MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Edward Brooke Charter School CPR Onsite Year: 2009-2010 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 08/20/2010. Mandatory One-Year Compliance Date: 08/20/2011 Summary of Required Corrective Action Plans in this Report Criterion SE 4 Criterion Title Reports of assessment results SE 19 Extended evaluation SE 29 Communications are in English and primary language of home Parent advisory council for special education Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Professional development SE 32 SE 46 SE 54 CPR Rating Partially Implemented Partially Implemented Partially Implemented Not 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: The student record review identified that assessors are not always defining in detail and in educationally relevant terms, the students needs and offering explicit means of meeting those needs. Several assessment reports indicated that recommendations will be presented at the IEP team meeting. Description of Corrective Action: The director of student support will conduct professional development for all special education teachers and related service staff who write assessment reports. The objectives of the professional development will be to develop common reports standards to ensure that the assessment reports consistently summarize the student's needs and offer explicit means of meeting those needs. Additionally, the director of student support will conduct internal monitoring of student records to ensure those assessors are maintaining the established report standards. Anticipated Results: All assessment reports will define in detail and in educationally relevant terms, the students needs, offer explicit means of meeting those needs and the assessor s recommendations. Title/Role(s) of responsible Persons: Expected Date of Cristie McGrath - Director of Student Support Completion: 02/28/2011 Evidence of Completion of the Corrective Action: 1) The district will submit a copy of agenda and sign in sheet from professional development 2) The district expects to see evidence of correction through the assessment reports reviewed as part of the internal monitoring Description of Internal Monitoring Procedures: The director of student support will select a sample of student records. The records selected will be either initial evaluations or reevaluations. This will ensure that the file contains assessments reports from both teachers as well as related service providers. If any assessment reports identified in the review do not contain the information regarding the students needs and explicit means of meeting those needs, than the special education administrator will complete the following: 1) immediately remedy the individual student file; 2) conduct an analysis to determine if similar student files lack the required information in assessment reports and determine if additional professional development is needed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 4 Reports of assessment results - Corrective Action Plan Status: In Process Status Date: 09/29/2010 Basis for Partial Approval or Disapproval: The Department has accepted the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 2 Please submit evidence, such as agenda and sign-in sheets, for the professional development held with special education staff and related service personnel responsible for conducting and writing assessment reports. This progress report is due 12/22/2010. Please submit the results of the internal monitoring conducted (including a narrative describing the district's findings) to ensure that all special education and related service responsible for conducting and writing assessment reports are adhering to the requirement of summarizing the student's needs and offering an explicit means of meeting those needs in the assessment report. Please identify the root cause of any noncompliance identified and the subsequent corrective action(s), if any are identified. Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). This progress report is due 3/18/2011. Progress Report Due Date(s): 12/22/2010 03/18/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 3 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 19 Extended evaluation Partially Implemented Department CPR Findings: The student record review identified that the district does not always convene an IEP team meeting to develop a partial IEP based on any available and sufficient evaluation information before initiating a parental consent for an extended evaluation. Description of Corrective Action: Step 1. The school district will develop procedures to following when an extended evaluation is needed. The director of student support will conduct professional development for all special education teachers and related service staff. This procedure will include a process for making sure special education staff is aware that an IEP team must meet to develop a partial IEP based on any available and sufficient evaluation information before initiating a parental consent for an extended evaluation. Professional development will be provided to special education staff with regards to this new procedure. Step 2. Additionally, the director of student support will conduct internal monitoring of student records to ensure team meetings are begin held and partial IEPs are developed during these meetings before extended evaluations are proposed. Anticipated Results: In all cases, the district will convene an IEP team meeting to develop a partial IEP before recommending extended evaluations. Title/Role(s) of responsible Persons: Expected Date of Cristie McGrath - Director of Student Support Completion: 02/28/2011 Evidence of Completion of the Corrective Action: 1) The district will submit a copy of the agenda and sign in sheet from professional development 2) The district expects to see evidence of correction as part of the internal monitoring (if any extended evaluations are proposed during this time). Description of Internal Monitoring Procedures: The director of student support will review all files that have had an extended evaluation proposed. If any files are do not follow the new procedure, than the special education administrator will complete the following: 1) immediately remedy the individual student file; 2) develop a new procedure to ensure compliance and provide additional professional development CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 19 Extended evaluation - Corrective Action Plan Status: In Process Status Date: 09/29/2010 Basis for Partial Approval or Disapproval: The Department has accepted the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit a copy of the newly developed procedure regarding the appropriate use of MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 4 an extended evaluation. Additionally, please submit evidence such as agendas and sign-in sheets, that staff received training on the newly developed procedure. This progress report is due 12/22/2010. Please submit the results of the internal monitoring conducted ( including a narrative describing the district's findings) to ensure that all special education staff and related service personal are adhering to the newly developed extended evaluation procedures. Please identify the root cause of any non-compliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). This progress report is due 3/18/2011 Progress Report Due Date(s): 12/22/2010 03/18/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 5 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: The student record review identified that communications are not always provided in the primary language of the home when the language identified as other than English. Additionally, student records and staff interviews identified that when notices are provided verbally, the district does not keep written documentation that it has provided such notice in an alternate manner, the content of the notice, and the steps taken to ensure that the parent(s) understood the content of the notice. Description of Corrective Action: Step 1. See CAP for CR # 7 Step 2. The school district will develop procedures to following for communicating with parent(s) when their primary language is not English. The director of student support will conduct professional development for all special education teachers and related service staff. This procedure will include a process for making sure special education staff