MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Dracut CPR Onsite Year: 2012-2013 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 09/10/2013. Mandatory One-Year Compliance Date: 09/10/2014 Summary of Required Corrective Action Plans in this Report Criterion SE 4 Criterion Title Reports of assessment results SE 6 Determination of transition services SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority IEP Team composition and attendance SE 8 SE 9 SE 11 SE 20 Timeline for determination of eligibility and provision of documentation to parent School district response to parental request for independent educational evaluation Least restrictive program selected CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 25 Criterion Title Parental consent SE 29 SE 41 Communications are in English and primary language of home Age span requirements SE 55 Special education facilities and classrooms CR 3 Access to a full range of education programs CR 8 Accessibility of extracurricular activities CR 9 Hiring and employment practices of prospective employers of students Student handbooks and codes of conduct CR 10A CR 12A CR 21 Annual and continuous notification concerning nondiscrimination and coordinators Counseling and counseling materials free from bias and stereotypes Non-discriminatory administration of scholarships, prizes and awards Staff training regarding civil rights responsibilities CR 24 Curriculum review CR 25 Institutional self-evaluation CR 14 CR 15 CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented 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 4 Reports of assessment results Partially Implemented Department CPR Findings: Review of student records indicated that the district's assessment summaries do not consistently define the student's needs in detail and in educationally relevant and common terms or offer explicit means of meeting those needs. Description of Corrective Action: The Dracut Public Schools will review with all staff conducting evaluations the requirements of 603 CMR 28.04(2)(c). A meeting will be held at each building in the fall of 2013 with relevant staff (psychologists, teachers, therapists and TEAM Chairs) to review this regulation. At that meeting the defined area of concern from the record review will be evaluated. Additionally the relevancy of the teacher’s/specialist’s report in relation to student specific recommendations, access to instruction and the general curriculum (Common Core) and will be stressed. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 06/01/2014 Evidence of Completion of the Corrective Action: All professional student services staff will be given a written summary of the Coordinated Program Review and obligations regarding the requirements. (see attached) Memo: STUDENT SERVICES DEPARTMENT DRACUT PUBLIC SCHOOLS MEMORANDUM To: TEAM Chairs, Out-of-District Coordinator, Pre-School Liaison, Special Education Teachers, School Psychologists, Speech and Language Therapists, Behaviorist and Physical Therapist From: John Mara, Director of Student Services Re: Coordinated Program Review Date: October 7, 2013 While completing the District's response to the Coordinated Program Review (CPR) there are several things that were mentioned that we all need to address. Most of these are a result of the record review conducted on a sample of student records by the Department last winter. I have attached notes on some of the specific sections below and three documents for your records. The documents should be used for reference and if there are any specific questions, please feel free to speak to me. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 3 I plan to speak to the School Committee at the end of the month regarding the District's response to the report. At present this memo is for our purposes only. When received, I will place a full copy of the final report on the District website. Additionally I will be posting, within the coming week, some additional resource materials for you on the Student Services Website to use in preparation of IEP Meetings. SE 4 What this means: Chart from SE4 on staff memo, to be sent under separate cover. In some of the records reviewed by DESE last year no recommendations regarding the student were made on the report. Please note and follow the highlighted section in #1 above. Description of Internal Monitoring Procedures: To ensure compliance the Director of Student Services and the TEAM Chairs will survey ten (10) percent of the assessments completed during the 2013-14 school year for compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 4 Reports of assessment results Corrective Action Plan Status: Approved Status Date: 11/12/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit evidence to ESE on or before January 15, 2014 of staff trainings to ensure that the district's assessment summaries consistently define the student's needs in detail and in educationally relevant and common terms and offer explicit means of meeting those needs. Include evidence such as memorandums, email correspondence, training/meeting agendas, signed attendance sheets, and a sample of training materials. Subsequent to training, submit the results of an administrative record review of a sample of student records, representing records from each school level, for evidence of detailed assessment summaries. This sample must be drawn from records with evaluations conducted after all corrective actions have been implemented. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before May 15, 2014. *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 record review; b) Date of the review; c) Name of the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut 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 record review indicated that the district's IEP Teams discuss a student's transition needs annually beginning when the student is 14 years old; however, document review demonstrated that the district's policy states that transition planning begins when the student is 15, rather than 14 years old as required. Description of Corrective Action: A meeting was held on September 24, 2013 to review this requirement with the teaching staff (agenda and attendance of meeting attached) for both the Junior High School and High School. Agenda: Special Education Meeting Junior High School and High School Staff Meeting September 24, 2013 John Mara Items of Discussion Assistive Technology IPad with speech and language therapists and some students Neo with Co-Writer for grades 7-12 CPR Results Assessments, must contain recommendations within summary Transition Services discussion at age 14, so that may mean 13 years old Age of Majority note in additional information of discussion, hand student’ rights brochure. Needs to be done at age 17, then documented with determination of student’s rights Time Lines for Evaluation - 5 days, 30 days, 43 days and 45 days Least Restrictive Setting for Students - needs to be noted Notes from memo to staff: Begin the transition discussion at age 13 if the student will turn 14 before the next IEP period. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 06/01/2014 Evidence of Completion of the Corrective Action: The Director of Student Services will review on a bi-monthly basis the compliance with MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 5 this requirement by meeting with the Team Chair from grades 6-12 and the Out-ofDistrict Coordinator. Description of Internal Monitoring Procedures: Both Chairs will be asked to keep a log of meetings held for students who are both thirteen and fourteen years old for monitoring purposes. Additionally the Director will work with our software vendor to create a report for continual monitoring of this provision. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 6 Determination of transition services Corrective Action Plan Status: Approved Status Date: 11/12/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit to ESE on or before January 15, 2014 a copy of the district's revised policy and evidence of staff trainings conducted at the Junior High School and High School levels, related to the requirement that IEP Teams discuss a student's transition needs annually beginning when the student is 14 years old. Include evidence such as memorandums, email correspondence, training/meeting agendas, signed attendance sheets, and a sample of training materials including updated TPFs. Subsequent to all trainings, submit the results of an administrative record review, representing a sample of records from the Junior High and High School levels, for evidence of compliance with this criterion. This sample must be drawn from records with Team meetings conducted after all corrective actions have been implemented. