MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Florida CPR Onsite Year: 2012-2013 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 08/24/2013. Mandatory One-Year Compliance Date: 08/24/2014 Summary of Required Corrective Action Plans in this Report Criterion CR 10A Criterion Title Student handbooks and codes of conduct CR 11A Designation of coordinator(s); grievance procedures CR 12A CR 21 Annual and continuous notification concerning nondiscrimination and coordinators Counseling and counseling materials free from bias and stereotypes Staff training regarding civil rights responsibilities CR 24 Curriculum review CR 25 Institutional self-evaluation CR 14 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: CR 10A Student handbooks and codes of conduct Partially Implemented Department CPR Findings: Document reviews and interviews reveal that district handbooks do not reference M.G.L. c. 76, s. 5 to affirm the school's non-tolerance for harassment based on race, color, national origin, sex, gender identity, religion, or sexual orientation, or discrimination on those same bases. The handbook does not outline the school's procedure for accepting, investigating and resolving complaints alleging discrimination or harassment and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. Description of Corrective Action: The district handbooks will be updated to reference M.G.L. c. 76, s.5 to affirm the school's non-tolerance for harassment, or discrimination, based on race, color, national origin, sex, gender identity, religion, or sexual orientation. The district handbooks will be updated to outline the school's procedure for accepting, investigating and resolving complaints of discrimination or harassment to include disciplinary measures that may be imposed. Title/Role(s) of Responsible Persons: Expected Date of Superintendent, Jon Lev Completion: Admin. of SPED, Debra Rosselli 10/30/2013 Principal, Heidi Dugal Evidence of Completion of the Corrective Action: District Handbook Description of Internal Monitoring Procedures: The Administrative Team will review handbooks annually for compliance and updates CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 10A Student handbooks and codes of Approved conduct Status Date: 10/21/2013 Basis for Status Decision: The district states it will make the required changes to district handbooks, including the newly developed procedure for accepting, investigating and resolving complaints alleging discrimination or harassment and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred, but does not indicate how it will share with staff to ensure that all staff are aware of the changes and understand the procedure. Department Order of Corrective Action: Provide a copy of the relevant pages of the newly updated handbooks that reference M.G.L. c. 76, s.5 to affirm the school's non-tolerance for harassment, or discrimination, based on race, color, national origin, sex, gender identity, religion, or sexual orientation; and those pages that outline the school's procedure for accepting, investigating and resolving complaints of discrimination or harassment to include disciplinary measures that may be imposed, along with evidence that staff was trained in the newly developed procedure for accepting, investigating and resolving complaints alleging discrimination or harassment and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 2 Required Elements of Progress Report(s): Provide a copy of the relevant pages of the newly updated handbooks that reference M.G.L. c. 76, s.5 to affirm the school's non-tolerance for harassment, or discrimination, based on race, color, national origin, sex, gender identity, religion, or sexual orientation; and those pages that outline the school's procedure for accepting, investigating and resolving complaints of discrimination or harassment to include disciplinary measures that may be imposed, along with evidence that staff was trained in the newly developed procedure for accepting, investigating and resolving complaints alleging discrimination or harassment and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred by December 2, 2013. Additionally, provide a description of how the handbook is shared with students, parents, and staff by December 2, 2013 Progress Report Due Date(s): 12/02/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 3 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 11A Designation of coordinator(s); grievance procedures Partially Implemented Department CPR Findings: Document review and interviews indicate that the district does not have designated staff person(s) to serve as coordinator(s) for compliance with its responsibilities under Title IX, Section 504, and Title II and has not adopted and published grievance procedures for students and for employees providing for prompt and equitable resolution of complaints alleging discrimination based on sex or disability. Description of Corrective Action: The Administrative Team will provide a written procedure listing the appropriate designated staff persons with contact information to serve as coordinators of compliance with responsibilities under Title IX, Section 504 and Title II, and description of the grievance procedures for students and employees. Title/Role(s) of Responsible Persons: Expected Date of Superintendent, Jon Lev Completion: Admin. of SPED, Debra Rosselli 10/30/2013 Principal, Heidi Dugal Evidence of Completion of the Corrective Action: District Handbook Description of Internal Monitoring Procedures: The Admin. Team will review handbooks annually for compliance and updates CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 11A Designation of coordinator(s); grievance procedures Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 10/21/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a copy of the applicable pages of the newly updated handbooks listing the appropriate designated staff persons with contact information to serve as coordinators of compliance with responsibilities under Title IX, Section 504 and Title II, and a description of the grievance procedures for students and employees along with a description of how handbooks were disseminated to students, parents, and staff by December 2, 2013. Progress Report Due Date(s): 12/02/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 12A Annual and continuous notification concerning Partially Implemented nondiscrimination and coordinators Department CPR Findings: Document review and interviews indicate that district notice does not include the name(s), office address(es), and phone number(s) of the person(s) designated to coordinate compliance under Title IX and Section 504. Description of Corrective Action: District notices will be updated to include the names, offices and phone numbers of persons designated to coordinate compliance under Title IX and Section 504. Title/Role(s) of Responsible Persons: Expected Date of Superintendent, Jon Lev Completion: Admin. of SPED, Debra Rosselli 10/30/2013 Principal, Heidi Dugal Evidence of Completion of the Corrective Action: Copy of Notice Staff sign-in sheet Description of Internal Monitoring Procedures: Updated notice will be included in the annual training for civil rights responsibilities CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 12A Annual and continuous notification concerning nondiscrimination and coordinators Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 10/21/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a copy of the relevant pages of district notices newly updated to include the names, offices and phone numbers of persons designated to coordinate compliance under Title IX and Section 504, along with staff sign-in sheet containing roles and signatures