MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW CODMAN ACADEMY CHARTER PUBLIC SCHOOL Corrective Action Plan Forms Program Area: Special Education Prepared by: Codman Academy Charter Public School / Emily Barbara (Special Education Coordinator) 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: August 24, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 1 Rating: Partially Implemented Assessments are appropriately selected and interpreted for students referred for evaluation Department CPR Finding: According to the student record review and staff interviews, students who are bilingual are not administered assessments for special education eligibility in the language and form most likely to yield accurate information on what the student knows and can accomplish academically, developmentally, and functionally. Narrative Description of Corrective Action: Any students suspected of being bilingual based on 1.) home survey forms sent at the beginning of the student’s 9th grade year and filed in student’s folder and 2.) communication with the home by the school psychologist, will be administered assessments and forms in the language that is likely to yield more accurate information on the student’s academics, development and overall level of functioning. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Assessments administered in languages other than English. See attached 2011-2010 Special Education Policies and Procedures manual. Description of Internal Monitoring Procedures: Regular review of files, communication with school psychologist. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 1 Assessments are appropriately selected and interpreted for students referred Status of Corrective Action: X Approved Partially Approved Disapproved for evaluation Basis for Partial Approval or Disapproval: Not applicable Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Please provide the results of CACS’ internal record review for evidence that students who are bilingual are assessed in the language and form most likely to yield accurate information. Provide a detailed summary of the district’s record review, including student’s grade level; method of determination; and the results of the review. Include: 1) The number of student records reviewed; 2) The number of student records in compliance; 3) For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and 4) The district’s plan to remedy the non-compliance if applicable. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 6 Rating: Partially Implemented Determination of Transition Services Department CPR Finding: According to the student record review and staff interviews, transition planning is not always done for students with IEPs. Narrative Description of Corrective Action: The Special Education Coordinator and/or designated teacher will meet with individual students before the IEP meeting is held to complete surveys and discuss interests after graduation or transition out of Codman Academy. In collaboration with the Dean of Enrichment, appropriate activities and services will be discussed at the IEP meeting with student and parent/guardian present. All transition information will be documented on the appropriate pages within the IEP as well as the Transition Planning Form page. Before the IEP, any needed agencies will be invited to participate in the meeting to discuss their roles in the student’s transition. In addition, all students participate in transition planning with the Dean of Enrichment through a College Class during the 11th and 12th grade years and through the substantially separate class (HLI.) Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Copies of students’ transition and career interest surveys will be located both in their physical files as well as their online portfolios that are completed with the Dean of Enrichment. Description of Internal Monitoring Procedures: Ongoing tracking using online IEP system, regularly scheduled Transitions class, regular meetings with students within advisory groups, annual reviews of IEP, review of grades and credits earned in the grading software. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 6 Determination of Transition Services Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Not Applicable Department Order of Corrective Action: Not Applicable Required Elements of Progress Report(s): The charter school will provide the results of a record review from a sample of students at each grade level (minimum sample of three records for each grade level) to ensure school personnel are discussing student transition and completing the transition planning form. Please indicate the total number of records reviewed and the number of records that demonstrated transition planning occurred and was documented appropriately. If continued noncompliance was identified, please indicate the specific corrective action taken to address the noncompliance. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 7 Rating: Partially Implemented Transfer of parental rights at age of majority Department CPR Finding: According to staff interviews, the document review and student record review, the charter school has not consistently informed students of the change in the decision-making rights one year before the student attains the age of majority. Narrative Description of Corrective Action: Appropriate documentation is included in the students’ files indicating the notice to both parents and students about the age of majority and the transfer of rights. The discussion takes place at the IEP meeting and the subsequent documentation is included in the students’ files at least one year before the student is to turn 18. A statement is also included in the “Additional Information” section on the last page of the IEP. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: August 24, 2011 Evidence of Completion of the Corrective Action: A copy of the signed document in each student’s physical files as well as statement indicating the action took place at the IEP meeting under “Additional Information” in IEP. Description of Internal Monitoring Procedures: Record reviews. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 7 Transfer of parental rights at age of majority Status of Corrective Action: X Approved Partially Approved Basis for Partial Approval or Disapproval: Not applicable Disapproved Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Please provide the results of CACS’ internal record review for evidence that parents and students are notified about the change in decision-making rights one year before the student turns 18. Provide a detailed summary of the district’s record review, including student’s grade level; method of determination; and the results of the review. Include: 1) The number of student records reviewed; 2) The number of student records in compliance; 3) For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and 4) The district’s plan to remedy the non-compliance if applicable. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 8 Rating: Partially Implemented IEP Team composition and attendance Department CPR Finding: The student record review demonstrated that not all IEP Team meetings had general education staff in attendance when students’ placement indicated full or partial inclusion. There were no excusal forms for these meetings. Further, according to document and student record review, the charter school has not developed a procedure for excusing staff members from IEP team meetings. Narrative Description of Corrective Action: In the spring of 2010, a procedure was developed to excuse team members from the IEP meeting. All staff members involved in the education of a student at Codman is asked for a written narrative describing a student’s strengths and weaknesses, concerns, etc., so that information can be included within the IEP. If a member of the Team has to be excused for any reason, contact is made with the parent before the meeting begins to seek permission to excuse the staff member. An excusal form is then used at the meeting (accessed via the web-based IEP software) to seek consent from the parent. At that time, the written documentation that the staff member had previously provided is attached. All documentation is then included within the students’ file. The appropriate boxes are also checked on the meeting attendance. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Signed excusal forms with supporting documentation in student files. Description of Internal Monitoring Procedures: Record reviews. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 8 IEP Team composition and attendance Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Not applicable Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): 1. Provide a description of the school’s IEP Team composition policies. Please demonstrate that training was provided on this topic; please submit supporting documentation demonstrating staff training and a copy of the charter school’s procedures. 2. Since this policy was established in Spring 2010, please conduct a record review for evidence that general education teachers regularly attend IEP meetings, and in cases where they cannot, a signed parent excusal form is included in the file. Provide a detailed summary of the district’s record review, including student’s grade level; method of determination; and the results of the review. Include: 1) The number of student records reviewed; 2) The number of student records where a regular education teacher was not in attendance (e.g., five out of ten, ten out of ten, etc.); 3) The number of student records where there was a signed excusal form for a regular education teacher; 4) For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and 5) The district’s plan to remedy the non-compliance if applicable. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 9A Elements of the eligibility determination; general education accommodations and services for ineligible students Rating: Partially Implemented Department CPR Finding: Student records demonstrated that when students are found ineligible or are no longer eligible for special education services, none of the Notice of School District Refusal to Act (N2) forms indicates the possibility of a 504 plan for students. Narrative Description of Corrective Action: When students are determined to be ineligible for special education services, a 504 plan will be considered at the eligibility meeting if the student is found to have a disability that impacts a major life activity. This will be documented on the appropriate forms including the Notice of School District Refusal to Act. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Use of Notice of School District Refusal to Act, when appropriate. See student files. Description of Internal Monitoring Procedures: Record reviews. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 9A Elements of the Status of Corrective Action: Approved Partially Approved Disapproved eligibility determination; general education accommodations and services for ineligible students Basis for Partial Approval or Disapproval: The charter school did not indicate that school personnel received training on the eligibility determination process and when consideration of a 504 plan would be applicable. Department Order of Corrective Action: Please ensure that school personnel are trained on the eligibility process and the circumstances which may lead to a 504 accommodation plan. Required Elements of Progress Report(s): Please conduct staff training on the eligibility process and the basis of which an IEP may consider the provision of a 504 accommodation plan. Please provide documentation demonstrating that school personnel were trained on the elements of the eligibility determination and the basis on which the student could receive a 504 accommodation plan. This progress report is due January 5, 2011. Conduct an internal record review for evidence that when students are determined to be ineligible for special education services, a 504 plan will be considered at the eligibility meeting if the student is found to have a disability that impacts a major life activity and is will be documented on the Notice of School District Refusal to Act. Provide a detailed summary of the district’s record review, including student’s grade level; method of determination; and the results of the review. Include: 1) The number of student records reviewed; 2) The number of student records where a regular education teacher was not in attendance (e.g., five out of ten, ten out of ten, etc.); 3) The number of student records where there was a signed excusal form for a regular education teacher; 4) For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and 5) The district’s plan to remedy the non-compliance if applicable. This progress report is due March 15, 2011. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): January 5, 2011 & March 15, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 11 School district response to parental request for independent educational evaluation Rating: Partially Implemented Department CPR Finding: The charter school did not submit documentation of its procedures to offer parents the option of participating in an income eligibility program for free or reduced cost independent educational evaluations that are equivalent to the types of assessments completed by the school. Narrative Description of Corrective Action: A plan has been developed offering the option of an independent educational evaluations at a free or reduced rate for parents of students at Codman Academy. Supporting documentation is now included in the Special Education Policies and Procedures Manual. This information is verbally shared at each reevaluation meeting at the close of the assessments review, but will now also be printed and offered to the parents/guardians in addition to the Parental Notice of Procedural Safeguards. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Documentation included in the attached 20112012 Special Education Policies and Procedures Manual, statement included in eligibility determination paperwork that the conversation took place and that parents/guardians are aware of their rights. Description of Internal Monitoring Procedures: Action completed and will be reviewed yearly. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 11 School district Status of Corrective Action: Approved Partially Approved response to parental request for independent educational evaluation Basis for Partial Approval or Disapproval: Not applicable Disapproved Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Please conduct a record review of all records in which the parent(s) requested the public funding of an Independent Educational Evaluation (IEE). Please indicate the number of records reviewed, the number of records found in compliance, and for any records indicating continued noncompliance, the school’s analysis of the root cause and the school’s subsequent corrective action to achieve full compliance. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 13 Progress Reports and Rating: Partially Implemented content Department CPR Finding: According to student record review and staff interviews, related service providers do not consistently provide progress reports. In addition, the charter school has not provided graduating students with a summary of his or her academic achievement and functional performance. Narrative Description of Corrective Action: All related services staff have access to the web-based IEP software and are now contacted 6 times a year to complete the progress reports. Beginning in the spring of 2010, all graduating students are provided a summary of academic achievement and functional performance in late May using the state-mandated forms and are mailed this information along with their final progress reports. A copy of the reports and summaries are included in the students’ permanent special education files. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: June 2011 Evidence of Completion of the Corrective Action: Completed progress reports, completed summaries at the end of the academic year; copies located in student files. Description of Internal Monitoring Procedures: Record reviews, calendar reminders, check-off system and review of progress reports before mailing. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 13 Progress Reports and content Status of Corrective Action: X Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Not applicable Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Conduct an internal record review for evidence that related service providers are completing and mailing progress reporting for students. Provide a detailed summary of the district’s record review, including student’s grade level; method of determination; and the results of the review. Include: 1) The number of student records reviewed; 2) The number of student records where a regular education teacher was not in attendance (e.g., five out of ten, ten out of ten, etc.); 3) The number of student records where there was a signed excusal form for a regular education teacher; 4) For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and 5) The district’s plan to remedy the non-compliance if applicable. The district indicates that corrective action occurred in the Spring of 2010 to ensure that all graduating students are provided a summary of academic achievement and functional performance using the statemandated forms. Please provide the Department with verification that the Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 29 Communications are in English and primary language of home Rating: Partially Implemented Department CPR Finding: Staff interviews indicated that the charter school does not translate IEPs or evaluation reports for parents whose home language is other than English. Narrative Description of Corrective Action: All IEP forms will be translated ahead of time using web-based software, such as Google Translate, and mailed home before any meetings are held, giving the parents time to review the documents. At the time of the IEP meeting, and with the assistance of an interpreter, information will be reviewed and clarified. Documents that went out this summer to students’ families whose primary language is not English were translated using the software. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Translated forms in student files. Description of Internal Monitoring Procedures: Record reviews, yearly updating of files and documents. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 29 Communications Status of Corrective Action: Approved Partially Approved Disapproved are in English and primary language of home Basis for Partial Approval or Disapproval: Web-Based software such as Google Translate does not always provide accurate translations. Department Order of Corrective Action: The charter school must ensure that written information translated into other languages is clear to ensure parental access to the information. Further, the district indicated that an interpreter will assist parents in reviewing and clarifying information at the IEP Team meeting. Interpreters must be familiar with special education procedures, programs and services. Qualified interpreters should review written communications before mailing such documents to the parent. Required Elements of Progress Report(s): 1. The charter school will demonstrate it has qualified interpreters (for example, using teachers or other appropriate school personnel) to review written communications prior to distribution. 2. In addition, the charter school will review a sample of student records to ensure communications are appropriately translated. Please indicate the number of records reviewed, the number of records found in compliance, and any corrective action taken if continued noncompliance was identified. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 43 Behavioral Interventions Rating: Partially Implemented Department CPR Finding: Staff interviews and student record review indicated that behavioral supports are developed and monitored by the guidance/student support coordinator. Behavioral interventions were not considered by a student’s IEP Team and therefore not included in the IEP even when a student had multiple suspensions and was at risk of expulsion. Narrative Description of Corrective Action: Collaborating with the school’s Social Worker, the Special Education Coordinator will develop additional behavioral interventions and support plans for students whose behavior impede their own learning or the learning of others in the classroom; these students will be identified through teacher reports and requests for classroom observations and through data gathered by the Dean of Students who will identify students that routinely get sent out of class or get sent home. This will be shared with the Special Education Coordinator. Behavioral interventions (above the school-wide Citizenship positive behavior rewards system and interventions system set up through Student Accountability) will be formally documented in the IEP within PLEP B and any FBAs and BIPs will be filed in the students’ records. Behavioral interventions and support plans will be reviewed at each trimester when progress reports are written. Adjustments to plans will be made at this time and/or reviewed and revised at the annual IEP. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: June 2011 Evidence of Completion of the Corrective Action: Documentation in student files. Description of Internal Monitoring Procedures: Record reviews, reviews of Student Accountability data, review of progress reports. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 43 Behavioral interventions Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: School personnel who participate in IEP Team meetings should be aware of the various behavioral supports available to students and their responsibility to develop Behavioral Intervention Plans where appropriate. Department Order of Corrective Action: The charter school will provide training on the development of Behavioral Intervention Plans to school personnel who participate in IEP Team meetings. Required Elements of Progress Report(s): The charter school will provide documentation demonstrating that appropriate staff members receive training on the development of Behavior Intervention Plans. Please provide an agenda, the name of the training and signed attendance list for verification. This progress report is due January 5, 2011. Subsequent to the training, please conduct a sample review of student records for students who required behavioral interventions and the development of Behavioral Intervention Plans. Please indicate the number of records reviewed, the number found in compliance, and if necessary, the root cause of any continued noncompliance and additional corrective action taken to address the identified concerns. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 & March 15, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 44 Procedure for recording Rating: Partially Implemented suspensions Department CPR Finding: According to the document review, the school’s code of conduct includes a “send home” policy for non-compliant students. Staff interviews indicated that although “send home” exclusions are monitored internally, they are not recorded as suspensions. As a result, the school cannot accurately track the numbers of days a student with disabilities has been suspended, nor can they identify the behavior(s) that constitute a pattern. Narrative Description of Corrective Action: The school internally tracks all send homes. A review of 2009-2010 data revealed that 100% of “send homes” were in the afternoon, after the student had completed over a half-day of school. Consequently, none of the “send homes” were counted as a suspension. For the 2011-2012 year, the school will count any “send home” that results in the loss of more than one half-day of school as a suspension. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Dean of Students Corrective Action Activity: complete Evidence of Completion of the Corrective Action: “Send home” internal data sheet (2010-2011 data available in June 2010). Description of Internal Monitoring Procedures: Record reviews, annual review of student accountability documentation by Dean of Students and Principal. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 44 Procedure for recording suspensions Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Any removal from the students’ program, regardless of the time of day in which a student is sent home, must count as a day’s suspension. The charter school may not count only those days that results in the loss of more than one half-day of school. Department Order of Corrective Action: The charter school must ensure that all “send home” actions count as removal from the student’s program and must count as suspensions. Please revise the school’s procedures. Required Elements of Progress Report(s): Please demonstrate that the charter school revised its procedures, and provided training to staff on the revised procedures. This progress report is due January 5, 2011. Please conduct an internal review of the number of special education students who have been sent home since January 2010; and whether the district conducted manifestation determinations for any of these students. Provide a detailed summary of this review, including each student’s grade level; the number of times the student was removed from his or her program; and whether the school conducted a manifestation determination. Include for each student whether subsequent behavioral support (or a Behavior Intervention Plan) was provided to address emergent patterns of behaviors. This progress report is due March 15, 2011. Please note that 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): January 5, 2011 & March 15, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 45 Procedures for suspension Rating: Partially Implemented up to 10 days and after 10 days: General requirements Department CPR Finding: According to documentation, the school’s accountability program, which outlines expectations for student conduct, contains no reference to additional protections required for students with IEPs and 504 plans. Narrative Description of Corrective Action: Statements and procedures have been outlined in the Special Education Policies and Procedures Manual and have been referenced in the Student and Family Handbook. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator, Corrective Action Activity: complete Principal Evidence of Completion of the Corrective Action: See documentation in attached handbooks. Description of Internal Monitoring Procedures: Annual review of handbooks and procedures. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 45 Procedures for Status of Corrective Action: Partially Approved suspension up to 10 days and after 10 X Approved days: General requirements Basis for Partial Approval or Disapproval: Not applicable Disapproved Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Provide the page(s) from the Student and Family Handbook that describes disciplinary procedures for special education students and students on 504 plans. Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 46 Procedures for Rating: Partially Implemented suspension of students with disabilities when suspensions exceed 10 consecutive school days Department CPR Finding: Although the school submitted a 2009-2010 special education manual that includes the provisions for a manifestation determination, and the school’s suspension and expulsion hearings are well documented, student record review indicated that the manifestation determination procedures are not consistently applied. Narrative Description of Corrective Action: A formal procedure is now in place for students at risk for a manifestation determination. Documents which include sections for parental and staff comments, as well as a checklist (based on state-mandated requirements) will be consistently used when and if the need arises. Any and all information regarding prior behavioral supports and interventions will also be formally documented and included in the files. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: June 2011 Evidence of Completion of the Corrective Action: Documentation in student records. Description of Internal Monitoring Procedures: Record reviews. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 46 Procedures for Status of Corrective Action: X Approved Partially Approved suspension of students with disabilities when suspensions exceed 10 consecutive school days Basis for Partial Approval or Disapproval: Not applicable Disapproved Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Provide any training materials, including signed agendas, supporting materials, etc., provided to special education staff members on the new manifestation determination procedure. Provide a copy of the checklist and the document described (with sections for parent and staff comments). Progress Report Due Date(s): January 5, 2011 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW CODMAN ACADEMY CHARTER PUBLIC SCHOOL Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Codman Academy Charter Public School / Meg Campbell (Executive Director) 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: August 24, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7 Information to be translated into languages other than English Rating: Partially Implemented Department CPR Finding: Although the school has translated its application and enrollment forms into Spanish and Haitian Creole, examples of translated recruitment and promotional materials disseminated to residents in areas served by the school were not provided. Narrative Description of Corrective Action: This year, Codman Academy had its recruitment and promotional materials translated into five (5) languages – English, Haitian Creole, Chinese, Spanish, Portuguese. Recruitment materials were made available in public spaces throughout Dorchester, including bus stops, T stops, and local businesses. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Executive Director Corrective Action Activity: complete Evidence of Completion of the Corrective Action: The translated documents are available on the homepage of our website at www.codmanacademy.org. Description of Internal Monitoring Procedures: Annual review of application, enrollment form, and promotional materials to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7 Information to be translated into languages other than English Status of Corrective Action: X Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Not applicable Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Provide a selection of the school’s recruiting materials in Haitian Creole, Chinese, and Portuguese used to recruit students for the 2010-2011 school year. Progress Report Due Date(s): January 5, 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: Document review demonstrates that the school’s described procedures assuring due process in disciplinary proceedings and procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans do not contain provisions for a manifestation determination or a process to expedite the evaluation process for a student suspected of having a disability. Narrative Description of Corrective Action: The school’s 2010-2011 Special Education Policies and Procedures manual includes a description of the manifestation determination process and the process to expedite the evaluation process for a student suspected of having a disability. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Coordinator Corrective Action Activity: complete Evidence of Completion of the Corrective Action: See attached 2010-2011 Special Education Policies and Procedures manual. Description of Internal Monitoring Procedures: Annual review of the Special Education Policies and Procedures manual to ensure compliance. 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: X Approved Partially Approved Basis for Partial Approval or Disapproval: Not applicable Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): See corrective action for SE 45. Progress Report Due Date(s): January 5, 2011 Disapproved COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: CR 11A Designation of coordinator(s); grievance procedures Department CPR Finding: Although the Principal is described as the individual who would resolve any harassment or discrimination allegations (e.g., Title IX), the school’s handbook does not designate a staff member as its coordinator for Section 504. Narrative Description of Corrective Action: The school’s 2011-2012 handbook will designate a staff member as its coordinator for Section 504. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal Corrective Action Activity: August 24, 2011 Evidence of Completion of the Corrective Action: School handbook for 2011-2012 will be updated with the 504 grievance procedure. Description of Internal Monitoring Procedures: Annual review of school handbooks to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 11A Designation of coordinator(s); grievance procedures Status of Corrective Action: Approved X Partially Approved Disapproved Basis for Partial Approval or Disapproval: According to this submission, CACS did not provide the name of its Section 504 coordinator in the 2010-2011 parent and student school handbook. Department Order of Corrective Action: See the required progress report element below. Required Elements of Progress Report(s): If the school has not corrected the 2010-2011 parent and student handbook, provide parents and students with an addendum to the handbook that gives the Section 504 coordinator name and contact information. Provide a copy of the corrected text to the department, along with a description of how the school distributed this information to parents and students for the 2010-2011 school year. Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 12A Annual and continuous Rating: Partially Implemented notification concerning nondiscrimination and coordinators Department CPR Finding: While the school’s handbook does contain an anti-discrimination statement, other publications used to publicize the school do not include a notice that the school does not discriminate on the basis of race, color, national origin, sex, disability, religion, or sexual orientation. Narrative Description of Corrective Action: Our website contains a non-discrimination statement, listed on our “Positions Available” page (link is located on the left, below the “Main Menu” list). The only other two publications used to publicize the school include our annual report calendar and our school profile, will include this statement in their next print run. Title/Role of Person(s) Responsible for Implementation: Executive Director Expected Date of Completion for Each Corrective Action Activity: Aug 24, 2011 Evidence of Completion of the Corrective Action: The school’s 2011-2010 calendar will be posted to the school website: www.codmanacademy.org. Description of Internal Monitoring Procedures: The Executive Director will ensure that the nondiscrimination statement is included in future publications. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 12A Annual and Status of Corrective Action: X Approved Partially Approved continuous notification concerning nondiscrimination and coordinators Basis for Partial Approval or Disapproval: Not applicable Disapproved Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Provide a copy of the non-discrimination statement for the 2010-2011 calendar and the school profile. Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 16 Notice to students 16 or Rating: Partially Implemented over leaving school without a high school diploma Department CPR Finding: The school has a procedure in the student handbook for contacting a parent or guardian when a student is absent for more than 15 consecutive days. However, there is no indication that the school has a procedure to send an annual notice to former students who have not yet earned their competency determination and who have not transferred to another school. Additionally there is an outdated citation (Chapter 766) to the state’s special education law (now Chapter 71B) in the school’s policy. Narrative Description of Corrective Action: The school has included in the 2010-2011 Student Family Handbook the procedure to send an annual notice to former students who have not yet earned their competency determination and who have not transferred to another school. The school also changed an outdated citation in the 2010-2011 handbook to reflect the state’s current special education laws. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal Corrective Action Activity: complete Evidence of Completion of the Corrective Action: See attached 2010-2011 Student Family Handbook. Description of Internal Monitoring Procedures: The Principal will ensure that the current handbook accurately references current state laws and includes required descriptions of school procedures. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 16 Notice to students Status of Corrective Action: Approved X Partially Approved Disapproved 16 or over leaving school without a high school diploma Basis for Partial Approval or Disapproval: Please note that a statement in the school’s handbook is not sufficient to meet the standard. Each district must also have a verifiable procedure to demonstrate that students and parents are notified by mail individually of their right to return to school if they have not yet attained a high school diploma before they are 22 years old. Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Provide a copy of the school’s written annual notice to students age 16 or over and their parents or guardians who have left the school without graduating and who have not re-enrolled in another school district. The notice must also be in the family’s native language and state that the student and the parent or guardian may meet with a representative of the district within ten days from the date the notice was sent. Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 17A Use of physical restraint Rating: Partially Implemented Department CPR Finding: According to document review and staff interviews, the school has not developed or implemented staff training at least annually on the use of physical restraint consistent with regulatory requirements. Narrative Description of Corrective Action: For the 2010-2011 academic year, the school has developed and implemented staff training on the use of physical restraint consistent with regulatory requirements. All staff received physical restraint training in August, 2010 during professional development. Additionally, two staff have been identified to serve as a school-wide resource to assist in ensuring proper administration of physical restraint; one has already received additional training offsite and the other will attend training this year. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal Corrective Action Activity: complete Evidence of Completion of the Corrective Action: See August 2010 PD schedule. Description of Internal Monitoring Procedures: Annual review of state and federal requirements and staff certifications to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 17A Use of physical restraint Status of Corrective Action: X Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Not applicable Department Order of Corrective Action: Not applicable Required Elements of Progress Report(s): Please provide verification that the physical restraint occurred in August 2010 as indicated by the submitted draft professional development agenda. Please include a signed attendance sheet, examples of the restraint training materials, and the date that the training occurred. Progress Report Due Date(s): January 5, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 25 Institutional selfRating: Partially Implemented evaluation Department CPR Finding: According to staff interviews, the school has not evaluated all aspects of its program annually to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs. Narrative Description of Corrective Action: The school has responded in several ways to this finding including holding multiple equity professional development workshops for all staff over the course of the year. Workshops are aimed at ensuring that all students and staff, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs. Additionally, the school will review equal access during the two week, end-of-year professional development. Finally, the Student Support Team, addresses this issue in a year-end meeting. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal Corrective Action Activity: July 2011 Evidence of Completion of the Corrective Action: See attached August 2010 professional development schedule. Description of Internal Monitoring Procedures: 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: While the charter school response indicates various initiatives to address the Department’s concern, the school is not synthesizing these elements to produce an evaluation that provides an analysis, conclusion and any resolution of possible issues. Department Order of Corrective Action: Demonstrate that the school compiles information from these various activities, conducts an analysis and as an outcome of that analysis, makes any necessary changes. Required Elements of Progress Report(s): Please provide the results of the evaluation, including the conclusions reached, and resolution of any identified issues. Please identify the persons responsible for conducting the evaluation. Progress Report Due Date(s): January 5, 2011 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW CODMAN ACADEMY CHARTER PUBLIC SCHOOL Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Codman Academy / Thabiti Brown (Principal) 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: August 24, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 3 Initial Identification Rating: Partially Implemented Department CPR Finding: Documentation review and staff interviews indicated that the school uses a qualified staff person to assess students and determine a student’s English language proficiency; however, the home language survey is translated into Spanish only. Narrative Description of Corrective Action: Translate home language survey to Haitian Creole. Title/Role of Person(s) Responsible for Implementation: Principal Expected Date of Completion for Each Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Additional translated document is attached. Description of Internal Monitoring Procedures: Principal reviews which languages the home language survey should be translated into annually at the beginning of the recruiting season. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 3 Initial Identification Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: None Department Order of Corrective Action: None Required Elements of Progress Report(s): No further progress reporting necessary. Progress Report Due Date(s): None COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 Program Placement and Rating: Partially Implemented Structure Department CPR Finding: Sheltered English immersion (SEI) is a program model for limited English proficient (LEP) students composed of two parts—English as a second language (ESL) and sheltered content instruction. ESL is explicit, direct instruction about the English language, delivered to LEP students only and designed to promote the English language development of LEP students. Sheltered content instruction is an approach for teaching content to LEP students in strategic ways that make the subject matter concepts comprehensible while promoting the LEP students’ English language development. A review of district documents shows that the district does not have an ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO). While the school does not currently have any LEP identified students, SIMS data submitted by the school