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to ESE by May 15, 2014.* 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 the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 7 Transfer of parental rights at age of majority and student Partially Implemented participation and consent at the age of majority Department CPR Findings: Record review indicated that one year prior to the student reaching age 18, the district does not always inform the student and the parent/guardian of the rights that will transfer from the parent/guardian to the student upon the student's 18th birthday. Description of Corrective Action: In each IEP beginning in September of 2013, for students who are 17 or about to turn 17, the liaison will need to note under the Additional Information Section of the IEP that the discussion was held about the transfer of rights and staff will need to note the date of the conversation and the results of that discussion Notes from Memo to staff: DPS DESE Response: In each IEP beginning in September of 2013, for students who are 17 or about to turn 17, the liaison will need to note under the Additional Information Section of the IEP that the discussion was held about the transfer of rights and staff will need to note the date of the conversation and the results of that discussion. A sampling ten percent of the records for students who are of transition age will occur in February 2014 to determine compliance. The results of this survey will be forwarded to the Department in April 2014. What this means for you: See the highlighted section above. Title/Role(s) of Responsible Persons: John Mara, Director of Student Services Expected Date of Completion: 05/01/2014 Evidence of Completion of the Corrective Action: Ninety-five percent of the records surveyed will be compliant. Description of Internal Monitoring Procedures: A sampling ten percent of the records for students who are of transition age will occur in February 2014 to determine compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 11/12/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 7 Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit to ESE on or before January 15, 2014 evidence of staff trainings conducted at the high school level related to ensuring that one year prior to the student reaching age 18, the district informs the student and the parent/guardian of the rights that will transfer from the parent/guardian to the student upon the student's 18th birthday. Include evidence such as memorandums, email correspondence, training/meeting agendas, signed attendance sheets, and a sample of training materials. Additionally, please submit a narrative of the administrative tracking and monitoring system along with role(s) and name of person(s) responsible to ensure timely notification to both student and parent of AOM rights along with evidence of training and tracking system by January 15, 2014. Subsequent to training, submit the results of an administrative record review, representing a sample of records of students who are 17 or about to turn 17, for evidence of compliance with this criterion. This sample must be drawn from records with Team meetings conducted after all corrective actions have been implemented. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before May 15, 2014. *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 the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 8 IEP Team composition and attendance Partially Implemented Department CPR Findings: Record review and parent surveys indicated that regular education teachers do not consistently attend Team meetings even when the student is involved in a regular education program. There was no evidence in the student records that required Team members are excused in writing from attending the Team meetings by parents or provide written input to the parent for the development of the IEP prior to the meeting. Description of Corrective Action: During the first meeting of the TEAM Chairs in the fall of 2013, this regulation will be reviewed. It is important that general education teachers be present to speak about the students’ progress within the general curricular. All meetings should have all of the required TEAM members. Specific instructions of TEAM requirements will be given to the Chairs and all teachers reminding them of this requirement. Notes from Memo to Staff: A full TEAM must be present for all meetings. If a member cannot be present, please note such and have the parents waive participation of that member, see #13 above. #13 References: 13. Members of the Team attend Team meetings unless: a. the parent and district agree to use alternative means, such as a video conference or a conference call, for any Team meeting OR b. the district and the parent agree, in writing, that the attendance of the Team member is not necessary because the member´s area of the curriculum or related services is not being modified or discussed OR c. the district and the parent agree, in writing, to excuse a required Team member´s participation and the excused member provides written input into the development of the IEP to the parent and the IEP prior to the meeting. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 06/01/2014 Evidence of Completion of the Corrective Action: Sampling of completed packets and meeting attendance sheets reviewed and memo to staff reminding of requirement. Description of Internal Monitoring Procedures: The District will monitor by sampling ten percent of the completed IEP’s from October 2013 to April 2014 and reporting to the Department by June 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 8 IEP Team composition and attendance Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 11/12/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 9 Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit evidence of staff trainings to ESE on or before January 15, 2014 regarding Team attendance requirements for general education teachers when the student is involved in a regular education program, the excusal process, and required documentation in the IEP, e.g. excusal forms regarding decision of excusal and means of parental notification of an excused Team member. Evidence may include memorandums, email correspondence, training/meeting agendas, signed attendance sheets, and a sample of training materials. Subsequent to all trainings, submit the results of an administrative record review representing records from each school level, for evidence of attendance by general education teachers as indicated and use of excusal forms as required. This sample must be drawn from records with IEP Teams convened after all corrective actions have been implemented. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to ESE by May 15, 2014. *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 the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: Record review and parent surveys indicated that the district does not always convene a Team meeting within forty-five school working days after receipt of the parent's written consent to an initial evaluation or a re-evaluation to determine whether the student is eligible for special education and either propose an IEP and placement or provide a written explanation of the finding of no eligibility. Description of Corrective Action: During a fall meeting in 2013 the District will give all members of the professional staff in Special Education the 2001 Process Guide from DESE, the Parents Guide to Special Education with particular emphasis on pages 6 and 7 about evaluations and a flow-chart on the time line process. The timelines for Special Education will be reviewed with the building administrators in October of 2014. The Principals will be given the same documents as the teachers. A copy of the agenda of the Administrative Meeting will be forwarded to the Department by November 1, 2013. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 12/01/2013 Evidence of Completion of the Corrective Action: A copy of the agenda of the Administrative Meeting will be forwarded to the Department by November 1, 2013. A copy of the staff memo and attendance sheets at building meetings will be forwarded to the Department by December 1, 2013. Description of Internal Monitoring Procedures: Meetings with staff and administrators fall of 2013. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 9 Timeline for determination of eligibility and provision of documentation to parent Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 11/12/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit to ESE on or before January 15, 2014 evidence of the staff trainings conducted by the district regarding the requirement to convene a Team meeting within forty-five school working days after receipt of the parent's written consent to an initial evaluation or a re-evaluation to determine student eligibility for special education. Evidence may include memorandums, email correspondence, training/meeting agendas, signed attendance sheets, and a sample of training materials. Additionally, submit a narrative description of the district's internal oversight and tracking system with periodic MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 11 administrative review to ensure 45 day timelines noting the role(s)/name(s)of designated person(s) responsible along with evidence of training and tracking procedures to ESE by January 15, 2014. Submit the results of the administrative record review of a sample of student records, representing records from each school level, for evidence of compliance with this criterion. This sample must be drawn from records with IEP Teams convened after all corrective actions have been implemented. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to ESE by May 15, 2014. *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 the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 11 School district response to parental request for Partially Implemented independent educational evaluation Department CPR Findings: Record review indicated that although the district has a detailed letter to respond to parent requests for an independent educational evaluation (IEE), this letter does not include the following: 1) a reference to the 16 month time limit from the date of the evaluation with which the parent disagrees to request an IEE; 2) a reference to the five school day timeline for the district to proceed to the Bureau of Special Education Appeals(BSEA) if the district contests the IEE request; and 3) a reference to the ten school day timeline for the district to convene a Team meeting upon receipt of the report. Description of Corrective Action: The Director of Student Services has reviewed the existing letter and has made changes with regards to current regulations. A copy of the new letter is included in this response. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 11/01/2013 Evidence of Completion of the Corrective Action: A copy of the new letter is included in this response. New Letter: Date: ____________________________________ Student’s Name: _____________________________________ Re: Request for Independent Educational Evaluation (IEE) Dear _______________________________________: I am in receipt of your letter requesting an Independent Educational Evaluation (IEE). Public funding guidelines of Independent Educational Evaluations are contained in Massachusetts Regulations CMR 28.04(5)(c). Relevant language is included below: (c) Public funding of independent education evaluations - When the parent requests public funding for an independent education evaluation, the district shall abide by the following provisions for a sliding fee scale: 1. If the student is eligible for free or reduced cost lunch or is in the custody of a state agency with an Educational Surrogate Parent appointed in accordance with federal law, then the school district shall provide, at full public expense, an independent education evaluation that is equivalent to the types of assessments done by the school district. No additional documentation of family financial status is required from the parent. 2. If the family financial status is not known, the district shall offer the parent information about the sliding fee scale and the opportunity to provide family income information to determine if the family may be eligible for public funding of all or part of the costs of an independent education evaluation. Provision of financial information by the family is completely voluntary on the part of the family. The lack of financial information provided by the family will disqualify the family from such additional public funding of all or part of the costs of an independent education evaluation under 603 CMR 28.04(5)(c) but shall not limit the rights of parents to request public funding under 603 CMR 28.04(5)(d). 3. If the family agrees to provide financial information, such information shall include anticipated annual income of the family, including all sources of income and verifying documents. Financial information shall be reviewed by the district, shall be kept MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 13 confidential during review by the district, shall not be copied or maintained in any form at the district except to note that information was provided and reviewed and met or did not meet sliding fee scale standards. Financial documents shall be promptly returned to the parent upon the district's determination of financial income status. 4. The district shall consider family size and family income information in relation to Federal Poverty Guidelines and shall contribute public funds to the costs of the independent education evaluation according to the following standards: (i) If the family income is equal to or less than 400% of the federal poverty guidelines, the district shall pay 100% of the costs of an independent education evaluation. (ii) If the family income is between 400% and 500% of the federal poverty guidelines, the district shall pay 75% of the costs of an independent education evaluation. (iii) If the family income is between 500% and 600% of the federal poverty guidelines, the district shall pay 50% of the costs of an independent education evaluation (iv) If the family income is over 600% of the federal poverty guidelines, the district shall have no obligation to cost-share with the parent. The District is not in possession of records that would indicate the qualifications for your child to receive a free or reduced lunch. In order to determine the obligation of the District and/or any cost-share requirements; and to move forward with the process, please provide financial information related to family income as described above. Once the District has determined its obligations relative to an independent evaluation you will be contacted to discuss any cost-share agreements and/or the District’s decisions related to your request. Federal poverty guidelines can be found at: http://aspe.hhs.gov/poverty/07poverty.shtml. Please be aware that the District will fund an evaluation that is equivalent to the one conducted by the District. Parents may request fewer, but not additional, types of assessments. Any request for an IEE must be within sixteen months from the date of the evaluation to which you object. If the District objects to your request, the District has five school days to proceed to the Bureau of Special Education Appeals (BSEA). The District will only assume financial responsibility (according to the above fee scale) for assessments equivalent to those listed below: Further the following provision must also be adhered to in order for the independent evaluator to receive financial compensation from Dracut Public Schools: The District will not enter into a financial agreement with an evaluator who is not qualified and/or licensed to conduct an evaluation and/or an evaluator who will not agree to conduct the evaluation at rates set by the Office for Health Care Policy and Finance. Once you have located an appropriate evaluator, please have the evaluator contact my office to make arrangements. Contractual arrangements must be made prior to any testing being completed. Whenever possible, the IEE shall be completed and a written report sent no later than (30) days after the date the parent requests the independent education evaluation. If publicly funded, the report shall be sent to the parent and to the Dracut Public Schools. The independent evaluator shall provide a report that summarizes, in writing, procedures, assessments, results, and diagnostic impressions as well as educationally relevant recommendations for meeting identified needs of the students. The independent evaluator may recommend appropriate types of placements but shall not recommend MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 14 specific programs or schools. 