procedures: The district will randomly review the tutoring file in the Sped/ Pupil Personnel Office for compliance with the above criterion. If noncompliance is found, the root cause will be determined and additional trainings will be conducted along with more frequent administrative review to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 46 Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed Corrective Action Plan Status: Approved Status Date: 04/22/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 29 for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Basis for Partial Approval or Disapproval: The district will provide training to Team Chairs and administrators regarding the suspension of students on IEPs. The use of an Interim Alternative Educational Setting will be limited to weapons, controlled substances and physical assaults. Subsequent to ten days of suspension, the district will provide tutoring for students to access the general curriculum AND the special education and related services on the IEP. The district has developed an internal monitoring process to ensure compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide evidence of training for administrators and Team Chairs on the requirements for suspension for more than 10 consecutive or cumulative days for tutoring and the provision of special education and related services for students on IEPs. Submit the evidence of training consisting of the agenda, attendance sheet with date, name, role and signature by May 26, 2011. By October 26, 2011, conduct an administrative review of student records, subsequent to staff training, for compliance with the requirements for access to the general curriculum and the special education and related services. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address 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: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 30 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 51 Appropriate special education teacher licensure Partially Implemented Department CPR Findings: Documentation indicated that not all special education teachers have a current license or waiver in place as required. Description of Corrective Action: At the time of the CPR there was one middle school Functional Academics teacher without a waiver/license. She has since received her license. Anticipated Results: All special education teachers will possess a current license or waiver. Title/Role(s) of responsible Persons: Expected Date of Director Of Human Resources, Director Of Special Education, Completion: Principals 03/01/2011 Evidence of Completion of the Corrective Action: Copy of current license. Description of Internal Monitoring Procedures: The Director of Human Resources will continue to maintain files and licenses of all special education teachers. She will continue to monitor any teachers who are on a waiver. If noncompliance is found, the teacher and principal will be contacted to document efforts to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 51 Appropriate special education Status Date: 04/22/2011 teacher licensure Basis for Partial Approval or Disapproval: The district will provide the license for the middle school teacher. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide a copy of the license for the middle school special education teacher. Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 31 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 53 Use of paraprofessionals Partially Implemented Department CPR Findings: Staff interviews indicated that some paraprofessionals are not aware of who is responsible for supervising them and in some instances were not aware of supervisors who would be available to them for support and guidance. Description of Corrective Action: The district will include in its annual paraprofessional training at the start of the school year the contractual information regarding the supervision of paraprofessionals by the building principal. They will also receive information on building/district supervisors who are available for any support/guidance that they may warrant. Anticipated Results: All paraprofessionals will be aware of who supervises and evaluates them as well as whom they may access for support in performing their assigned duties. Title/Role(s) of responsible Persons: Expected Date of Special Education Director or designee, Principals Completion: 10/30/2011 Evidence of Completion of the Corrective Action: The district will conduct and submit evidence of training on the above SE Criterion #53 (dated agenda, attendance sheets). Description of Internal Monitoring Procedures: The district will randomly interview paraprofessionals for compliance of the above SE Criterion #53 in the fall of 2011. If noncompliance is found, the root cause will be determined and targeted interventions will be conducted along with administrative followup to ensure 100% compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 53 Use of paraprofessionals Corrective Action Plan Status: Approved Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The district will train all paraprofessionals regarding supervision from the principal and from a special education teacher assigned for support and guidance. The district will randomly interview paraprofessionals in the fall of 2011. Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, submit the training agenda on supervision of paraprofessionals with agenda, attendance sheet with date, name and role. Provide a list of paraprofessionals and their supervising special education teacher. By October 26, 2011, submit the results of the paraprofessional interviews including the number interviewed, the number of interviews that indicated compliance, and for those found not in compliance indicate the root cause(s) of the noncompliance and provide the specific corrective action taken with regard to each paraprofessional. *Please note when conducting internal monitoring the district must maintain the following MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 32 documentation and make it available to the Department upon request: a) List of staff names with job title who were interviewed, b) Date of the interview(s); c) Name of person(s) who conducted the interviews, their role(s) and signature(s). Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 33 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 55 Special education facilities and classrooms Partially Implemented Department CPR Findings: Classroom observations and staff interviews indicated that there are signs posted identifying related services spaces within both the Hooks and Sokolowski Elementary Schools. Additionally at the Sokolowski Elementary School there is a resource room that is divided from another classroom by a shower curtain. Also the Functional Academics classroom, which serves students in grades 1-4 at Sokolowski Elementary School is located in the first grade wing and has materials and furniture that are unsuitable for older students receiving services there. This classroom contains preschool cube chairs and other items that do not meet the needs of the older students in the classroom and the older children have limited interaction with age appropriate peers. Observations at the Early Learning Center showed that the sub separate classroom (Room 218) for preschoolers is in the basement and is isolated from the life of school. At the high school, the special education post graduate program is located in a small room in the back of the special education administrative suite; it is isolated from the life of school and there were no instructional materials for students to access related to independent living or job skills. Description of Corrective Action: See CR #23 **Please note that there was no subseparate preschool classroom at ELC last year and room 218 is on the second floor. It has always been an integrated Kindergarten and it is in a wing with another integrated Kindergarten and with 6 other regular Kindergarten classrooms. There is no basement. Anticipated Results: All special education facilities and classrooms will comply with the above SE Criterion # 55. The high school post graduate program has been relocated to a classroom in the main hallway. Instructional materials related to independent living skills will be purchased in FY 12. Title/Role(s) of responsible Persons: Expected Date of Principals, Chief Finance Officer, Buildings Facilities Director, Completion: Special Education Director 10/30/2011 Evidence of Completion of the Corrective Action: Site Visit Description of Internal Monitoring Procedures: The district will submit evidence of compliance (i.e. Requisitions, purchase orders, work requests). CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 55 Special education facilities and Approved classrooms Status Date: 04/22/2011 Basis for Partial Approval or Disapproval: The signs indicating special education services will be removed and replaced with teacher/related service provider name and room number at Hooks and Sokolowski Elementary Schools. The plan did not address the Functional Academics classroom and MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 34 the resource room at Sokolowski Elementary School. The district proposed going beyond the one year timeline for corrective action if the budget does not allow for furniture expenses. All corrective action must be completed within one year from the date the Final Report for the CPR, December 13, 2011. The district also plans to move the post graduate classroom and to order supplies for independent living. Department Order of Corrective Action: The district must remove signs in order to minimize stigmatization of eligible students at the Hooks Elementary School and Sokolowski Elementary School. The resource room and the functional academics classroom at Sokolowski Elementary school should be equal in all physical respects to the average standards of general education facilities and classrooms and should minimize the stigmatization of eligible students. The high school post graduate program at the high school must be in a location that enhances opportunities for students to be part of the life of the school. Required Elements of Progress Report(s): By May 26, 2011, provide a copy of floor plans for the high school and Sokolowski Elementary School that indicate where classrooms were located and where they have been moved. By October 26, 2011, provide confirmation regarding a scheduled onsite visit by DESE to review signs, Hooks Elementary School, Sokolowski Elementary School and the High School. Progress Report Due Date(s): 05/26/2011 10/26/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 35 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Chelsea Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Chelsea/Donna Covino & Mary Grace Fusco 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: December 13, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 3 Access to a Full Range of Rating: Partially Implemented Educational Programs Department CPR Finding: At Browne Middle School, students with disabilities and English language learners who are placed in the alternative program did not receive Extended Learning Time support classes for reading and math as their typical peers at the middle school do. Staff interviews indicated that English language learners across the district were not referred to the Student Support Team and could not request an evaluation for special education for one year. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 36 Narrative Description of Corrective Action: The Browne Middle School day begins at 7:30 and ends at 3:30. All Browne Middle School students, including students with disabilities and English language learners, who need intervention support in math and reading receive this support during the day. The last period of the day is the student elective period. During this period, these students are integrated with their peers for electives. 1. Names of students with disabilities and English language learners in the alternative program who receive reading and math support will be submitted to the DESE. 2. Schedules of the aforementioned students will be provided. It has been district practice to provide students with an acculturation and acclimation period before requesting a SPED evaluation; however, any student who is experiencing difficulty can and should be referred to the student support team. 1. The policy and protocol for Student Support Team (SST) referral is currently under review. 2. The revised policy and protocol will be disseminated district-wide. 3. Documentation of efforts and implementation of SST recommendations will be reviewed for any student who is referred for a special education evaluation. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Deb McElroy, Principal in Corrective Action Activity: collaboration with Donna Covino, SPED February 1, 2011 Director, and Mary-Grace Fusco, ELL Coordinator Evidence of Completion of the Corrective Action: See above Description of Internal Monitoring Procedures: A quarterly review of schedules of these students will be conducted by persons responsible for implementation. Copy of revised SST policy. Random sampling of ELL students who are referred for a special education evaluation. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 3 Access to a Full Range of Educational Programs 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 May 26, 2011, provide the revised policy and protocol for the Student Support Teams and date for district-wide staff training regarding the revised policy and protocol. By October 26, 2011, submit the training agenda, handouts and attendance sheet with date, name and role for each building. Conduct an administrative review of a sampling of student schedules, for students with disabilities and English language learners at Browne Middle School who, subsequent to staff training, receive(d) Extended Learning Time support and were referred to the Student Support Team. Indicate the number of records reviewed at each level, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken by the district to address any identified non-compliance. *Please note when conducting internal monitoring the district must maintain the following MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 37 documentation and make it available to the Department upon request: a) List of student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): May 26, 2011 and October 26, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7 Information to be Translated Rating: Partially Implemented into Languages Other than English Department CPR Finding: Student records, documentation and staff interviews indicated that the district has most documents translated into Spanish; however parents and students who speak other languages such as Portuguese, Haitian or Chinese do not consistently receive printed translated materials or oral translations. Narrative Description of Corrective Action: The district contracts with Catholic Charities for oral translations for languages other than Spanish. Copies of translation requests are currently maintained by the ELL Coordinator. Contact information for translators in/out of the district will be updated annually and distributed to all schools. A committee will develop a log to document completed oral translations. This log will be maintained by each school. A committee will develop a translation request form to be included with all written materials sent to parents. These forms will be maintained by each school in a master file. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: School Principals and ELL Corrective Action Activity: June 30, 2011 Coordinator Evidence of Completion of the Corrective Action: Copies of contracts and forms. Description of Internal Monitoring Procedures: Random auditing of procedures and protocols. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7 Information to be Status of Corrective Action: Translated into Languages Other than Approved Partially Approved English Basis for Partial Approval or Disapproval: Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, provide training for appropriate staff at each school building regarding translation, filing oral translation logs and the list of translators. Submit the training agenda, handouts and attendance sheet with date, name and role for each building. By October 26, 2011, conduct an administrative review of translation logs from each building. Indicate the number of logs reviewed, the number found to be compliant, an explanation of the root cause for any continuing non-compliance and a description of additional corrective actions to be taken MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 38 by the district to address 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: a) List of buildings for the logs reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): May 26, 2011 and October 26, 2011. COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7B Structured Learning Time Rating: Partially Implemented Department CPR Finding: Documentation and staff interviews indicated that juniors and seniors in high school do not receive physical education every year as required by G.L. c. 71, s. 3. Narrative Description of Corrective Action: A course audit sheet has been drafted to document student fulfillment of the annual physical education requirement. An Addendum to PE requirements will be added to the 2011-2012 Course Catalog to include the following options: Regular Physical Education classes, Athletics, Cheerleading, Dance, Stay in Shape, Weight Training, etc. Documented participation in program/activity outside of school will also fulfill the PE requirement; such activity should require participation at a minimum equal to the attendance of one quarter. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal of Chelsea High Corrective Action Activity: School, School Registrar and CHS Guidance Audit sheet: February 28, 2011 Department. Participation Requirement September , 2011 Evidence of Completion of the Corrective Action: Completed Audit Sheets and revised course catalog. Description of Internal Monitoring Procedures: The CHS Guidance department will be responsible for tracking each student’s completion of physical education requirements annually for each of the four years as required by G.L.c.71, s.3 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7B Structured Learning Time 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 May 26, 2011, provide the procedures for documenting participation in a program/activity outside of school to fulfill the physical education requirement. Provide training to appropriate staff on the course audit sheet and the procedures for participation in outside of school programs and activities and submit the agenda and attendance sheet with date, name and role. Provide a copy of the pertinent sections of the high school’s Program of Studies for 2011-2012 regarding physical education requirements. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 39 By October 26, 2011, submit a letter of assurance from the Superintendent that states that the all students in the district receive physical education as required by G.L.c.71, s.3. Progress Report Due Date(s): May 26, 2011 and October 26, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 10A Student Handbooks and Rating: Partially Implemented Codes of Conduct Department CPR Finding: A review of documentation showed that the student handbooks do not provide appropriate procedures for the discipline of students with Section 504 Accommodation Plans. Additionally, the section on discipline for students with special needs indicates that if a manifestation determination results in suspension beyond the ten days, the student will receive special education services, however it does not reference how students will access the general education curriculum. See also SE 43. Narrative Description of Corrective Action: A committee will review, edit, and add appropriate procedures to handbooks relative to the discipline of students with Section 504 Accommodation Plans . Language particular to providing tutoring in core requirements of the curriculum to students with special needs who are suspended beyond ten (10) days will be articulated and added to the all handbooks. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Corrective Action Activity: Director/PPS Director, School Handbook June 2011 Committees, Principals Evidence of Completion of the Corrective Action: Copies of handbook pages documenting the above. Description of Internal Monitoring Procedures: Review additions to draft handbooks before printing and distribution. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 10A Student Handbooks and Codes of Conduct 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 May 26, 2011, provide a copy of the student handbook sections regarding the discipline of students with disabilities, including students on 504 Plans. Provide training to principals, assistant principals and appropriate special education staff on the revised discipline of students with disabilities section of the handbooks and procedures to ensure that general curriculum as well as special education services are provided for students with disabilities who are suspended beyond 10 days. Submit the agenda, handouts and attendance sheet with date, name, and role for each building. Progress Report Due Date(s): May 26, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 40 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 13 Availability of Information and Academic Counseling on General Curricular and Occupational/Vocational Opportunities Rating: Partially Implemented Department CPR Finding: Documentation and staff interviews indicated that the district offers limited opportunities for occupational/vocational courses. Additionally, the students who attend alternative programs at the middle and high school levels do not have access to orientations and information for the regional vocational school and have very limited access to occupational/vocational opportunities offered by the district. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 41 Narrative Description of Corrective Action: CR13 /SE 34 MA DESE Comment: Documentation and staff interviews indicated that the district offers limited opportunities for occupational/vocational courses. Additionally, the students who attend alternative programs at the middle and high school levels do not have access to orientations and information for the regional school and have very limited access to occupational/vocational opportunities offered by the district. The Chelsea Public Schools disagrees with MA DESE findings in Criterion Number 13. The Chelsea Public Schools is a member of the Northeast Metropolitan Regional Vocational School located in Wakefield, Massachusetts and founded in 1964. Because Chelsea Public Schools is a member of this regional school system, we are prohibited from replicating programs offered to our students at Northeast Regional Vocational School. FY10 budget documents 206 students from Chelsea receiving academic and vocational training in any number of the following: Automotive Collision Repair and Refinishing Automotive Technology Building and Grounds Maintenance Carpentry -Commercial Design Cosmetology Culinary Arts Dental Assistant Drafting & Design Early Childhood Education Electricity Graphic Communications Health Assistant HVAC/Refrigeration Metal Fabrication Office Technology Plumbing & Pipefitting Telecommunications Electronics Academic, vocational, and career programs offered at Chelsea High School and not offered at Northeast Vocational Regional School include courses in our Commerce and Technology Department: Basic Computer Skills Keyboarding Word Processing Presentations Spreadsheet/Database Desktop Publishing Digital Photography MA Department of Elementary & Secondary Education , Program Quality Assurance Services Middle Guidance counselors will ensure that students in the alternative program are Chelsea CPRSchool Corrective Action Plan included in the informational sessions for the regional vocational school. In addition, students will be invited to participate in the open houses hosted by Northeast Vocational Schools. 42 Title/Role of Person(s) Responsible for Implementation: Middle and High School Principals and Guidance Counselors Expected Date of Completion for Each Corrective Action Activity: Informational Session: October 2011 Open Houses : December-January 2012 Evidence of Completion of the Corrective Action: Copies of flyers referencing the above activities. Description of Internal Monitoring Procedures: Auditing of participation in the abovementioned offerings. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 13 Availability of Status of Corrective Action: Information and Academic Counseling Approved Partially Approved on General Curricular and Occupational/Vocational Opportunities Basis for Partial Approval or Disapproval: Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, submit a narrative description as well as any additional documentation regarding access to the vocational, occupational offerings by all middle and high school students. Progress Report Due Date(s): May 26, 2011 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 staff interviews indicated the district failed to issue the annual written notice to students who attended high school in the district within the past two years 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 support programs and to encourage them to participate in those programs. Narrative Description of Corrective Action: The CHS Guidance Department will track these students and notify them annually in writing of locally available programs. A copy of these letters will be maintained in the Guidance Department. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Principal and Lead Corrective Action Activity: October 2011 Guidance Counselor. Evidence of Completion of the Corrective Action: Copy of letter detailing the above information. Description of Internal Monitoring Procedures: Comparison of student roster with letters sent. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 43 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 16 Notice to Students 16 Status of Corrective Action: or over Leaving School without a High Approved Partially Approved School Diploma, Certificate of Attainment, or Certificate of Completion Basis for Partial Approval or Disapproval: Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By May 26, 2011, submit a copy of the letter that will be sent to 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 support programs and to encourage them to participate in those programs by May 26, 2011. By October 26, 2011, submit a report of the number of students who were sent the letter. Progress Report Due Date(s): May 26, 2011 and October 26, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 18 Responsibilities of the School Principal Rating: Partially Implemented Department CPR Finding: Documentation and staff interviews indicated that the implementation of the Instructional Support Team across the district is inconsistent. Specifically, staff efforts and their results are not consistently documented and placed in the student record. Additionally, when an individual student is referred for an evaluation to determine eligibility for special education, the documentation on the use of instructional support services for the student was not consistently provided as part of the evaluation information reviewed by the Team when determining eligibility. Further interviews indicated that students in the high school and middle school alternative program are not referred or part of the instructional support process within those schools. Narrative Description of Corrective Action: Procedures and protocols for consistent IST implementation are currently being developed. Training will be provided to the Special Education Team Chairs to insure that this documentation is consistently included when considering eligibility. Articulation of the equitable inclusion of all students in the IST process will be included in the IST procedures and protocols. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Donna Covino Corrective Action Activity: May 2011 Evidence of Completion of the Corrective Action: Copies of the aforementioned procedures and protocols Training agenda and sign-in sheet MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 44 Description of Internal Monitoring Procedures: Random auditing of files CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 18 Responsibilities of the School Principal 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 May 26, 2011, provide training to all appropriate staff at each building on the IST procedures, completion of forms and filing of forms. Submit the procedures and evidence of training (agenda and attendance sheet with date, name and role). By October 26, 2011, conduct a district-wide administrative review of a sampling of schools from each level regarding the implementation of the IST protocol. Indicate the number of buildings (grade level) reviewed, the number found to be compliant, an explanation of the root cause for any continuing noncompliance and a description of additional corrective actions to be taken by the district to address 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: a) List of buildings reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): May 26, 2011 and October 26, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 20 Staff Training on Rating: Partially Implemented Confidentiality of Student Records Department CPR Finding: Staff interviews indicated that the school personnel at Wright Middle School did not receive training on the provisions of the Family Educational Rights and Privacy Act, M.G.L. c. 71, s. 34H, and 603 CMR 23.00 and on the importance of information privacy and confidentiality. Narrative Description of Corrective Action: The City Solicitor will conduct this training at the Wright Middle School on March 22, 2011. She will repeat this training on the first teacher day of the 2011-2012 school year Title/Role of Person(s) Responsible: Expected Date of Completion for Each City Solicitor and Principal Corrective Action Activity: March 22, 2011 and August 2011 Evidence of Completion of the Corrective Action: Copy of agenda and sign-in sheets Description of Internal Monitoring Procedures: Copy of agenda and sign-in sheets MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 45 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 20 Staff Training on Confidentiality of Student Records 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 May 26, 2011, provide training to staff at the Wright Middle School on the provisions of the Family Educational Rights and Privacy Act, M.G.L. c. 71, s. 34H, and 603 CMR 23.00 and on the importance of information privacy and confidentiality. Please submit the agenda, handouts and attendance sheet with date, name and role. Progress Report Due Date(s): May 26, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 23 Comparability of Facilities Rating: Partially Implemented Department CPR Finding: See SE 55. Narrative Description of Corrective Action: Signs posted in the services spaces at the Hooks and Sokolowski Elementary Schools will be removed. The shower curtain dividing the resource room from another classroom will be replaced with a door (summer 2011). A cost analysis will be conducted to determine budget for furniture replacement at the Sokolowski School. Replacement of furniture will be completed summer of 2011 if FY’11 funds are sufficient to cover expense; otherwise, FY’12 funds will be allocated. Room 218 at ELC is an integrated Kindergarten. There was no subseparate classroom last year. Room 218 has always been a Kindergarten; it is on the second floor in a wing with another integrated Kindergarten and with 6 other regular Kindergarten classrooms. ELC has no basement. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal , Chief Finance Corrective Action Activity: August 2011 Officer and Building Facilities Manager . Evidence of Completion of the Corrective Action: Site Visit Description of Internal Monitoring Procedures: Requisitions, purchase orders and work requests MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 46 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 23 Comparability of Facilities Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See SE 55 Department Order of Corrective Action: Required Elements of Progress Report(s): See SE 55 Progress Report Due Date(s): May 26, 2011 and October 26, 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 Department CPR Finding: Documentation and staff interviews indicated that the district has not annually evaluated all aspects of the K-12 programming 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 contract an outside evaluator to complete an evaluation of all aspects of K-12 programming. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Carol Murphy, contracted Corrective Action Activity: June 2011 evaluator Evidence of Completion of the Corrective Action: Copies of evaluation reports Description of Internal Monitoring Procedures: Written Contract w/timeline for completion CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 25 Institutional SelfEvaluation 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 October 26, 2011, submit the results of the evaluation for equal access to all programs including academics, athletics and extracurricular programs operated by the district for any students of a protected class (race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status,). Progress Report Due Date(s): October 26, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 47 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: Classroom observations and staff interviews indicated that the district practices are inconsistent and that not all staff members were trained on confidentiality of student records at the Wright Middle School. Narrative Description of Corrective Action: See CR20 Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: March 22, 2011 Evidence of Completion of the Corrective Action: Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 26A Confidentiality and Student Records 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 CR 20 Progress Report Due Date(s): May 26, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 48 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Chelsea Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Name of School/District Staff Member 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: December 13, 2011 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 Chelsea CPR Corrective Action Plan 49 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. A review of district documents shows that the district does have a completed ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes. While documentation indicates that a program of sheltered English immersion is in place for all LEP students in the district other information gathered by the onsite team does not support that. The number of hours of ESL instruction is consistent with recommended hours as outlined in the Department’s September 2009 guidance document: “Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students." The district uses a Content-Based ESL model in which students are taught ESL in a self-contained setting for several grade levels. The district also has a Two-Way Model, the Caminos program, to instruct students in both English and Spanish. Content instruction is based on the appropriate Massachusetts Curriculum Framework, however not all LEP students receive sheltered content instruction as only several teachers have completed all of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, as described in the Commissioner’s Memorandum of June 2004. The district has a plan to complete Category training for all remaining teachers. Narrative Description of Corrective Action: The district will continue the practice of content and grade level staff co teaching, planning and grouping for instruction, and analyzing student performance in collaboration with qualified teachers of LEP students to ensure appropriate placement and create the proper instructional settings for LEP students. The district will continue with its aggressive plan (as noted in ELE 15) and District Improvement Plan goal of SEI training completion for all staff. The district will continue to require new staff to complete Category 1 as part of the induction year series of PD. The district will train additional staff by prioritizing and targeting staff assigned to sheltered content classrooms and content classrooms to complete all 4 categories of SEI training. The district will seek partnerships with other districts to provide additional opportunities for staff SEI training completion The district will work in collaboration with DESE to have staff participate in Train the Trainer PD to build capacity for staff training. The district will continue to track SEI training and distribute lists to principals to ensure proper placement of LEP students and IDPD goals for staff MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 50 Title/Role of Person(s) Responsible for Implementation: ELL Coordinator, Expected Date of Completion for Each Corrective Action Activity: February 2012 principals and ongoing Evidence of Completion of the Corrective Action: Professional learning community agendas /notes Co teaching schedules Data Entry forms submitted to DESE for completed trainings Description of Internal Monitoring Procedures: PD list of staff completion sent to principals annually Staff IPDP CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Program Placement and Structure Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s internal monitoring procedures do not specifically address how the sheltering of content will be provided to English language learners (ELLs) while the district increases the qualifications of general education and content area teachers in all four (4) categories of Sheltered English Immersion (SEI). Also, yearly monitoring of PD training is insufficient to ensure that teachers are enrolling and completing all four (4) categories of SEI training. Department Order of Corrective Action: Monitoring of the district’s plan for completion of all four (4) categories of SEI must be done minimally on a biannual basis. The district must also include an explanation on how it will ensure that sheltering of content will be provided to ELLs while the district increases teachers’ sheltering content capacity, as well as who will take responsibility for tracking completion of SEI categories. Required Elements of Progress Report(s): Please submit evidence of the following by September 16, 2011. Professional development partnerships that expand the district’s capacity to increase the district’s Sheltered English Immersion (SEI) PD category training. Submit community agendas/notes. 