MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Falmouth CPR Onsite Year: 2011-2012 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 02/24/2012. Mandatory One-Year Compliance Date: 02/24/2013 Summary of Required Corrective Action Plans in this Report Criterion SE 8 Criterion Title IEP Team composition and attendance SE 9 SE 14 Timeline for determination of eligibility and provision of documentation to parent Review and revision of IEPs SE 18B Determination of placement; provision of IEP to parent SE 40 Instructional grouping requirements for students aged five and older Procedural requirements applied to students not yet determined to be eligible for special education Student handbooks and codes of conduct SE 47 CR 10A CPR Rating 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 8 IEP Team composition and attendance Partially Implemented Department CPR Findings: Student record review indicated that when a required Team member does not attend a Team meeting: (a) the district and the parent do not always 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 (b) the district and the parent do not always agree, in writing, to excuse a required Team member´s participation and the excused member does not provide written input into the development of the IEP to the parent and the IEP Team prior to the meeting. Documentation indicates that the district has developed a form contrary to regulatory requirements that seeks a parent's written consent to excuse a required Team member, when the member's area of the curriculum or related services are being modified and discussed, without the excused Team member needing to submit written input into the development of the IEP. Description of Corrective Action: The Director of Pupil Personnel has met with a group of administrators to develop appropriate excusal forms. This workgroup of Assistant Principals/Team Chairs and SPED Department Heads meets biweekly. The Coordinated Program Review and now the CAP are areas of ongoing discussion and training in this venue. Training will be provided to the district Team Chairpersons regarding the use of an appropriate excusal form including written parental consent to excuse a team member, and the requirement pertaining to written input on the part of the excused team member. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Completion: Anne Barnes, Out of District Coordinator 11/16/2012 Evidence of Completion of the Corrective Action: Two excusal forms were developed and will be submitted with the Corrective Action Plan. Agendas and training materials, and attendance sheets will also be included with the CAP. Description of Internal Monitoring Procedures: Director of Pupil Personnel Services will be responsible for conducting 3 on-site record reviews per school year. Each building in the district will be included in the review, during which 6 files will be reviewed per building, with a mix of annual reviews, initial evaluations and 3 year evaluations. A form will be developed that will include a checklist for each area cited ?in this case that would include a check for excusal forms when a team member is absent from a meeting. In addition to the checklist, a narrative will be written including a summary of the findings. The development of the new excusal forms included input from the team chairs and SPED Dept. Heads. As a result of the Coordinated Program Review process, the PPS Director has already implemented this on-site monitoring process. Visits were made to each building over the past several months, and summaries were written. The next step is to develop a monitoring form for these visits. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 8 IEP Team composition and Status Date: 03/28/2012 attendance Basis for Partial Approval or Disapproval: The district has met to develop an appropriate excusal form for use when a required Team MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 2 member does not attend a Team meeting. The district also proposed training staff on the use of the revised form. Although the district indicated the they submitted evidence of completion with the CAP, they rather meant to propose that supporting documentation would be submitted with progress reports. The district has developed an internal monitoring process to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 08, 2012, submit a copy of the revised forms used to excuse a required Team member from a Team meeting and submit as evidence of training on excusal procedures the following: (1) agenda; (2) signed attendance sheet(s) indicating role of staff; (3) training materials; (4) date of the training(s). By November 9, 2012, submit a summary report of the internal monitoring of records reviewed subsequent to the implementation of corrective actions on the excusal of Team members. Include the following: (1) the number of records reviewed, (2) rate of compliance, (3) description of root cause(s) of any non-compliance. Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): 06/08/2012 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 3 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: Student record review and interviews indicate that Team meetings do not always take place 45 days following receipt of the parent's written consent for an evaluation. Description of Corrective Action: The Director of Pupil Personnel Services has met with an administrative group of assistant principals/team chairpersons to review this finding and to brainstorm about ways to improve in this area. We will make a concerted effort to schedule meetings with enough time to reschedule within the 45 day timeline in the event that a parent cancels at the last minute, which is often the root cause of this issue. Training has and will be provided to this administrative group, with building based follow-up visits as described later in the Internal Monitoring Process section. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Services Completion: Ann Barnes, Out of District Coordinator 11/12/2012 Evidence of Completion of the Corrective Action: Agendas, attendance sheets and training materials from our team chair meetings will be submitted as part of the CAP. Description of Internal Monitoring Procedures: The Director of Pupil Personnel Services will be responsible for conducting 3 yearly on-site visits to each building in the district for file reviews in order to monitor this timeline requirement. A form will be developed with a checklist and a narrative component describing our findings with respect to compliance in this area. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 9 Timeline for determination of Approved eligibility and provision of documentation Status Date: 03/28/2012 to parent Basis for Partial Approval or Disapproval: Although the district met with an administrative group to discuss the finding and consider the root causes of the non-compliance, they did not review the timelines of initial and reevaluations to reach their conclusion. Although the district indicated the they submitted evidence of completion with the CAP, they rather meant to propose that supporting documentation would be submitted with progress reports. The district has developed an internal oversight and tracking system to ensure that Team meetings take place within 45 days following receipt of the parent's written consent for an evaluation. Department Order of Corrective Action: Review the timelines of initial evaluations and re-evaluations that have been conducted this past school year and analyze this data to establish the root cause(s) for noncompliance. Based on this root cause analysis indicate the specific corrective actions taken to remedy the non-compliance. Required Elements of Progress Report(s): By June 8, 2012, submit the outcomes of the root cause analysis with the specific proposal for remedying the non-compliance. By November 9, 2012, submit a report of the results of an internal review of records in which an initial evaluation or re-evaluation MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 4 was conducted since implementation of the oversight and tracking system for compliance with timelines. Include the following: (1) the number of records reviewed, (2) rate of compliance, (3) description of root cause(s) of any non-compliance. Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): 06/08/2012 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 5 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: Student record review indicated that the Team does not always meet on or before the anniversary date of the IEP to review, revise or develop a new IEP. Description of Corrective Action: The Director of Pupil Personnel Services has provided training to the Assistant Principals, Team Chairs and SPED Department Heads regarding this finding. She will continue to provide oversight and training. As a result of working with this focus group, it was determined that the root cause of the problem might have involved a misunderstanding on the part of the team chair about moving the date of an annual review meeting to match the date of a 3 year re-evaluation meeting. That misunderstanding has been cleared up. The Director of Pupil Personnel Services will conduct on-site file reviews 3 times per year in each building in order to monitor compliance. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Services Completion: Anne Barnes, Out of District Coordinator 11/16/2012 Evidence of Completion of the Corrective Action: Training agendas, attendance sheets and training materials will be submitted to the DESE as part of the CAP. Description of Internal Monitoring Procedures: The Director of Pupil Personnel Services will be responsible for conducting on-site file reviews 3 times per year in order to monitor compliance with this finding. A form will be developed including a checklist and a narrative component to describe the on-site findings. The Pupil Personnel Director has also met with each team chairperson to review their procedures for scheduling meetings to increase our ability to meet time lines and to become fully compliant. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Partially Approved Status Date: 03/28/2012 Basis for Partial Approval or Disapproval: Although the district met with an administrative group to discuss the finding and consider the root causes of the non-compliance, they did not review the timelines of annual reviews and the student records of those not in compliance to reach their conclusion. The district has developed an internal oversight and tracking system to ensure that Team meetings take place on or before the anniversary date of the IEP. Department Order of Corrective Action: Review the timelines of annual reviews that have been conducted this past school year and analyze student records to establish the root cause(s) for non-compliance. Based on this root cause analysis indicate the specific corrective actions taken to remedy the noncompliance. Required Elements of Progress Report(s): By June 8, 2012, submit the outcomes of the root cause analysis with the specific proposal for remedying the non-compliance. By November 9, 2012, submit a report of the results of an internal review of records in which an annual review was conducted since implementation of the oversight and tracking system for compliance with timelines. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 6 Include the following: (1) the number of records reviewed, (2) rate of compliance, (3) description of root cause(s) of any non-compliance. Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): 06/08/2012 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 7 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18B Determination of placement; provision of IEP to parent Partially Implemented Department CPR Findings: Student record review indicates that the parent is not always provided with two copies of the proposed IEP and placement immediately following the Team meeting. Description of Corrective Action: The Director of Pupil Personnel Services has met with Assistant Principals, Team Chairpersons and SPED Department Heads to review this finding. As a result of our focus group, we established a procedure that follows: The Team Chsirs will note on the N1 that 2 copies of the IEP has been sent out This will be monitored 3 times per year by the Director of Pupil Personnel Services at each building as part of a file review. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Services Completion: Anne Barnes, Out of District Coordinator 11/16/2012 Evidence of Completion of the Corrective Action: Agendas, training materials, and attendance sheets will be submitted to the DESE as part of the CAP. Also, copies of the newly developed compliance form including a checklist an a narrative summary will be submitted as well. Description of Internal Monitoring Procedures: The Director of Pupil Personnel Services will conduct 3 on-site reviews per year in each building in the district in order to monitor compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 18B Determination of placement; Status Date: 03/28/2012 provision of IEP to parent Basis for Partial Approval or Disapproval: The district has established a procedure to ensure that the parent is provided with two copies of the IEP. They have met with staff, trained them in the procedure, and they have developed an internal monitoring system. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 8, 2012, provide as evidence of training in the procedures to provide the parent with two copies of the IEP the following: (1) agenda; (2) signed attendance sheet(s) indicating role of staff; (3) training materials; (4) date of the training(s). By November 9, 2012, submit a summary report of the internal monitoring of records reviewed subsequent to the implementation of corrective actions. Include the following: (1) the number of records reviewed, (2) rate of compliance, (3) description of root cause(s) of any non-compliance. Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): 06/08/2012 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 8 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 9 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 40 Instructional grouping requirements for students aged five Partially Implemented and older Department CPR Findings: Interviews and observations indicate that there is one class at the Morse Pond School that has 17 students with disabilities with one teacher and one aide. Description of Corrective Action: The Director of Pupil Personnel Services will implement an on-site review at the Morse Pond School, by visiting the classroom that had 17 students in it at the time of the DESE visit. She will also review schedules for the students and rosters for the classroom to ensure compliance. Training has already been provided for the administrator responsible for these programs at the Morse Pond School. Visits will take place 3 times per year to monitor compliance. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Services Completion: Anne Barnes, Out of District Coordinator 11/16/2012 Evidence of Completion of the Corrective Action: Training agendas, attendance sheets, and materials will be submitted to the DESE as part of the CAP. Copies of the checklists associated with these on-site visits, including a narrative summary of the findings will also be shared with the DESE. Description of Internal Monitoring Procedures: The Director of Pupil Personnel Services will be responsible for conducting on-site visits to the Morse Pond School 3 times per year to monitor compliance. A checklist and a narrative summary of those visits will be completed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 40 Instructional grouping Status Date: 03/28/2012 requirements for students aged five and older Basis for Partial Approval or Disapproval: Additional information submitted indicated that the district added an aide to the class at Morse Pond School and changed one student's class schedule so that the class currently has 16 students with one teacher and two aides. Training was provided to administrators regarding instructional grouping requirements. A description of internal monitoring process was provided. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 08, 2012, submit as evidence of training on instructional grouping requirements the following: (1) agenda; (2) signed attendance sheet(s) indicating role of staff; (3) training materials; (4) date of the training(s). By November 9, 2012, submit a summary report of the internal monitoring of classes reviewed subsequent to the implementation of corrective actions. Include the following: (1) the number of classes monitored, (2) rate of compliance, (3) description of root cause(s) of any non-compliance (4) and the specific corrective action taken by the district to remedy any non-compliance. Progress Report Due Date(s): 06/08/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 10 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 11 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 47 Procedural requirements applied to students not yet Partially Implemented determined to be eligible for special education Department CPR Findings: Documentation indicates that student codes of conduct do not contain the procedural requirements applied to students not yet determined eligible for special education. Description of Corrective Action: In order to comply with this finding, the district developed language pertaining to the codes of conduct that contain the procedural requirements applied to students not yet determined eligible for special education. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Services Completion: Anne Barnes, Out of District Coordinator 11/16/2012 Evidence of Completion of the Corrective Action: The district will submit the newly written language to the DESE as part of the CAP, with evidence of placement in our handbooks. Description of Internal Monitoring Procedures: Once the newly written language has been incorporated into our handbooks, we will know that we have met the legal standard for this criteria. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 47 Procedural requirements applied to Approved students not yet determined to be Status Date: 03/28/2012 eligible for special education Basis for Partial Approval or Disapproval: The district indicated that they have developed the language that will be inserted in student handbooks regarding the procedural requirements applied to students not yet eligible for special education. The district did not indicate that staff would be trained in these procedures. Department Order of Corrective Action: Provide training to administrative staff on the procedural requirements applied to students not yet eligible for special education. Required Elements of Progress Report(s): By June 8, 2012 submit a copy of the language that will be inserted in student handbooks regarding the procedural requirements applied to students not yet eligible for special education and evidence of staff training on these requirements, including the agenda, training materials and sign-in sheet(s). By November 9, 2012 submit a copy of the student handbook from each school. Progress Report Due Date(s): 06/08/2012 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 10A Student handbooks and codes of conduct Partially Implemented Department CPR Findings: Documentation indicates that codes of conduct contained in elementary school handbooks do not reference M.G.L. c. 76 s. 5 and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. Description of Corrective Action: The District plans to add a reference to M.G.L. c.76s. 5 and the disciplinary measures that a school may impose if it determines that harassment or discrimination has occurred, to the elementary handbooks. Title/Role(s) of responsible Persons: Expected Date of Beverly Shea, Director of Pupil Personnel Services Completion: Anne Barnes, Out of District Coordinator 11/16/2012 Evidence of Completion of the Corrective Action: The district will submit this new reference to the DESE as part of the CAP along with evidence of incorporating it into our elementary handbooks. Description of Internal Monitoring Procedures: Once the new information has been added to the elementary handbooks, we will know we are in compliance with this criteria. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 10A Student handbooks and codes of Approved conduct Status Date: 03/28/2012 Basis for Partial Approval or Disapproval: The district indicated that they will add a reference to M.G.L. c. 76 s. 5 and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. Department Order of Corrective Action: Provide training to administrative staff on the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. Required Elements of Progress Report(s): By June 8, 2012 submit a copy of the language that will be inserted in student handbooks regarding the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred and evidence of staff training on these requirements, including the agenda, training materials and sign-in sheet(s). By November 09, 2012 submit a copy of the student handbook from each school. Progress Report Due Date(s): 06/08/2012 11/09/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Falmouth CPR Corrective Action Plan 13