is aware that all oral translations must be documented and include the following: a. primary language of parent(s) b. name of the person translating c. content of the conversation or notice d. steps taken to ensure that the parent(s) understood the content of the notice Step 3. Professional development will be provided to special education staff with regards to this new procedure. Step 4. Additionally, the director of Student Support will conduct internal monitoring of student records to ensure these procedures are being followed. Anticipated Results: All written communication will be translated into parent(s) primary language. Any oral translations will be documented and with the following information: a. primary language of parent(s) b. name of the person translating c. content of the conversation or notice d. steps taken to ensure that the parent(s) understood the content of the notice Title/Role(s) of responsible Persons: Expected Date of Cristie McGrath - Director of Student Support Completion: 02/28/2011 Evidence of Completion of the Corrective Action: 1) The district will submit a copy of the agenda and sign in sheet from professional development 2) The district expects to see evidence of correction as part of the internal monitoring. Description of Internal Monitoring Procedures: The director of student support will review all files of students whose parents' primary language is not English. If any files indicate procedures have not been followed, the director of student support will complete the following: 1) immediately remedy the individual student file; 2) develop a new procedure to ensure compliance and provide additional professional development MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 6 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: In Process SE 29 Communications are in English and Status Date: 09/29/2010 primary language of home Basis for Partial Approval or Disapproval: The Department has accepted the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit a copy of the newly developed procedure regarding communications, both oral and written to parents in a language or mode that they can understand. Additionally, please submit evidence such as agendas and sign-in sheets, that staff have been notified of the newly developed procedure. This progress report is due 12/22/2010. Please submit the results of the internal monitoring conducted to ensure communications to parents are in a language and mode that they can understand. Please identify the root cause of any non-compliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). This progress report is due 3/18/2011 Progress Report Due Date(s): 12/22/2010 03/18/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 7 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 32 Parent advisory council for special education Not Implemented Department CPR Findings: The document review and staff interviews verified that the district does not have a parent advisory council for special education. Description of Corrective Action: Step 1. The director of student support will contact a parent of a child on an IEP to ask if he/she would like to be a special education PAC officer. Step 2. The new PAC officer and director of student support will meet to discuss the issues EWBCS has faced in the past with generating a Sped PAC. They will create a list of ways to engage, recruit and keep parents active member of the Sped PAC. They will also plan the first Parents' Rights Workshop. Ideally another agenda item on this night will interest parents which may increase participation. Step 3. EWBCS will hold the Parents' Rights Workshop Step 4. Ideally, after the Parents Rights Workshop event more parents will want to join and become active members of the Spec. PAC. Step 5. The Sped Pac officers will meet and discuss recruitment, concerns of parents and schedule future Sped PAC meetings Step 6. Sped PAC meeting will be held to develop By-Laws and continue discussions Anticipated Results: The Parent Advisory Council will meet regularly with the Director of Student Services and the School Committee (or a subgroup of the School Committee) to advise the district on matters that pertain to the education and safety of student with disabilities. Title/Role(s) of responsible Persons: Expected Date of Cristie McGrath - Director of Student Support Completion: 02/28/2010 Evidence of Completion of the Corrective Action: Step 1 - 3 The district will submit the following -minutes of PAC meetings that include date and attendance -Parents' Rights Workshop recruitment notices -Parents' Rights Workshop Event agenda and sign-in sheet Step 4-6 The district will submit the following -minutes of PAC meetings that include date and attendance -EWBCS Sped PAC by-laws Description of Internal Monitoring Procedures: The director of student support will create a 2010-2011 school year calendar with the meetings, events and activities listed in steps 1 - 6. She will review progress towards meeting these deadlines each week. If deadlines are not being met the special education administrator will immediately remedy the situation by either scheduling the meeting or event as soon as possible or change the calendar to allow for more time however no part of step 1- 6 will take place after April of 2011. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 32 Parent advisory council for special Corrective Action Plan Status: In Process Status Date: 09/29/2010 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 8 education Basis for Partial Approval or Disapproval: The Department has accepted the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): In order to ensure that the membership on the council is offered to all parents of children with disabilities as well as other interested parties, please submit evidence of all recruitment conducted. Additionally, please submit evidence that the newly developed PAC has held a workshop on the rights of students and their parents and guardians under the state and federal special education laws. Finally, please submit a copy of the Special Education PAC by-laws regarding officers and operational procedures. This progress report is due 3/18/2011 Progress Report Due Date(s): 12/22/2010 03/18/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 9 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 46 Procedures for suspension of students with disabilities Partially Implemented when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Department CPR Findings: Although the district does conduct manifestation determinations for students who have reached 10 consecutive or cumulative days of suspension, the document review identified that the district does not have a policy or a procedure in place for the provision of services once the team has determined that the behavior is not a manifestation of the disability and the suspension or expulsion may go forward. Additionally, staff interviews and document review identified that the district does not have a policy or procedure for students who have been placed in an interim alternative educational setting (IAES) either by the authority of the school district or by the authority of a hearing officer. Description of Corrective Action: Step 1. The school district will revise its policy regarding procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days. This revised policy and procedures will include the following a. an explanation of how the provision of services will continue once the team has determined the behavior is not a manifestation of the disability and the suspension or expulsion goes forward b. the schools policy for students who have been placed in an interim alternative educational setting (IAES) either by the authority of the school district or by the authority of a hearing officer Step 2. The director of student support will conduct professional development for all teaching staff, administrators and special education staff. Step 3. The director of student support will conduct internal monitoring of student records to ensure students who have been suspended for more than 10 days are receiving services during days they are suspended and any student who has have been placed in (IAE) was done so following EWBCS policy and procedures. Anticipated Results: The newly developed policy and procedure will ensure the following: -services will continue on days of suspension for students who have exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days after a team has determined the behavior is not a manifestation of the disability and the suspension or expulsion goes forward -the district's policy for students who have been placed in an interim alternative educational setting (IAES) either by the authority of the school district or by the authority of a hearing officer will be followed Title/Role(s) of responsible Persons: Expected Date of Cristie McGrath - Director of Student Support Completion: 02/28/2011 Evidence of Completion of the Corrective Action: 1) The district will submit a copy of the agenda and sign in sheet from professional development. 