603 CMR 28.04(5)(d) Payment will not be made until this office receives a copy of the Independent Evaluation. The evaluator should send the invoice to the following address: Student Services Office Dracut Public Schools 2063 Lakeview Ave. Dracut, MA 02675 The Dracut Public Schools will convene a TEAM Meeting within ten (10) school working days of receipt of the evaluation information to consider the evaluation and what, if any, changes should be made to your child’s IEP based on the evaluation If you have any questions please feel free to contact my office. Sincerely, John E. Mara, M.Ed. C.A.G.S. Director of Student Services Description of Internal Monitoring Procedures: Use of New Letter CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 11 School district response to parental request for independent educational evaluation Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 11/12/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Progress Report Due Date(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 15 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 20 Least restrictive program selected Partially Implemented Department CPR Findings: Record review indicated that IEP Teams do not always state why a student's removal from the general education classroom is considered critical to the student's program or provide the basis for its conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. Description of Corrective Action: The Director has met with the TEAM Chairs (10/3/13) and reviewed this requirement with them and they will review and reinforce with all teaching staff the need to state why a student’s removal from the general education classroom is considered critical to the student's program and/or provide the basis for its conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily within the general education environment. Notes from Memo to Staff: See highlighted section above. Highlighted Section: why the removal is considered critical to the student’s program and the basis for its conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 06/01/2014 Evidence of Completion of the Corrective Action: Log of ten percent of the IEP's from November to March for compliance. Description of Internal Monitoring Procedures: The Director with the TEAM Chairs will review ten percent of the IEP’s from November to March for compliance and report to the Department its findings in May of 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 20 Least restrictive program selected Corrective Action Plan Status: Approved Status Date: 11/12/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit evidence to ESE on or before January 15, 2014 evidence of staff training regarding the requirement for the Team to specifically state in the IEP nonparticipation justification statement why removal is considered critical to the student's program and cannot be achieved in a general education setting. Include evidence such as MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 16 memorandums, email correspondence, training/meeting agendas, signed attendance sheets, and training materials along with sample IEP nonparticipation justification statements. Subsequent to trainings, submit the results of an administrative record review of a sample of records representing each school level for evidence of nonparticipation justification statements as related to why a student's participation in a least restrictive environment could not be satisfied. This sample must be drawn from records with IEP Team development meetings convened after all corrective actions have been implemented. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to ESE by May 15, 2014. *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 record review; b) Date of the review; c) Name of the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 17 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: SE 25 Parental consent Department CPR Findings: Record review indicated that the district does not always complete that parents have consented to. Description of Corrective Action: Record review indicated that the Pre-School did not conduct Home requested by parents. Title/Role(s) of Responsible Persons: John Mara, Director of Student Services CPR Rating: Partially Implemented home assessments Assessments as Expected Date of Completion: 07/01/2014 Evidence of Completion of the Corrective Action: memo to staff regarding Home Assessments: STUDENT SERVICES DEPARTMENT DRACUT PUBLIC SCHOOLS MEMORANDUM To: Susan Desmond, Pre-School Liaison From: John Mara, Director of Student Services Re: Coordinated Program Review Date: October 7, 2013 While finalizing responses to the District’s response to the Coordinated Program Review from last spring, Criterion SE25 was noted as Partially Implemented. The files selected did not have a home assessment included, if requested by the parent(s). I ask that you please take care in observing this requirement and report to me the names of all students that Home Assessments have been requested on a monthly basis as part of an initial evaluation and/or re-evaluation this academic year. I will need to report this data in June to the Department as part of our compliance monitoring. If there are any questions, please speak with me. The Director has sent a memo to the Pre-School Coordinator concerning this item (above) and will ask for monthly reports on compliance. Description of Internal Monitoring Procedures: The Director will report on compliance based on evidence of logs in June of 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 25 Parental consent Corrective Action Plan Status: Approved Status Date: 11/12/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 18 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit the results to ESE by May 15, 2014 of an administrative record review of a sample of records for evidence of completion of home assessments for those students whose parents have consented to such evaluation. Indicate the number of records reviewed, the number found compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified 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 the person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 19 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: Record review and interviews indicated that the district does not always ensure that documents are translated for parents when the family's primary language is not English. Description of Corrective Action: During the spring of 2013 the District made a connection with the University of MA Lowell, to seek students who are seniors in language and/or education programs to serve as translators for the District. In May of 2013, a student was used at a meeting held at Dracut High School and all documents were provided to the family in the language of the home. Additionally in the summer of 2013 the District spoke with its software vendor ESpEd of Andover, MA and will use the vendor to translate relevant documents if a student from Lowell is not available. Notes from Memo sent to Staff: 1. Please review language settings with ESpEd on all IEP’s in: a. Screen #5 DESE Codes #24 and #25 b. Screen #6 Primary Language of Parents 2. If you have a student on your caseload where English is not the primary language of the parent listed, please check in the office to see what is listed in IPass and if needed, please let my office know a month in advance, so we can arrange for a translator if needed. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 07/01/2014 Evidence of Completion of the Corrective Action: Log of need of translation/interpretive services. Description of Internal Monitoring Procedures: The District will monitor IEP’s from 11/1/13 to 5/1/14. If the primary language listed is not English, the District will report on translation/interpretive services offered to the Department in June of 2014. 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: 11/12/2013 Basis for Status Decision: The Department accepts the district's corrective action plan, but the district must ensure that any interpreter used in fulfilling these requirements is fluent in the primary language of the home and familiar with special education procedures, programs and services. Department Order of Corrective Action: Incorporate into the district's procedures ensuring interpreters used in fulfilling the requirements of this criterion are not only fluent in the primary language of the home, but MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 20 also are familiar with special education procedures, programs and services. Required Elements of Progress Report(s): Please submit to ESE the following on or before January 15, 2014: 1) A detailed narrative of the newly developed internal procedures for determining which parents require special education translations as well as the procedures for requesting translations including copies of any forms for this request and who is responsible for tracking and ensuring that these requests are fulfilled; 2) Evidence of staff trainings, such as signed attendance sheets and agendas, conducted for all staff involved in the process of ensuring translators for IEP Team meetings as required, as well as provision of translations for all special education documentation where parents have requested such translations. Subsequent to the district's corrective action, conduct an administrative review of a sample of student records across all levels for students whose parents have requested translations. Examine for procedural compliance by verifying that the district has provided all documentation to parents, i.e. IEPs, N1s, progress reports, invitations and consent forms (if necessary) in a language that the parents have requested, as well as documentation of oral translations. Report the number of student records reviewed, the number of records that contained required translated parent documents and specific corrective action steps taken to remedy any continuing non-compliance. This progress report is due by May 15, 2014. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s)/signature(s). Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 21 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 41 Age span requirements Partially Implemented Department CPR Findings: Document review and interviews indicated that the age span of the oldest and the youngest student exceeds 48 months in one class for students with Pervasive Developmental Disorder at Campbell Elementary School and in one substantially separate Life Skills class at Dracut High School. Document review indicated that appropriate waivers have not been filed with the Department. Description of Corrective Action: Appropriate waivers for the 2013-2014 academic year have been filed the Department for the HS Life Skills Class and the PDD Elementary Class at the Campbell School. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 12/01/2013 Evidence of Completion of the Corrective Action: Waivers on file with DESE. Description of Internal Monitoring Procedures: Review of students/caseloads and attendance in September of each academic year. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 41 Age span requirements Corrective Action Plan Status: Approved Status Date: 11/12/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit to ESE on or before January 15, 2014 evidence of waiver submissions and current student age span groupings (birth dates) for the 2013-14 academic year for the class for students with Pervasive Developmental Disorders at Campbell Elementary School and the substantially separate Life Skills class at Dracut High School. Progress Report Due Date(s): 01/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 22 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 55 Special education facilities and classrooms Partially Implemented Department CPR Findings: Observations of instructional space at the Brookside School indicated stigmatizing signage such as speech-remedial on a classroom door. Also at the Brookside School, pull-out special education services are provided in Learning Centers on the first floor and lower level while occupational therapy, physical therapy, and other services are provided at the same time. There is no physical barrier separating these activities to mitigate auditory and visual distractions. Description of Corrective Action: A memo concerning signage has been given to the District Director of Maintenance to have the door replaced and/or repaired (see attached). The District will forward a picture of the door in question to the Department by November 1, 2013. The classroom in question on the lower level of the Brookside School has been addressed for 2013-2014. Therapy services (occupation and physical) are in their own space and separated from the educational services provided to students. The District will forward pictures of the educational spaces in question to the Department by November 1, 2013. Memo to Director of Facilities: Memo To: Andy Graham From: John Mara Date: June 27, 2013 Re: Signage at Brookside As part of the Coordinated Program Review that was held in February, the Department sited the District that at Brookside two doors by the library stated Remedial Reading/Speech. I am sure that those signs were painted on the doors when the building was built, but it can be used to identify students that enter for speech therapy. I know that there are a multitude of projects for the maintenance staff this summer, but I do need someone to either paint over those identifying signs, or sand them off the doors. Thank you so much in advance for your assistance. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 23 Title/Role(s) of Responsible Persons: John Mara, Director of Student Services Expected Date of Completion: 11/01/2013 Evidence of Completion of the Corrective Action: Pictures of spaces in question to be forwarded under an email to the Department. Description of Internal Monitoring Procedures: Annual review of building and instructional spaces with each principal. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 55 Special education facilities and classrooms Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 11/12/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): On or before January 15, 2014 please submit to ESE a letter of assurance from the Principal of the Brookside School and the Superintendent of the removal of the identified potentially stigmatizing signage (photos may additionally be uploaded) along with description of relocation of the spaces where occupational and physical therapy services are now provided. Also submit a floor plan with the new locations for noted rooms. A representative of the Department will conduct an onsite visit to the district to verify facilities compliance by May 15, 2014. Progress Report Due Date(s): 01/15/2014 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 24 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 3 Access to a full range of education programs Partially Implemented Department CPR Findings: A review of the district's documents and policies regarding access to a full range of educational programs revealed that gender identity as a protected category is not included. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of Completion: John Mara, Director of Student Services 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review handbooks, and documents during the 2013-2014 academic year and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 3 Access to a full range of education Approved programs Status Date: 11/12/2013 Basis for Status Decision: The District should make available the updated policy upon approval by the School Committee that now includes gender identity as a protected category with a one page insert made available at the front offices of each school before the reprinting in September, 2014. School personnel and the school community should be made aware of this protected class regarding equal access. Department Order of Corrective Action: Please present evidence of the School Committee approved policy change regarding gender identity as a protected category regarding full access to all educational programs. Please create a one page insert and make it available at each front office of all schools within the district as evidence of dissemination of the corrected statement in the handbooks and other hardcopy documents until reprinting in September, 2014. Required Elements of Progress Report(s): On or before May 15, 2014 please submit to ESE evidence of the School Committee approval that gender identity has been added as a protected category regarding equal access to a full range of educational programs and upon approval, a letter of assurance that this correction has been made available to the school community. Also submit any newly corrected documents and training/notice to school personnel of the updated policy regarding gender identity as a protected class. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 25 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 8 Accessibility of extracurricular activities Partially Implemented Department CPR Findings: A review of the district's documents and policies regarding accessibility of extracurricular activities revealed that gender identity as a protected category is not included. Description of Corrective Action: The District has updated its Civil Rights Statement to state “gender identity”, not “gender equity” as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of Completion: John Mara, Director of Student Services 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review meet with the principals to ensure the up to date statement of non-discrimination is on "official" documentation and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 8 Accessibility of extracurricular Approved activities Status Date: 11/12/2013 Basis for Status Decision: The District should make available the updated policy upon approval by the School Committee that now includes gender identity as a protected category with a one page insert made available at the front offices of each school before the reprinting in September, 2014. School personnel should be made aware of this protected class regarding access to extracurricular activities. Department Order of Corrective Action: Please submit evidence to ESE of the School Committee approved policy change regarding gender identity as protected category regarding access to extracurricular activities. Please create a one page insert and make it available at each front office of all schools within the district as evidence of dissemination of the corrected statement until reprinting of hardcopy documents in September, 2014. Required Elements of Progress Report(s): Please submit to ESE on or before May 15, 2014 evidence of the School Committee approval that gender identity has been added as a protected category regarding access to extracurricular activities and upon approval, a letter of assurance that this correction has been made available to the school community. Also submit any newly corrected documents and training/notice to school personnel of the updated policy regarding gender identity as a protected class. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 26 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 9 Hiring and employment practices of prospective employers Partially Implemented of students Department CPR Findings: A review of the district's documents indicated that the statement signed by employers recruiting at the high school does not include gender identity as a protected category. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review meet with the principals to ensure the up to date statement of non-discrimination is on "official" documentation and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 9 Hiring and employment practices of Approved prospective employers of students Status Date: 11/12/2013 Basis for Status Decision: The District should make available the updated policy upon approval by the School Committee that now includes gender identity as a protected category with a one page insert made available at the counselor's office at the high school before the reprinting in September, 2014. School personnel should be made aware of this protected class and ensure that there is an updated statement signed by recruiting employers that includes gender identity protection in its anti-discrimination statement. Department Order of Corrective Action: Please submit evidence to ESE of the updated School Committee approved policy change regarding gender identity as a protected category included in the statement to be signed by recruiting employers at the high school. Please create a one page insert and make it available at the guidance office of the high school as evidence of dissemination of the corrected statement until reprinting in September, 2014. Required Elements of Progress Report(s): Please submit to ESE on or before May 15, 2014 evidence of the updated School Committee policy statement that gender identity has been added as a protected category regarding employer recruitment at the high school with a letter of assurance that this correction has been made available to the school community. Also submit any newly corrected documents and training/notice to school personnel of the updated policy regarding gender identity as a protected class. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 27 Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 28 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 10A Student handbooks and codes of conduct Partially Implemented Department CPR Findings: Review of the district's student handbooks and codes of conduct revealed that the district's nondiscrimination policy does not include gender identity as a protected category. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review each handbook and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 10A Student handbooks and codes of Approved conduct Status Date: 11/12/2013 Basis for Status Decision: The District should make available the updated policy upon approval by the School Committee that now includes gender identity as a protected category with a one page insert made available at the front offices of each school before the reprinting in September, 2014. The school community should be made aware of this protected class. Department Order of Corrective Action: Please present evidence of the School Committee approved policy change regarding gender identity as protected category. Please create a one page insert and make it available at each front office of all schools within the district as evidence of dissemination of the corrected statement in the handbooks and code of conduct until planned reprinting in September, 2014. Required Elements of Progress Report(s): On or before May 15, 2014 please submit to ESE evidence of the School Committee policy approval that gender identity has been added as a protected category along with a letter of assurance from the Superintendent that this correction has been made available to the school community. Also submit the insert made available at all schools until reprinting of student handbooks and code of conduct with the updates planned for September, 2014. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 29 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 12A Annual and continuous notification concerning Partially Implemented nondiscrimination and coordinators Department CPR Findings: Review of the district's written materials and other media used to publicize a school does not include gender identity as a protected category. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review meet with the principals to ensure the up to date statement of non-discrimination is on "official" documentation and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 12A Annual and continuous Approved notification concerning nondiscrimination Status Date: 11/12/2013 and coordinators Basis for Status Decision: See CR 3. Department Order of Corrective Action: See CR 3. Required Elements of Progress Report(s): See CR 3. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 30 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 14 Counseling and counseling materials free from bias and Partially Implemented stereotypes Department CPR Findings: A review of the district's documents and policies to ensure that counseling and counseling materials are free from bias and stereotypes revealed that gender identity as a protected category is not included. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review meet with the principals to ensure the up to date statement of non-discrimination is on "official" documentation and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 14 Counseling and counseling Approved materials free from bias and stereotypes Status Date: 11/12/2013 Basis for Status Decision: School personnel should be made aware of this protected class to ensure that when reviewing counseling and counseling materials for bias and stereotypes, gender identity has been added as a protected category. Department Order of Corrective Action: The district must train its staff and school counselors that gender identity is an added protected category to ensure that counseling and counseling materials are not biased or stereotypical. Required Elements of Progress Report(s): On or before May 15, 2014 please submit evidence of counselor policy changes along with staff trainings conducted to evidence that gender identity is now included upon review of counseling and counseling materials and ensure that they are free from bias and stereotypes. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 31 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 15 Non-discriminatory administration of scholarships, prizes Partially Implemented and awards Department CPR Findings: A review of the district's documents and policies to ensure that scholarships, prizes and awards sponsored or administered by the district are free of restrictions, revealed that gender identity as a protected category is not included. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review meet with the principals to ensure the up to date statement of non-discrimination is on "official" documentation and submit a statement of assurance to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 15 Non-discriminatory administration Approved of scholarships, prizes and awards Status Date: 11/12/2013 Basis for Status Decision: See CR 3. Department Order of Corrective Action: See CR 3. Required Elements of Progress Report(s): See CR 3. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 32 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 21 Staff training regarding civil rights responsibilities Partially Implemented Department CPR Findings: A review of the district's policies and procedures regarding staff training on civil rights responsibilities revealed that gender identity as a protected category is not included. Description of Corrective Action: All professional staff during the opening days of school took part in an on-line training program including Civil Rights Training. One of the questions involved the issue of gender as a protected class. the training is available for review at: https://docs.google.com/file/d/0B8VplUKZzQeXZnVEVWpsbUxNTTg/edit?usp=sharing&pli =1 Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 11/01/2013 Evidence of Completion of the Corrective Action: Certificates of staff are available for review and/or forwarding to the Department. Description of Internal Monitoring Procedures: Staff were to submit certificates of completion to the building principals and they were forwarded to the Personnel Office. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 21 Staff training regarding civil rights responsibilities Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 11/12/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Progress Report Due Date(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 33 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 24 Curriculum review Partially Implemented Department CPR Findings: A review of the district's policies and procedures regarding curriculum review revealed that gender identity as a protected category is not included. Description of Corrective Action: The District has updated its Civil Rights Statement to state "gender identity", not "gender equity" as previously forwarded to the Department. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: The District has updated the statement on the website (http://dracutps.org/district/student-services) and begun to use the statement in documents for staff (i.e. DCAP http://dracutps.org/sites/dracutsd/files/u550/dcap_201314_9-17-13.pdf) The District will work with each principal, to make sure that all handbooks and other documents contain the up to date language and have full implementation for September 1, 2014. Description of Internal Monitoring Procedures: The Director will review meet with the Director of Curriculum and Assessment to ensure that any and all materials purchased meet the new non-discrimination criteria. Any materials adopted during the 2013-2014 school year will be reported to the Department by September 1, 2014. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 24 Curriculum review Corrective Action Plan Status: Approved Status Date: 11/12/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Progress Report Due Date(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 34 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: According to document review, although the district reviews all programs, including athletics and other extracurricular activities, on a regular basis to ensure equal access for all students, there is no evidence that the district keeps documentation of the evaluation activities, the conclusions reached on the basis of the evaluation, and any steps taken to resolve identified problems. Description of Corrective Action: The District will work to establish procedures during the coming academic year (20132014) to establish a set procedure for review of all programs to ensure equal access for all students. Title/Role(s) of Responsible Persons: Expected Date of John Mara, Director of Student Services Completion: 09/01/2014 Evidence of Completion of the Corrective Action: Procedure for yearly review and establishing who is responsible for data collection at all levels. Description of Internal Monitoring Procedures: Report of findings and procedure to the Department on 09/01/2014 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Approved Status Date: 11/12/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a narrative to ESE of the newly developed procedures along with role(s)/names of person(s) responsible for ensuring that all programs are evaluated on an annual basis for equal access to all students including the newly added protected category of gender identity, and documentation of the 2013-2014 evaluation activities. Include in submissions materials and surveys, meeting dates, conclusions reached on the basis of the evaluation, and any steps planned to resolve identified issues by May 15, 2014. Progress Report Due Date(s): 05/15/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 35 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW District: Dracut Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: David S. Hill / Director of Curriculum, Instruction, & Assessment Margaret Biedron / ESL District Chairperson 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 2, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 5 Program Placement and Structure Department CPR Finding: District documentation indicated that in elementary schools ELLs at all proficiency levels receive instruction in their regular mainstream classroom with the support of an ESL paraprofessional. Therefore, at the time of the review not all English Language Learners (ELLs) were receiving ESL instruction from appropriately licensed English as Second Language (ESL) teachers within the district. District documentation demonstrated that the district uses Hampton Brown/National Geographic Inside the USA, Edge Fundamentals and Edge level A with their Newcomers and some online programs called ELLIS Academic and ESL Reading Smart as their curriculum. While purchased materials can be used as resources they cannot replace the curriculum districts are expected to develop based on WIDA standards. Beginning in the 2012-2013 school year, districts are expected to integrate the WIDA standards into ESL and content area curricula for classes where ELLs participate. However, based on the documentation reviewed there is no indication that the district had a plan in place at the time of the onsite visit, to review or develop a plan for integrating WIDA standards into content area and ESL curricula. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 36 1. Narrative Description of Corrective Action: 2. 1. ESL Staff 3. The district anticipates the hiring of a 1.0 ELL certified teacher in grades K-4 for FY 2015 to replace the present three part time ESL paraprofessionals. 4. 5. 2. ESL curriculum: ➢ The following steps are being taken to meet the defined need for an established ELL curriculum: ➢ -ELA and Math draft curriculum mapping and unit development, integrating the WIDA standards, will be completed by the end of the 2015 school year. ➢ -The district is actively participating in the creation of ELL curriculum. Margaret Biedron, ESL Chair, & Marion Brown, ESL Teacher, participated in the 2-day, Massachusetts Association of Teachers to Students of Other Languages (MATSOL) ESL curriculum working group in the summer of 2012, where grade level teams worked on Newcomer ESL curriculum. It is their intent to continue working with MATSOL on this curriculum development. 1. Title/Role of Person(s) Responsible for 1. Expected Date of Completion for Each Implementation: Corrective Action Activity: 2. 1. David S. Hill - Director of Curriculum, 2. September 2015 Instruction and Assessment and Margaret Biedron ESL District Chairperson 2. David S. Hill - Director of Curriculum, September 2014-June 2015 Instruction and Assessment, Margaret Biedron ESL District Chairperson and Marion Brown - ESL Teacher 5-8 Content area teachers Evidence of Completion of the Corrective Action: * The district anticipates hiring a 1.0 licensed ESL teacher to provide ELL instruction in grades K-4 to replace the current three paraprofessionals for the 2015-2016 school year * Initial ELA and Math curriculum maps and units created with embedded WIDA standards will be complete by the end of 2015. * Dracut ELL staff will continue with active participation on MATSOL ELL committee creating ELL curriculum 1. Description of Internal Monitoring Procedures: 2. The district anticipates the hiring of a 1.0 ELL teacher whom the ESL District Chairperson will oversee at the beginning of the 2015-2016 school year. 3. The Director of Curriculum, Instruction and Assessment will oversee the curriculum development portion of the project. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): 1) Please provide a detailed plan that shows that the district is providing sufficient ESL MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 37 instruction to all ELL students during the 2013-2014 school year based on the Department's Transitional Guidance on Identification, Assessment, Placement, and Reclassification of English Language Learners found at http://www.doe.mass.edu/ell/TransitionalGuidance.pdf 2) Please complete district information in the attached spreadsheet labeled ELL List by school for each ELL student in the district. 