3-5 samples of co-teaching schedules per school (elementary, middle school and high school) Spreadsheet, per school, across the district that lists all teachers who are teaching English language learners (ELLs) along with all four (4) SEI PD category training they have completed to date. Biannual district’s findings of monitoring activity. Include names of staff responsible for monitoring and tracking completion of SEI categories district wide; summary of findings, and actions taken to remedy any area of non-compliance. Submit an update by December 2, 2011. Progress Report Due Date(s): September 16, 2011 and December 2, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 51 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 demonstrated that the annual parent notification letter used by the district does not contain information related to the parents’ right to apply for a waiver as required. Narrative Description of Corrective Action: The district has revised the annual letter to include language related to the parents’ right to apply for a waiver as required Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: ELL Coordinator Completed and Uploaded to Security Portal: December 2010 Evidence of Completion of the Corrective Action: Uploaded revised letter Description of Internal Monitoring Procedures: Random sampling of LEP files CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Parental Notification 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): Provide a copy of the updated Parent Notification letter and evidence of informing appropriate staff (copy of email, meeting agenda and attendance sheet) regarding the requirement of including the parent’s right to apply for a waiver in the Parent Notification letter by September 16, 2011. Submit a detailed narrative of the results of an administrative review of student records for compliance related to Parental Notification letter including the parent’s right to apply for a waiver. Please indicate the number of records reviewed at each building level, the number found to be compliant, the root cause of any non-compliance and any further steps the district takes to address areas of concern by December 2, 2011. 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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): September 16, 2011 and December 2, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 52 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Development Rating: Partially Implemented Requirements Department CPR Finding: Content instruction is based on the appropriate Massachusetts Curriculum Framework; LEP students do receive sheltered content instruction as several teachers have completed all of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, as described in the Commissioner’s Memorandum of June 2004, and the district has an aggressive plan to complete Category training for all remaining teachers. Narrative Description of Corrective Action: See ELE 5 DESE Findings state that LEP students do receive sheltered content instruction as several teachers have completed all of the required categories of SEI PD. DESE findings state that the district has an aggressive plan to complete Category training for all staff. Title/Role of Person(s) Responsible for Implementation: ELL Coordinator Expected Date of Completion for Each Corrective Action Activity: See ELE 5 Evidence of Completion of the Corrective Action: See ELE 5. Description of Internal Monitoring Procedures: See ELE 5. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 15 Professional Development Requirements Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See ELE 5. Department Order of Corrective Action: See ELE 5. Required Elements of Progress Report(s): See ELE 5. Progress Report Due Date(s): See ELE 5. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 53 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: Record review demonstrated that that not all of the required documentation was found in each student record. Specifically, some records did not contain completed annual parent notification letters and some files did not contain testing results such as MEPA and MCAS. Additionally, it was noted that in several files that copies of parent notification letters, progress reports and other documents were not translated for those families whose primary language is other than English. Narrative Description of Corrective Action: The district will use an audit sheet to be completed yearly to ensure the required documentation is found in each student cumulative file Missing MEPA and MCAS information for transfer students will be noted on LEP Record Audit sheet with a date of entry and notation for missing records. The district will provide LEP parent notification letters in the following languages: Spanish, Portuguese, Arabic, Vietnamese and Chinese. The district will provide oral or written translations for additional documents using request form. See CR 7. The ELL coordinator will train ELL staff annually as to the required documentation and record keeping process. Title/Role of Person(s) Responsible for Implementation: ELL Coordinator and ELL Expected Date of Completion for Each Corrective Action Activity: June 2011 and staff September 2011 Evidence of Completion of the Corrective Action: Translated Forms, LEP Record Audit Sheet, Logs of Oral translations, Student Cumulative Files Description of Internal Monitoring Procedures: Random audit of student files 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): Provide training to appropriate staff on ELE student record requirements and submit the agenda and attendance sheet for each building by September 16, 2011. Submit a detailed narrative of the results of an administrative review of ELE student records for compliance related to ELE student record requirements. Please indicate the number of records reviewed at each level, the number found to be compliant, the root cause of any non-compliance and any further steps the district takes to address areas of concern by December 2, 2011. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 54 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 level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Progress Report Due Date(s): September 16, 2011 and December 2, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Chelsea CPR Corrective Action Plan 55