for this review indicated that there has been at least one LEP students in the past two years and the documentation indicated that there is no program of ESL instruction to be in place; therefore it is inconsistent 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.” Content instruction is based on the appropriate Massachusetts Curriculum Framework. While there are no LEP students enrolled at this time, the school would be unable to meet the instructional needs of LEP students enrolled going forward as no 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. In fact, the only Categories completed were Category 1 with a generalized SEI PD plan to complete the remaining Categories over the next two years. Narrative Description of Corrective Action: After conducting research into various ESL curricula possibilities the school has settled on adopting the High Point curriculum from Hampton Brown. The High Point curriculum is a language and literacy program that is aligned with MA standards/frameworks. Although the curriculum is not currently in action, our research indicates that High Point excels at being consistent, recycling and building upon reading/writing strategies and grammar skills throughout the series of textbooks, and teaching crosscontent literacy skills. The school’s revised plan for Category trainings is to annually enroll ate least one teacher from each grade level in a Category training. During the 2009-2010 one teacher completed the Category 1 training; she has since moved on to teach elsewhere. Title/Role of Person(s) Responsible for Implementation: Principal Expected Date of Completion for Each Corrective Action Activity: August 24, 2011 Evidence of Completion of the Corrective Action: Teachers will be enrolled in Category training as evidenced by certificates of completion. One page summary of High Point ESL curriculum attached. Description of Internal Monitoring Procedures: ESL curriculum published internally. Principal checks annually to ensure new batch of Category training. 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: Although at the time of the Coordinated Program Review (CPR), Codman Academy did not have ELLs enrolled, it still remains responsible for providing an English as a Second Language (ESL) program at any time an ELL (s) is identified. Therefore, the program must include the use of an ESL curriculum that is based on the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO). Codman Academy’s submission of an internet summary page of High Point’s ESL curriculum does not address how this ESL curriculum would be used for the grades served at the school. (Refer to the links below to view the Guide for Developing a Content-Based English as a Second Language Curriculum ) http://www.doe.mass.edu/ell/cdguide/?section=step4_cbcm http://www.doe.mass.edu/ell/cdguide/?section=steps http://www.doe.mass.edu/ell/curriculum.html Codman Academy does not address the following: How content instruction will be aligned with the ELPBO, when using the High Point curriculum, How the school will ensure that the four categories of SEI PD have been completed for all teachers. Internal monitoring practices do not include means of ensuring continuous monitoring of all areas noted in the CPR report. Monitoring must include the following: Ensuring completion of the ESL Curriculum Ensuring that all teachers have completed the four categories of SEI professional development (SEI PD) Ensuring that there is at least one licensed ESL instructor on staff able to provide ESL/ELD instruction Department Order of Corrective Action: Provide a report on the progress of the ESL curriculum. At a minimum, Codman Academy could adapt the content curriculum in current use and adapt it to meet the needs of ELLS. Submit this report by February 19, 2011. Include a list of persons responsible. Complete an ESL curriculum draft for all grades by April 12, 2011. Provide evidence that all content instruction for all grade levels has been aligned with the ELPBO by April 12, 2011. Provide the school’s plan for tracking how many of the four categories of SEI professional development (SEI PD) teachers completed. Include specific dates, names of all staff members, presenters’ names, and agendas, to address completion of all four Categories of training by February 19, 2011. Submit evidence of completed SEI PD Category Training. Include: attendance sheets that indicate grades/subjects taught, and dates of training. Provide this evidence by February 19, 2011. Submit an update by April 12, 2011 If Codman Academy has any ELLs enrolled , then submit the following: Report on the means of ensuring that ELLs will be grouped by proficiency level. Sample schedules of ELLs from all grades to show that students are receiving recommended hours of ESL instruction by February 19, 2011. Sample schedules of ELLs from all grades to show placement with content teachers who have been SEI trained by February 19, 2011. Submit an update by April 12, 2011. If Codman Academy has any ELLS enrolled, then continuous monitoring must include a means of ensuring that ELL students are: Provided with a minimum of recommended ESL instruction hours to all ELLs based on MEPA proficiency level at all grade levels. Taught appropriate grade level content at all grade levels. Placed with content teachers who have received professional development in Sheltered English Immersion (SEI) Provide evidence of the most recent monitoring plan, including all of the above elements, and indicating the name of the individual who will be responsible for monitoring, results of internal monitoring, and actions taken to remedy all areas of non-compliance (as detailed above) by February 19, 2011. Required Elements of Progress Report(s): Provide a report of the completed category training, including the following information: roles and grade levels of staff trained, categories in which staff are trained, and dates of completion by February 19, 2011 Provide an update by April 12, 2011. Progress Report Due Date(s): February 19, 2011; April 12, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 8 Declining Entry to a Rating: Partially Implemented Program Department CPR Finding: The school’s submitted policy declining entry to a program indicates that staff members do not understand the difference between waiving out of a sheltered English immersion (SEI) program and opting out of an SEI program. Narrative Description of Corrective Action: Further research has yielded the following distinction: 1) A parent/guardian may choose to have their child “opt out” of an SEI classroom or any other type of English Language Learner program. 2) A parent/guardian must sign a waiver to allow their student to participate in an SEI classroom or any other type of English Language Learner program every year. The goal of Chapter 71A is to have students participate in an ELL program for as short of an amount of time as possible, while still meeting the needs of students. Title/Role of Person(s) Responsible for Implementation: Principal Expected Date of Completion for Each Corrective Action Activity: complete Evidence of Completion of the Corrective Action: Waiver request and Opt-out forms attached. Description of Internal Monitoring Procedures: Principal ensures that forms are completed and filed in a timely fashion for all identified LEP students. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 8 Declining Entry to a Program Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The charter school is correct regarding what it means to “opt-out” of an English language learner program. However, a parent only signs a waiver when school personnel consider a parental request for an English language learner program other than Sheltered English Immersion (SEI), such as the provision of a Transitional Bilingual Education program instead of an SEI program. The school’s newly developed letter for opting out is not a requirement by Ch. 71A, although each school or district should have a consistent process in place. Codman Academy’s letter lists a set of language programs that are not offered by the school, which may confuse parents. The parents should be informed of their right to opt-out in the initial and annual notification letters, but the ESE is concerned with the use of an additional letter with non-existent program options. The school should also be aware that if a parent does elect to opt out a student from the school’s SEI program, Title VI still requires that students identified as limited English proficient receive English language support to ensure academic progress. The ESE has determined that such support would be comprised of either direct language acquisition support from a certified ESL teacher or sheltered content from general education teachers with a minimum of three (3) categories of training completed, specifically Categories 1, 2, and 4. Additionally, all LEP-identified students, including those who have been opted-out, must be assessed annually with the MEPA and MELA-O to determine if the student is making progress in acquiring English proficiency. Department Order of Corrective Action: Revise the opt-out letters, removing the non-existent programming option. Required Elements of Progress Report(s): Provide the school’s revised opt-out letter. Progress Report Due Date(s): February 19, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 9 Instructional Grouping Rating: Partially Implemented Department CPR Finding: A review of district documents shows that the district does not have an appropriate ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO). While there are no LEP students enrolled at this time, the content instruction provided to LEP students at the charter school would not meet state requirements as the mainstream teachers have completed few category trainings. Narrative Description of Corrective Action: See ELE 5. Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: 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: ELE 9 Instructional Grouping 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): February 19, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 10 Parent Notification Rating: Partially Implemented Department CPR Finding: Codman Academy did not submit a template or example of the parent notification letter that would be used for students identified as LEP. Narrative Description of Corrective Action: Create parent notification letter. Title/Role of Person(s) Responsible for Implementation: Principal Expected Date of Completion for Each Corrective Action Activity: complete Evidence of Completion of the Corrective Action: See attached parent notification letter. Description of Internal Monitoring Procedures: Letter is complete. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Parent Notification Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: CACS’ parent notification letter requiring families to sign a waiver to access the school’s sheltered English immersion (SEI) program is incorrect. According to Ch.71A, once a student has been identified as limited English proficient, entrance into an SEI program is automatic. Upon such placement in the SEI program, and annually thereafter, a notice is mailed to the parents or guardians written in the primary/home language as well as in English and informs parents of: (a) the reasons for identification of the student as Limited English Proficient (LEP); (b) the child’s level of English proficiency; (c) program placement and/or the method of instruction used in the program; (d) the parents’ right to apply for a waiver or to decline to enroll their child in the program. The parents must sign a waiver only to gain entrance into another type of language support program, such bilingual education, which CACS currently does not offer. Additionally, the school does not need to attach either a waiver or opt-out letter to its notification letter. If a parent chooses to opt-out of the SEI program offered at CACS, the school still must support the student’s English acquisition (see ELE 8, above) and annually assess the student’s progress in acquiring English fluency. Additionally, the parents must still be annually notified of the student’s progress. Department Order of Corrective Action: The school should clarify with its staff the distinction between waivers and opt-out; parents do not sign waivers to access SEI programming. Required Elements of Progress Report(s): Revise and re-submit a notification letter that includes elements (a)-(d) only. Revise any procedure developed by the school predicated on the waiving into SEI programming; provide the revised procedures. Progress Report Due Date(s): February 19, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 14 Licensure Requirements Rating: Partially Implemented Department CPR Finding: The charter school currently has no licensed ESL instructors able to provide ESL/ELD instruction. Narrative Description of Corrective Action: As of the 2010-2011 school year, Haley Malm (licensed in ESL, French and History) is a member of the Codman Academy staff. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal Corrective Action Activity: Now Evidence of Completion of the Corrective Action: See copy of licensure attached. Description of Internal Monitoring Procedures: Licensed personnel now on staff. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 14 Licensure Requirements Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: None. Department Order of Corrective Action: None. Required Elements of Progress Report(s): Documentation indicates that the ESL teacher hired is appropriately licensed. See ELE 5 in regards to Codman Academy ensuring that there is at least one licensed ESL instructor on Staff. Progress Report Due Date(s): No further progress reporting necessary. COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Rating: Partially Implemented Development Requirements Department CPR Finding: Content instruction is based on the appropriate Massachusetts Curriculum Framework. However, while there are no LEP students enrolled at this time, the school would be unable to meet the instructional needs of LEP students enrolled going forward as no 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. In fact, the only Categories completed were Category 1 with a generalized SEI PD plan to complete the remaining Categories over the next two years. Narrative Description of Corrective Action: See ELE 5. Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: 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: ELE 15 Professional Development Requirements Status of Corrective Action: Approved Partially Approved 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): February 19, 2011; April 12, 2011. Disapproved