3) Submit a plan that includes information about a process for reviewing or developing ESL curriculum that integrates WIDA ELD standards. a plan for WIDA implementation including information such as WIDA training opportunities for the district staff, responsible district staff, meeting dates, minutes and signing sheets and timelines for implementation Progress Report Due Date(s): October 23, 2014 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: Documentation submitted indicated that elementary and middle school ELL students receive instruction in their regular mainstream classroom. The pull-out option is available when needed. High school students are placed in self-contained classes. The district did not submit documentation about how students are grouped in any of these settings when providing ESL instruction. Therefore, it is unclear whether the district only groups ELL students together in instructional settings if their levels of English proficiency are similar as indicated in G.L. c. 71A, § 4. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 38 Narrative Description of Corrective Action: ESL instruction, as noted within our initial Coordinated Review, in the district is designed and implemented as follows: Grades 9-12 Dracut Senior High School presently offers the following three ESL classes: Newcomer I is for ELL students in grades 9-12 whose proficiency level is 1&2. Newcomer II is for ELL students in grades 912 whose proficiency level is 3. ESL is for ELL students in grades 9-12 whose proficiency levels are 4, 5, & 6. Level 1 & 2 ELLs are enrolled in all of the above ESL classes. Level 3 ELLs are enrolled in Newcomer II and ESL. Levels 4, 5 & 6 are enrolled in the one ESL class. Grades 7-8 The Lakeview Jr. High School offers a Newcomer class which is appropriate for ELL students in grades 7&8 whose proficiency level is 1 and/or 2. ELL students at Levels 3 -6 are pulled out for ESL instruction and the amount depends on their individual level of proficiency, which the ESL Department aligns with the DESE’s recommended amount of instruction for ELLs. Grades K-6 ELL students in the elementary grades of K-6 receive ‘pull-out” ESL instruction. The amount depends on their level of English proficiency as well as their grade level. Newcomers (levels 1 & 2) receive 2 periods daily of ESL instruction and are grouped by the following grade spans; Kindergarten, grades 1&2, grades 3&4, and grades 5&6, to ensure age appropriate instruction. Levels 3-6 are grouped with other ELLs in the same grade to ensure appropriate grade level ESL instruction, whereas ELLs at these specific levels of proficiency benefit from specific content area instruction, therefore grade level grouping is vital. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Corrective Action Activity: Ongoing protocol Implementation: Margaret Biedron/ESL District Chairperson Evidence of Completion of the Corrective Action: Dracut High School & Lakeview Jr. High course offerings and schedules of ESL teachers and ESL paraprofessionals. Description of Internal Monitoring Procedures: The district ESL Chairperson will continue to monitor the proficiency levels of ELLs district wide and the amount of ESL instruction each student is receiving to ensure the appropriate delivery method. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 9 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a copy of the most recent ESL teacher schedules for all grade levels district wide. All schedules should include the following for each block of time: 1. Names of the ELL students 2. Grade level for each student 3. English proficiency level for each student. Progress Report Due Date(s): October 23, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 39 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: Review of student records and staff interviews indicated that although the district has waiver and opt out procedures, parent notification letters do not inform parents of their right to apply for a waiver or decline to enroll their child in the English learner education (ELE) program. In addition, the district does not currently have a system or procedure for ensuring that parents of English language learners (ELL) have documents, such as progress reports and report cards, translated into their primary language. Progress and report cards in different languages 1. Narrative Description of Corrective Action: 2. The district has created an ELL Parental/Guardian Waiver document explaining parent/guardian’s right to decline from the recommended ESL instruction. This waiver was included in this year’s parent/guardian letters sent home for ESL programming during the 2013-2014 school year. 3. The district’s Home Language Survey, which is available in 30 different languages, includes parental requests for oral and/or written communication in their native language. The ESL Chairperson will work with the Special Education office and ESPED to translate documents requested for translation. 1. Title/Role of Person(s) Responsible for 2. 1. 2. 1. 2. 1. Expected Date of Completion for Each Implementation: Corrective Action Activity: Margaret Biedron/ESL District Chairperson 2. Presently implemented David S. Hill/ Director of Curriculum, Instruction June 2014 and Assessment, Margaret Biedron/ESL District Chairperson Evidence of Completion of the Corrective Action: Revised district ELL waiver attached Translated progress & report cards in the native languages requested Description of Internal Monitoring Procedures: The district’s ELL waiver will continue to be sent home with all parent notification letters. The ESL Chairperson will continue to review all of the district’s Home Language Surveys and identify parents who are in need of oral and/or written communication in their native language. Translated progress and report cards will be sent home to these parents. 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: Department Order of Corrective Action: Required Elements of Progress Report(s): No further progress reports are required for this criterion. Progress Report Due Date(s): N/A MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 40 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: Documentation reviewed indicates that in elementary schools, ESL instruction is not delivered by a teacher who holds an ESL license or current waiver issued by the Massachusetts Department of Elementary and Secondary Education. Narrative Description of Corrective Action: Please see ELE 5 for clarification. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: David S. Hill/ Director of Curriculum, Instruction September 2015 and Assessment Evidence of Completion of the Corrective Action: The district anticipates hiring a 1.0 licensed ESL teacher for the 2015-2016 school year. Description of Internal Monitoring Procedures: ELLs in grades K-4 will receive ESL instruction by a licensed ESL teacher. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 14 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Please provide evidence of the licensure of the current ELL teacher(s) or any other staff person providing ESL instruction to ELLs by the progress report due date. Progress Report Due Date(s): October 23, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 Records of ELL Students Rating: Partially Implemented Department CPR Finding: Student record review indicated that for students who have not passed the MCAS, there are no Individual Student Success Plans in the student files. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 41 Narrative Description of Corrective Action: Clarification provided by the ELL office at the DESE regarding ISSP stated the district does not qualify under the 20% or more students performing below proficiency threshold and thus does need to create ISSPs. Educational Proficiency Plans (EPP) are implemented for ELL students who do not pass MCAS in either ELA or Math. These plans are placed in the student’s Cumulative/ELL folder. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Dracut High School Guidance Department November 2014 ESL District Chairperson Evidence of Completion of the Corrective Action: Educational Proficiency Plans for ELL students who have not successfully passed MCAS. Description of Internal Monitoring Procedures: The ESL District Chairperson will monitor the ELL folders to ensure they contain Educational Proficiency Plans for students who have not successfully passed MCAS. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): No further progress reports are required for this criterion. Progress Report Due Date(s): N/A MA Department of Elementary & Secondary Education, Program Quality Assurance Services Dracut CPR Corrective Action Plan 42