2) The district expects to see evidence of correction as part of the internal monitoring. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 10 Description of Internal Monitoring Procedures: The director of student support will review all student files in which students have been suspended for more than 10 days and/or been placed in an IAES. If any files are found that do not follow the new procedure, than the special education administrator will complete the following: 1) immediately remedy the individual student file or situation (if possible) 2) develop a new procedure to ensure compliance and provide additional professional development CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: In Process SE 46 Procedures for suspension of Status Date: 09/29/2010 students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Basis for Partial Approval or Disapproval: The Department has accepted the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit a copy of the newly developed procedure regarding suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days. Additionally, please submit evidence such as agendas and sign-in sheets, that staff have been notified of the newly developed procedure. This progress report is due 12/22/2010. Please submit the results of the internal monitoring conducted to ensure that the provision of services beyond a students tenth cumulative or consecutive day of suspension adheres to the district's newly developed policy. Please identify the root cause of any non-compliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). This progress report is due 3/18/2011 Progress Report Due Date(s): 12/22/2010 03/18/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 11 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 54 Professional development Partially Implemented Department CPR Findings: Staff interviews indicated that the district does not conduct professional development activities pertaining to state and federal special education requirements and related local special education policies and procedures. Description of Corrective Action: School year 2010 - 2011 Step 1. Through this CPR the director of student support has created a comprehensive list of professional development needs of all new procedures, policies, laws and regulations that must be provided for the EWBCS staff. Step 2. This list will be shared with the principals of the school and a time to conduct the PD will be scheduled before winter recess. Step 3 Professional development will occur before March 2011. Beyond school year 2010-2011 Step 1. Two times annually during special education staff meetings the director of student support will conduct a needs assessment survey. This survey will give staff an opportunity to report what they would like to learn more about in terms of state and federal special education laws. In addition to this, the director of student support will create an annual list of laws, procedures, policies that have changed that staff members need to be informed of. Step 2. EWBCS will continue to conduct pre-year meetings with all teaching staff with regards to students on IEPs and 504 plans. In addition to this annual professional development the special education staff will engage in annual or biannual professional development on state and federal special education laws, and/or new polices or procedures the school has adopted. Step 3. The director of student support will conduct internal monitoring system, as part of the special education program evaluation, to ensure the professional development has occurred. Anticipated Results: Annual or biannual professional development will be given to staff pertaining to state and federal special education requirements and related local special education policies and procedures. Title/Role(s) of responsible Persons: Expected Date of Cristie McGrath - Director of Student Support Completion: 02/28/2011 Evidence of Completion of the Corrective Action: 1) The district will submit a copy of the agenda(s) and sign in sheet(s) from professional development 2) The district expects to see evidence of correction as part of the internal monitoring. Description of Internal Monitoring Procedures: The director of student support will include the SE 54 requirement on the special education program evaluation form that is conducted annually. The annual program review will be completed in March of each year so that if noncompliance in this area exists by March, remedies can be put forth to correct before the end of the school year. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 12 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 54 Professional development - Corrective Action Plan Status: In Process Status Date: 09/29/2010 Basis for Partial Approval or Disapproval: The Department has accepted the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit evidence such as agendas and sign-in sheets, of professional development to all staff on local special education polices and procedures as well as state and federal special education laws and regulations. This progress report is due 3/18/2011. Progress Report Due Date(s): 12/22/2010 03/18/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 13 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Edward W. Brooke Charter School Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Name of School/District Staff Member CAP Form will expand to as many lines as necessary. Before completing and emailing to pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans. All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report to the school or district. Mandatory One-Year Compliance Date: August 19, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7 Information to be translated Rating: Partially Implemented into a language other than English. Department CPR Finding: The document review indicated that important information, e.g. handbooks and codes of conduct are only translated into Spanish and not the other major languages spoken by parents within the school community. In addition, the document review identified that recruitment and promotional materials are only being translated into Spanish and not the other major languages spoken by parents within the school community. Although several staff members are available to provide oral translations, document review and staff interviews indicate that the district does not have an established system of oral interpretation to assist parents/guardians with limited English skills, including those who speak low-incidence languages MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 14 Narrative Description of Corrective Action: Part 1: Translation of Internal Documents The Director of Operations will resend the census form to all parents asking in what language they would like documents to be sent home. After identifying all translation needs, the Director of Operations will locate a high-quality translation software provider. After initial contact and a needs assessment, software with the capability to translate all Word, PowerPoint, Excel, PDF and email documents will be purchased. After purchasing and installing the software, all major documents (handbooks, report cards, IEP’s, etc.) will immediately be sent home in the requested languages. Additionally, all teachers will be trained to use the software and will be required to send translated materials home to any families that have requested document translations. Part 2:Provision of Oral Translations The Director of Operations will send out a form asking if any staff members speak any languages other than English. After identifying staff members that are bi or tri-lingual, the Director of Operations will put together an oral translation request protocol. After the oral translation request protocol has been written and approved, a copy of the document will go home to families that need oral translations so that they know who they may contact when they need to request a translator. For any low incidence languages the Director of Operations will identify and establish a contract with a local translation agency that has translators that speak the low incidence languages. Title/Role of Person(s) Responsible for Implementation: Part 1: Director of Operations Part 2: Director of Operations Expected Date of Completion for Each Corrective Action Activity: Part 1: December 2010 Part 2: September 2010 Evidence of Completion of the Corrective Action: Part 1: The Director of Operations will provide copies of all translated major documents to the state as well as a copy of the sheet used to document that all families have returned their census forms. Part 2: The Director of Operations will provide a copy of the oral translation protocol to the state. Description of Internal Monitoring Procedures: The school will keep copies of all translated documents to ensure that they have been translated properly. The school will also train any new staff members each year to use the translation software. Each year the front office will provide teachers with a list of students in their classes with translation needs. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7 Information to be Status of Corrective Action: translated into a language other than Approved Partially Approved Disapproved English. Basis for Partial Approval or Disapproval: There is no indication that the district will notify all staff of any newly developed policies and procedures related to oral translations, including procedures for parents who speak a low incidence language. Department Order of Corrective Action: Please submit evidence such as agendas and sign-in sheets that all staff have been notified of the newly developed oral translation protocol, including procedures related to the translation of low incidence languages. This progress report is due December 22, 2010. Required Elements of Progress Report(s): Please submit a copy of all major documents translated, including documents related to non-academic and extracurricular programs, into the dominant languages of the district. Additionally, please submit a copy of the newly developed oral translation MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 15 procedures. Finally, please submit evidence of an agreement reached between the district and a translation company to accommodate those parents who speak a low incidence language. This progress report is due December 22, 2010. Progress Report Due Date(s): December 22, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 10A Student handbooks and Rating: Partially Implemented code of conduct Department CPR Finding: The document review identified that although the student handbook does contain a detailed student code of conduct, it does not contain the procedures assuring due process in disciplinary proceedings or the appropriate procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans. Additionally, the district did not submit evidence verifying that the district has a code of conduct for teachers Narrative Description of Corrective Action: Part 1: Procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans. Step 1. The director of student support will meet with the co-directors to discuss the current handbook and the additions needed with regards to due process and procedures for discipline of students with special needs. Consultation with the school’s attorney may be required at this time. Step 2. The administrators will rewrite these sections of the handbook and include them as an addendum to the 2010-2011 student handbook. Step 3. The addendum will be sent home to all families. Part 2: Code of Conduct for staff Step 1. The Director of Operations will meet with the co-directors to discuss the current staff handbook and the additions needed with regards to a code of conduct for teachers. Consultation with the school’s attorney may be required at this time. Step 2. The administrators will rewrite these sections of the handbook and include them as an addendum to the 2010-2011 staff handbook Step 3. The addendum will be given to all staff members Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Part 1: Director of Student Support Part 1: December Part 2: Director of Operations Part 2: December Evidence of Completion of the Corrective Action: Part 1: The district will submit a copy of the addendum to the student handbook. Part 2: The district will submit a copy of the addendum to the staff handbook. Description of Internal Monitoring Procedures: Part 1& Part 2: The district will keep a record indicating that all families and staff have received and reviewed the policies included in the handbooks each year. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 16 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 10A Student handbooks and code of conduct Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department has accepted the district proposed corrective action plan as designed. Department Order of Corrective Action: None Required Elements of Progress Report(s): Please submit a translated copy of the addendum to the student handbook that includes the appropriate disciplinary procedures for students with disabilities and students with a Section 504 Accommodation Plan. Additionally, please submit evidence that the district has a code of conduct for teachers. Progress Report Due Date(s): December 22, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 18 Responsibilities of the Rating: Partially Implemented school principal Department CPR Finding: The document review and staff interviews identified inconsistent practices regarding documenting the use of accommodations and interventions for students. The impact of such practices results in incomplete information on the use of instructional supports as part of the evaluation information that is reviewed by the IEP Team when determining eligibility for special education. Additionally, the district did not submit policies on its home or hospital procedures Narrative Description of Corrective Action: Part 1: Inconsistent practices regarding documenting the use of accommodations and interventions for students. Step 1. The director of student support will meet with the middle school principal to discuss the current practices teachers use to document the use of accommodation and interventions. Elementary school teachers currently have and use a consistent procedure. Step 2. The director of student support, in collaboration with the middle school principal, will conduct professional development for all middle school teachers. The objective of the professional development will be to develop a common procedure to follow to document the use of accommodations and intervention. Additionally, the director of student support will conduct internal monitoring of student records to ensure these procedures are consistently being followed. Part 2: Home or hospital procedures Step 1. The Director of Operations will meet with the principals and nurse to discuss the current practices teachers use to provide sick or house-bound children with school work and services. Step 2. The school nurse, in collaboration with the Director of Operations will develop formal procedures for providing students who are hospitalized or house-bound with school work or necessary services. After writing down these new procedures they will conduct professional development for all teachers. The objective of the professional development will be to inform the school staff of the procedures for providing sick or house bound students with school work and services. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 17 Title/Role of Person(s) Responsible for Implementation: Part 1: Director of Student Support Part 2: Nurse in collaboration with the school nurse Expected Date of Completion for Each Corrective Action Activity: Part 1: December Evidence of Completion of the Corrective Action: Part 1 &Part 2: 1) The district will submit a copy of agenda and sign-in sheet from professional development Part 1: 1) The district expects to see evidence of correction through the student files when reviewed as part of the internal monitoring Description of Internal Monitoring Procedures: Part 1: The director of student support will select a sample of student records. The records selected will be initial evaluations. This will ensure that the files contain pre-referral documentation from general education teachers. If any files identified in the review do not contain the information regarding the use of accommodation and interventions prior to a referral, than the special education administrator will complete the following: 1) Immediately remedy the individual student file; 2) Conduct an analysis to determine if similar student files lack the required information and determine if additional professional development is needed. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 18 Responsibilities of the school principal Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department has accepted the district proposed corrective action plan as designed. Department Order of Corrective Action: None Required Elements of Progress Report(s): Please submit a copy of the elementary and middle school procedures regarding the documentation of instructional support as part of the evaluative information reviewed by the IEP Team when determining eligibility for Special Education. Please submit evidence such as agendas and sign-in sheets, that all staff have been notified of the newly developed procedures. Additionally, please submit a copy of the newly developed procedures for student’s requiring home and hospital services. Please submit evidence such as agenda and sign in-sheets that staff have been notified of the home and hospital procedures. This progress report is due December 22, 2010. Please submit the results of the internal monitoring conducted to ensure that the instructional supports have been included as part of the evaluation information when the Team is determining eligibility for special education. Please identify the root cause of any non-compliance and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 18 This progress report is due March 19, 2011. Progress Report Due Date(s): December 22, 2010 and March 18, 2011. COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 22 Accessibility of district Rating: Partially Implemented program and services for students with disabilities Department CPR Finding: Currently the district does not have any students enrolled with a physical disability that would prevent the student from accessing all of the district’s educational programs. However, the school building is not fully accessible according to state and federal requirements Narrative Description of Corrective Action: In order to ensure programmatic access to all of the districts’ programs, the district will employ a contractor to build a lift from the basement to the first floor of the building. Currently, all other programs are accessible through new lifts that have been installed in the gym and cafeteria level of the school. The classrooms on the second and third are not currently accessible but the district will, if it ever becomes necessary move the classroom of a student with a physical disability to the first floor of the school. The school plans to save money in order to eventually make all four floors of the school accessible. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Operations January 2011 Evidence of Completion of the Corrective Action: After the construction is complete, all entrances, exits, the basement (where co-curricular classes take place), the gym, the cafeteria, and the classrooms on the first floor will be accessible to students with physical disabilities. Because of this, all districts programs will be accessible to all students. The district will provide notice to the state when all construction has been completed. Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 22 Accessibility of Status of Corrective Action: district program and services for Approved Partially Approved Disapproved students with disabilities Basis for Partial Approval or Disapproval: The district must submit a statement of assurance indicating that in the event a student with a disability requires a program that is not currently accessible; the district will move all necessary programs to ensure that the student will have full access to all the programs available to meet their needs. Department Order of Corrective Action: Please submit a statement of assurance indicating that in the event a student with a disability requires a program that is not currently accessible, the district will move all necessary programs to ensure that the student will have full access to all the programs available to meet their needs. Required Elements of Progress Report(s): Please submit the statement of assurance no later than December 22, 2010. Additionally, the department will conduct onsite verification no later than March 18, 2010. Progress Report Due Date(s): December 22, 2010 and March 18, 2010 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 19 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Edward W. Brooke Charter School Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Name of School/District Staff Member CAP Form will expand to as many lines as necessary. Before completing and emailing to pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans. All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report to the school or district. Mandatory One-Year Compliance Date: August 19, 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: The document review identified that although the district revised the SY’ 10 Home Language Survey to include a question regarding parent’s preferred language when receiving important information and notices, the survey is not translated into all of the school’s major languages. Narrative Description of Corrective Action: Step 1 - The home language survey has been translated into the schools’ major languages. Step 2 - The director of student support will conduct an internal monitoring system of the enrollment procedures to ensure that the translated home language surveys are offered to families. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Student Support Step 1 – December 2010 Step 2 - February 2011 Evidence of Completion of the Corrective Action: 1. The district will submit copies of the newly translated home language surveys; 2. The district will submit results of internal monitoring MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 20 Description of Internal Monitoring Procedures: The director of student support will conduct internal monitoring of student records to ensure that translated home language surveys were offered to all families. If records identified in the review do not contain communications in the primary language of the home the director of student support will complete the following: 1) immediately remedy the individual student file; 2) conduct an analysis to determine if other families that need translated home language surveys did not receive translations. If continued noncompliance is identified through the analysis, the director of student support will review the recently developed procedures with staff. 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: The Department has accepted the district’s corrective action as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit copy of the home language survey translated into the major languages of the district. This progress report is due March 4, 2011 Additionally, please submit the results of the internal monitoring of student records conducted to ensure that all families received a translated a copy of the home language survey. Please identify the root cause of any noncompliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that the district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). This progress report is due May 14, 2011. Progress Report Due Date(s): March 18, 2011; May 14, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 4 Waiver Procedures Rating: Partially Implemented Department CPR Finding: The document review identified that the documentation informing parents of their right to request a waiver is not translated into the school’s major language Narrative Description of Corrective Action: Step 1 - The right to request a waiver has now been translated into the schools’ major languages. Step 2 - The director of student support will conduct an internal monitoring system to ensure that the translated waiver paperwork is offered to families Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Student Support Step 1 - December of 2010 Step 2 – February 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 21 Evidence of Completion of the Corrective Action: 1. The district will submit a copies of the newly translated waiver procedures 2. The district will submit results of internal monitoring Description of Internal Monitoring Procedures: The director of student support will conduct internal monitoring of student records to ensure that families are provided with EWBCS’s waiver procedures in their primary language. If records identified in the review do not contain communications in the primary language of the home the director of student support will complete the following: 1) immediately remedy the individual student file & situation; 2) conduct an analysis to determine if other families that need translated waiver procedures did not receive translations. If continued noncompliance is identified through the analysis, the director of student support will write a new policy to address this and conduct professional development. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 4 Waiver Procedures Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department has accepted the district’s corrective action as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit a translated copy of the district’s documentation informing them of their right to apply for a waiver. This progress report is due March 18, 2010. Additionally, please submit the results of the internal monitoring of student records conducted to ensure that all families received documentation informing them of their right to apply for a waiver. Please identify the root cause of any noncompliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s) This progress report is due May 14, 2011. Progress Report Due Date(s): March 18, 2011; May 14, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 22 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. Part 1 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), but from the documentation submitted, it appears to be the curriculum provided by the textbook company. Part 2 While the school does have staff licensed to teach ESL, documentation indicates the amount of instructional minutes LEP students are currently receiving is inconsistent with the 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. Part 3 Content instruction is based on the appropriate Massachusetts Curriculum Framework; however, it is clear that LEP students do not receive sheltered content instruction as none of the 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. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 23 Narrative Description of Corrective Action: Part 1 – Developing an ESL curriculum Step 1 – The director of students support will contact at least 3 schools within MA for guidance on developing an ESL curriculum. The goal in doing this is to have a curriculum that has already been developed to use as a model when developing our own ESL curriculum. Step 2 – The director of student support will use the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO), the EWBCS reading, writing, listening and speaking standards and align these to create a K-8 ESL curriculum. The curriculum will address each of the following proficiency levels; beginning, intermediate and transitioning. The following outlines the expected completion date for the K-8 ESL curriculum: SY 2010-2011 Grades 3-5 –transitioning Grades 6-8 – transitioning Grades K-2 –transitioning SY 2011 – 2012 Grades K-8 all levels (that have not been previously completed) Part 2 – ESL instructional program time This school district now follows the recommended hours of ESL instruction per week. The director of student support will conduct an internal monitoring system to ensure LEP students are receiving the appropriate number of ESL instructional minutes as recommended by the DESE. Part 3 – SEI professional development The entire teaching staff engaged in the Category 1 training and completed all of the requirements for this category in August of 2010. The school district contact SEI training providers and schedule Category 2 - 4 trainings that will follow the calendar below to ensure all LEP students are receiving sheltered content instruction by teachers who have completed all 4 Category SEI trainings in the next 22 months. August 2010 – Category 1 training August 2011 – Category 2 training Winter/Spring 2011 – Category 3 retraining August 2012 – Category 4 training Title/Role of Person(s) Responsible for Implementation: Director of Student Support Expected Date of Completion for Each Corrective Action Activity: Part 1: February 2011 Part 2: February 2011 Part 3: Dec. 2010, Feb. 2011 & August 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 24 Evidence of Completion of the Corrective Action: Part 1 – Developing an ESL curriculum The district will submit a copy of ESL curriculum. Part 2 – ESL instructional program time The district will submit evidence of correction through the internal monitoring system. Part 3 – SEI professional development The school district will submit copies of the Category 1 training certificates. The school district will submit a detailed plan including SEI providers, dates of PD, lists of teachers that will attend and other evidence indicating these trainings have been scheduled (e.g. PD plan for sy 2011-2012, SEI training agreements). Description of Internal Monitoring Procedures: The director of student support will review all LEP student records. This will ensure that the file contains documentation of the appropriate number of ESL instructional minutes as recommended by the DESE. If any student is not receiving the recommended number of ESL instructional minutes the director of student support will complete the following: 1) immediately remedy students schedule CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Program placement Status of Corrective Action: and Structure Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The timeline for the district to comply with the corrective action is not within the one year time frame. The district lacks appropriate detail of the monitoring system and the evidence of completion of this corrective action. Department Order of Corrective Action: Provide evidence that ESL/ELD instruction is being provided to all LEP students at all schools by a certified ESL teacher. Specifically, provide the following: Teacher schedules indicating assignments. Names of teachers delivering ESL/ELD. A list of all LEP students in the district, their MEPA proficiency levels, the numbers of hours of ESL/ELD instruction that they receive, and the name of the ESL/ELD teacher. Five sample schedules from each school in the district supporting the hours of ESL/ELD instruction that are evidenced on the aforementioned list. To the extent the documentation above does not demonstrate that LEP students receive sufficient hours of ESL/ELD instruction, provide a detailed plan that ensures that the district addresses this and is providing sufficient ESL/ELD to all LEP students before September 1, 2011. In order to monitor levels of ESL/ELD instruction, the assigned individual will review the schedules of all LEP students in the district biannually for the following: Sufficient levels of ESL/ELD instruction, consistent with Department guidance; Delivery of all ESL/ELD by appropriately licensed staff; and Placement in classrooms of teachers who have received training in sheltering content, and levels of training of each teacher. Provide the name(s) of the individual(s) and the means by which s/he or they will monitor the delivery of ESL/ELD and sheltered content to all LEP students. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 25 Provide evidence of SEI professional development training for the 2010-2011 school year, including the following: Specific training dates. Signed attendance sheets. Provide the above by March 4, 2011 Required Elements of Progress Provide status updates on the following by March 18, 2011 1) Progress toward aligning the K-12 ESL curriculum with the ELPBO. 2) Evidence of SEI professional development training for the 2010-2011 school year, including the following: Specific training dates. Signed attendance sheets. Also provide the following by the March 18, 2011: 1) Copies of the LEP students’ schedules, including ESL. Indicate, as to each student, the student’s grade level, and identified level of proficiency. 