of staff, and the agenda of the annual training for civil rights responsibilities by December 2, 2013. Progress Report Due Date(s): 12/02/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 5 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 14 Counseling and counseling materials free from bias and Partially Implemented stereotypes Department CPR Findings: Document review and interviews indicate that the district does not have procedures in place to ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, gender identity, religion, national origin, sexual orientation, disability, and homelessness. Description of Corrective Action: A description of the procedure for the district to ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, gender identity, religion, national origin, sexual orientation, disability and homelessness will be shared with faculty in faculty meetings Title/Role(s) of Responsible Persons: Expected Date of Principal, Heidi Dugal Completion: School Adjustment Counselor, Doug Wentworth 10/30/2013 Evidence of Completion of the Corrective Action: Faculty meeting and sign-in sheet Documents shared NBSU Policy manual Description of Internal Monitoring Procedures: Admin. Team will review policy annually or more frequently as needed from compliance and updating CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 14 Counseling and counseling materials free from bias and stereotypes Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 10/21/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a copy of the newly developed written procedure for the district to ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, gender identity, religion, national origin, sexual orientation, disability and homelessness along with the agenda and sign in sheets with signature and role from the faculty meeting where the new policy was shared by December 2, 2013. Provide the results of an administrative review of the efficacy of the policy and a description of any changes that would be considered based on those results by March 3, 2014. Progress Report Due Date(s): 12/02/2013 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 21 Staff training regarding civil rights responsibilities Partially Implemented Department CPR Findings: Document review and interviews indicate that training provided for all school personnel at the beginning of the school year regarding civil rights responsibilities did not include the prevention of discrimination and harassment on the basis of the protected category of gender identity. Description of Corrective Action: The annual faculty training for civil rights responsibilities will be updated to include all protected categories, specifically adding the category of gender identity Title/Role(s) of Responsible Persons: Expected Date of Superintendent. Jon Lev Completion: Admin. of SPED, Debra Rosselli 10/30/2013 Principal, Heidi Dugal Evidence of Completion of the Corrective Action: Faculty Training agenda and sign-in Documents shared Description of Internal Monitoring Procedures: The Administrative team will develop an updated agenda annually for training on civil rights responsibilities to include any new legal compliance issues, categories and/or mandates CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 21 Staff training regarding civil rights responsibilities Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 10/21/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): Submit copies of the agenda and materials, updated to include all protected categories; specifically adding gender identity, used during the annual training for staff on civil rights responsibilities along with copies of staff sign in sheets with role and signature by December 2, 2013. Progress Report Due Date(s): 12/02/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 7 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 24 Curriculum review Partially Implemented Department CPR Findings: Document review and interviews indicate that the district has no procedure in place to ensure that individual teachers in the district review all educational materials for simplistic and demeaning generalizations, lacking intellectual merit, on the basis of race, color, sex, gender identity, religion, national origin and sexual orientation and that teachers employ appropriate activities, discussions and/or supplementary materials to provide balance and context for any such stereotypes depicted. Description of Corrective Action: The district will articulate the procedure, and present it at a faculty meeting, to ensure that teachers in the district will review all educational materials for bias on the basis of race, color, sex, gender identity, religion, national origin and sexual orientation, with discussion of appropriate activities or supplementary materials to provide balance and context. Title/Role(s) of Responsible Persons: Expected Date of Principal, Heidi Dugal Completion: Admi. of SPED, Debra Rosselli 10/30/2013 Evidence of Completion of the Corrective Action: Faculty meeting agenda and sign in Documents shared Materials review template Description of Internal Monitoring Procedures: Procedure will be reviewed annually at the faculty training for civil rights responsibilities, and related curriculum review template materials updated as indicated CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 24 Curriculum review Corrective Action Plan Status: Approved Status Date: 10/21/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Submit copies of the agenda and materials, specifically the written procedure presented to faculty at the annual training for staff on civil rights responsibilities, along with copies of staff sign in sheets with role and signature by December 2, 2013. Provide the results of an administrative review of the efficacy of the procedure and a description of any changes that would be considered based on those results by March 3, 2014. Progress Report Due Date(s): 12/02/2013 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: Document review and interviews reveal that although the district evaluates some aspects of its program annually, it has not included the protected category of gender identity in its evaluation, to ensure that all students have equal access to all programs, and that the district makes changes as indicated by the evaluation. Description of Corrective Action: The district will ensure that updated written procedures for the annual self-evaluation to ensure that all students have equal access to all programs will include the protected category of gender identity Title/Role(s) of Responsible Persons: Expected Date of Superintendent, Jon Lev Completion: Admin. of SPED, Debra Rosselli 10/30/2013 Principal, Heidi Dugal Evidence of Completion of the Corrective Action: Student Handbook District policy Program notices Program review template Description of Internal Monitoring Procedures: Annual Admin. meeting to review procedures, compliance updates, and update protocols and templates as needed CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Approved Status Date: 10/21/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a description of the district's newly developed procedures for annual selfevaluation to ensure that all students have equal access to all programs including the protected category of gender identity, along with a copy of the district's program review template by December 2, 2013. Submit the results of the district's annual civil rights self-evaluation along with any changes being considered by the district based on the results of that self-evaluation by March 3, 2014. Progress Report Due Date(s): 12/02/2013 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Florida CPR Corrective Action Plan 9