2) A list of the general/special education classroom teachers with whom LEP students have been placed, including the initials of LEP students placed with them. 3) Evidence of the first biannual monitoring of student schedules, as ordered above. By May 14, 2011 provide the following: 1) The K-12 ESL curriculum completely aligned with the ELPBO. 2) Evidence of SEI professional development training for the 2010-2011 school year, including the following: Specific training dates. Signed attendance sheets. 3) Evidence of the most recent biannual monitoring of student schedules, as ordered above. Provide a description of actions taken to remedy any non-compliance. Progress Report Due Date(s): March 18, 2011; May 14, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 26 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 the charter school’s documents shows that the district does not have an appropriate ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO). Additionally, since no ESL/ELD instruction is provided, students are not grouped according to requirements. Similarly, the content instruction provided to the LEP students at the charter school do not meet requirements as the mainstream teachers have completed few if any Category trainings Narrative Description of Corrective Action: Step 1 - See ELE 5part 1 Step 2 - The district will write a policy for when it has LEP students in different grade levels and proficiency levels. The policy will include the following: Groups of LEP students can be of different ages only if their levels of English proficiency are similar. Grouping of students ensures that LEP students receive effective content instruction at appropriate academic levels and that ESL/ELD instruction is at the appropriate proficiency level and based on the English Language Proficiency Benchmarks and Outcomes. Step 3 - The director of student support will conduct an internal monitoring system to ensure students are grouped according to EWBCS’s policy. This will be included as part of the ELE program evaluation which will be conducted in October and May of each school year. Title/Role of Person(s) Responsible for Implementation: Director of Student Support Expected Date of Completion for Each Corrective Action Activity: Step 1 – February 2011 Step 2 – December 2010 Step 3 - February 2011 Evidence of Completion of the Corrective Action: See ELE 5 The district will submit a copy of the new policy outlining instructional grouping for LEP students. The district will submit a copy of the internal monitoring results. Description of Internal Monitoring Procedures: The director of student support will create a master ESL instruction schedule for the entire school. This schedule will include students’ names, ESL instruction times, proficiency levels and grade levels and will follow the new ELE instructional grouping policy. A biannual review of the schedule will be included as part of the ELE program evaluation which will be conducted in October and May of each school year. If any student is not receiving ESL instruction following the school’s policy the director of student support will complete the following: 1) immediately remedy students schedule MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 27 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): March 18, 2011; May 14, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 28 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 10 Parental Notification Rating: Partially Implemented Department CPR Finding: The review of student records indicated that the parent notification is not translated into the primary language of the home and does not inform parents of the reasons for identification of the student as LEP, the child’s English proficiency, program placements and/or the method of instruction used in the program, and the parent’s right to apply for a waiver. Additionally, the student records indicated that the district does not provide parents and guardians of LEP students with progress reports with the same frequency as other general education reporting Narrative Description of Corrective Action: 1. The director of student support will develop a new procedure to follow to notify parents when their child has been identified as LEP. The procedure will include sending a letter with the following information: reasons for identification the child’s English proficiency level program placement recommendations parents right to apply for a waiver progress report schedule The procedure will also include sending home reports on their child’s progress towards meeting the ESL standards. The policy and procedure will also ensure that all notifications are translated into the parents’ primary language. 2. The director of student support will conduct an internal monitoring system to ensure parental notifications are being done according to the new EWBCS’s policy. This will be included as part of the ELE program evaluation which will be conducted in October and May of each school year. Title/Role of Person(s) Responsible for Implementation: Director of Student Support Expected Date of Completion for Each Corrective Action Activity: Step 1 – December 2010 Step 2 – February 2011 Evidence of Completion of the Corrective Action: The district will submit a copy of the new procedure for notifying parent of LEP students. The district will submit a copy of the internal monitoring results. Description of Internal Monitoring Procedures: The director of student support will review all files of LEP students. If any file does not follow the new procedure, the director of student support will complete the following: 1) immediately remedy the individual student file; 2) develop a new procedure to ensure compliance CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 29 Criterion: ELE 10 Parental Notification Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department accepts the districts’ corrective action as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit a copy of the newly developed policy to ensure that parents are notified of their child’s LEP status upon initial identification and annually thereafter. Additionally, please submit a copy of parent notification letter translated into the dominant languages of the district. This progress report is due March 18, 2011. Please submit the results of the internal monitoring of student records conducted to ensure that all families receive notification of their child’s LEP status upon initial identification and annually thereafter. Additionally, please conduct internal monitoring of student records to ensure that parents are receiving progress reports with the same frequency as general education progress reporting is conducted. Please identify the root cause of any noncompliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s) This progress report is due May 14, 2011. Progress Report Due Date(s): March 18, 2011; May 14, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 30 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal access to academic Rating: Partially Implemented program and services Department CPR Finding: Staff interviews indicated the district does not send home information regarding activities, responsibilities, and academic standards to LEP students in a language and mode of communication that they understand. Furthermore, the charter school does not have teachers who have received training in all four of the categories for sheltering content required by the Department; therefore LEP students do not have equal access to the full range of academic opportunities Narrative Description of Corrective Action: Part 1 – Translating documents (activities, responsibilities, academic standards, etc.) See CR #7 Part 2 – SEI professional development See ELE 5 part 3 Title/Role of Person(s) Responsible for Implementation: Director of Student Support Expected Date of Completion for Each Corrective Action Activity: Part 1: February 2011 Part 2: Dec. 2010, Feb. 2011 & August 2012 Evidence of Completion of the Corrective Action: Part 1 – Translating documents (activities, responsibilities, academic standards, etc.) See CR #7 Part 2 – SEI professional development See ELE 5 part 3 Description of Internal Monitoring Procedures: Part 1 – Translating documents (activities, responsibilities, academic standards, etc.) See CR #7 Part 2 – SEI professional development See ELE 5 part 3 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 11 Equal access to Status of Corrective Action: academic programs and services 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): March 18, 2011; May 14, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 31 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 12 Equal access to nonRating: Partially Implemented academic and extracurricular programs Department CPR Finding: Staff interviews indicated the district does not send home information in notices to parents of LEP students in a language and mode of communication that they understand Narrative Description of Corrective Action: Part 1 – Translating documents (non-academic and extracurricular programs) See CR #7 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Student Support February 2011 Evidence of Completion of the Corrective Action: See CR #7 Description of Internal Monitoring Procedures: See CR #7 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 12 Equal Access to Status of Corrective Action: non-academic and extracurricular Approved Partially Approved Disapproved programs Basis for Partial Approval or Disapproval: The Department accepts the district’s proposed corrective action as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please see CR 7. Progress Report Due Date(s): March 18, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 32 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Development Rating: Partially Implemented Requirement Department CPR Finding: Content instruction is based on the appropriate Massachusetts Curriculum Framework; however, it is clear that LEP students do not receive sheltered content instruction as none of the 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. Narrative Description of Corrective Action: Part 2 – SEI professional development See ELE 5 part 3 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Student Support Dec. 2010, Feb. 2011& August 2012 Evidence of Completion of the Corrective Action: Part 2 – SEI professional development See ELE 5 part 3 Description of Internal Monitoring Procedures: Part 2 – SEI professional development See ELE 5 part 3 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: Please see ELE 5 Department Order of Corrective Action: Please see ELE 5 Required Elements of Progress Report(s): Please see ELE 5 Progress Report Due Date(s): March 18, 2011; May 14, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 33 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 17 Program Evaluation Rating: Partially Implemented Department CPR Finding: The documentation review indicated that the charter school has not identified the steps necessary to ensure that LEP students receive effective educational programming consistent with the requirements of state and federal law Narrative Description of Corrective Action: Step 1. The school district will develop procedures to following to evaluate the school’s ELE program. This procedure will include a process for ensuring LEP students are receiving an effective educational program and will occur biannually. The ELE program evaluation will include the following (note- this is not a complete list): Procedural Evaluation Enrollment procedures are being followed and ensure parents are receiving the home language surveys in their primary language All parent notifications are sent home in parents primary language Students are receiving direct ESL instruction from a licensed ESL teacher and are receiving the recommended number of instructional minutes per week as outlined by the DESE. Students are receiving SEI by qualified teachers who have had training in all 4 categories. EWBCS is on track to follow the SEI training calendar Students receiving ESL instruction are grouped according to EWBCS’s policy. Student Achievement Students are making effective progress in all areas (content areas as well as ESL) Students are making progress as indicated by MEPA and MELA-O results Students are making progress as indicated by MCAS results Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Student Support February 2011 Evidence of Completion of the Corrective Action: The district will submit a copy of the new ELE program evaluation. The district will submit a copy of an actual ELE program evaluation. Description of Internal Monitoring Procedures: The director of student support will create a master calendar for the ELE program. This calendar will include a biannual ELE program evaluation which will be conducted in October and May of each school year. For SY 2010-2011, the ELE program evaluation will be conducted in December and February. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 34 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 17 Program Evaluation Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department has accepted the district’s corrective action as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit a copy of the actual program evaluation conducted. This progress report is due May 14, 2011. Progress Report Due Date(s): May 14, 2011. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 35 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 Records of LEP students Rating: Partially Implemented Department CPR Finding: The review of student records indicated that the records were missing information regarding the student’s previous school experiences, copies of parent notification letter(s), progress reports, and report cards Narrative Description of Corrective Action: Step 1 - In accordance with Title VI; EEOA; M.G.L. c. 69 and 11; c. 71A, 5, 7; 603 CMR 14.02, 14.04, LEP student records will include: A home language survey Results of identification and proficiency tests and evaluations Parent notification letters Progress reports and report cards Information about student’s previous school experience Evidence of follow-up monitoring (if applicable) Documentation of a parent’s consent to “opt out” of English language instruction (if applicable) Waiver documentation (if applicable) Each student folder will contain the above checklist. Step 2 - The director of student support will conduct an internal monitoring system of the student records to ensure that each of the folders has the following. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Student Support Step 1 – December 2010 Step 1 – February 2011 Evidence of Completion of the Corrective Action: The district will submit a copy of the student record checklist The district will submit results of internal monitoring MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 36 Description of Internal Monitoring Procedures: The director of student support will conduct internal monitoring of student records to ensure that the following documents are in the record: A home language survey Results of identification and proficiency tests and evaluations Parent notification letters Progress reports and report cards Information about student’s previous school experience Evidence of follow-up monitoring (if applicable) Documentation of a parent’s consent to “opt out” of English language instruction (if applicable) Waiver documentation (if applicable) If records identified in the review do not contain any of the following the director of student support will complete the following: 1) immediately remedy the individual student file; 2) conduct an analysis to determine if other records are incomplete. 3) if continued noncompliance is identified through the analysis, the director of student support will review all of the records and remedy each file. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 18 Records of LEP Status of Corrective Action: students Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department has accepted the district’s proposed corrective action as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit the results of the internal monitoring of student records conducted to ensure each record contains the following pieces of documentation: A home language survey; Results of identification and proficiency tests and evaluations; Parent notification letters; Progress reports and report cards; Information about student’s previous school experience; Evidence of follow-up monitoring (if applicable); Documentation of a parent’s consent to “opt out” of English language instruction (if applicable);Waiver documentation (if applicable). Please identify the root cause of any noncompliance identified and the subsequent corrective action(s). Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s) This progress report is due May 14, 2011. Progress Report Due Date(s): May 14, 2011. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Edward Brooke Charter (District) CPR Corrective Action Plan 37