MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services

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MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY
EDUCATION
Program Quality Assurance Services
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Charter School or District: Four Rivers Charter School
CPR Onsite Year: 2010-2011
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 05/06/2011.
Mandatory One-Year Compliance Date: 05/06/2012
Summary of Required Corrective Action Plans in this Report
Criterion
SE 3
SE 13
Criterion Title
Special requirements for determination of specific learning
disability
Transfer of parental rights at age of majority and student
participation and consent at the age of majority
Timeline for determination of eligibility and provision of
documentation to parent
Progress Reports and content
SE 14
Review and revision of IEPs
SE 15
Outreach by the School District (Child Find)
SE 18B
Determination of placement; provision of IEP to parent
SE 7
SE 9
CPR Rating
Partially
Implemented
Partially
Implemented
Partially
Implemented
Partially
Implemented
Partially
Implemented
Partially
Implemented
Partially
Implemented
Criterion
SE 46
SE 54
Criterion Title
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
CPR Rating
Partially
Implemented
Partially
Implemented
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
CPR Rating:
SE 3 Special requirements for determination of specific learning
Partially Implemented
disability
Department CPR Findings:
According to a review of student records and interviews, the team did not consistently
complete all necessary forms needed to create a written determination when evaluating
students suspected of having a specific learning disability.
Description of Corrective Action:
In order to insure consistent completion of necessary forms we have revised our process.
When an initial referral is made and consent to evaluate is initiated, we will note on the
consent form that this student is suspected of having a specific learning disability. The
signed consent form will be passed on to the Director of Academic Support. He will
complete Component 1, Component 3 and Component 4. Component 2 will be completed
at the conclusion of the evaluation period at the initial evaluation meeting.
Anticipated Results:
All required documentation regarding specific learning disabilities will complete and filed
appropriately.
Title/Role(s) of responsible Persons:
Expected Date of
Sp. Educ. Dir, Sp. Educ, Secretary, Dir. of Aca. Supp., Sp. Educ.
Completion:
Liaisons, Reg. Educ. Teachers
05/06/2012
Evidence of Completion of the Corrective Action:
Evidence will be when each part of the SLD documentation is in the students folder. A
check list of necessary documentation will be at the front of each students folder. A
completed checklist will indicated complete documentation.
Description of Internal Monitoring Procedures:
We will gather necessary information at the weekly meetings. These meetings include
regular education teachers, special education teachers and Academic Support Director.
We also review the progress of all evaluations at the weekly Special Education
Coordinators Meeting. A check list will be placed in each students meeting folder. This
folder will be used for each team meeting. The check list will include all necessary
documentation. A completed check list will indicated c complete documentation.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
Corrective Action Plan Status: Approved
SE 3 Special requirements for
Status Date: 06/06/2011
determination of specific learning
disability
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Provide a copy of the newly revised procedure the district has developed to ensure that
the district consistently completes all required forms and paperwork when a student is
suspected of having a specific learning disability by September 15, 2011.
Provide training to Team chairs and other responsible personnel on newly revised district
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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procedures for determination of specific learning disability. Submit an agenda, sign-in
sheets and any materials used along with a copy of the checklist that will be used to keep
track of necessary documentation by September 15, 2011.
Conduct an internal review of a sampling of records from Team meetings that have taken
place since the training and implementation of corrective action, of students suspected of
having a specific learning disability to determine if the Team created a written
determination as to whether or the student had a specific learning disability which was
signed by all members of the Team, or if there was disagreement as to the determination,
one or more Team members documented their disagreement by February 15, 2012.
Submit:
1) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
CPR Rating:
SE 7 Transfer of parental rights at age of majority and student
Partially Implemented
participation and consent at the age of majority
Department CPR Findings:
According to a review of student records and interviews, the district did not consistently
implement requirements for the transfer of parental rights at the age of majority. In one
case the notice went only to the parent rather than to the parent and student, as
required, and in another case there was no notice found in the file.
Description of Corrective Action:
To insure the timely and consistent transfer of parental rights, the process by which this is
done has been revised. Two copies of the consent will be sent to the students home.
One will be addressed to the student and one will be addressed to the parent or legal
guardian. The age of majority consent will be on the agenda and discussed at the team
meeting prior to the student turning 18. Both parent and student will be on the invitation
list.
During the IEP meeting that occurs during the students 17th year meeting Age of Majority
is discussed and documented. Students will meet with Special Education Director to sign
their IEP when they turn 18.
Age of Majority will be an agenda on the PAC meeting.
Information regarding Age of Majority will be published in the school newspaper two times
a year.
Anticipated Results:
Each Special Education Student and their family will experience a successful transfer of
parental rights at the age of majority.
Title/Role(s) of responsible Persons:
Expected Date of
Dir. of Sp. Educ., Sp. Educ. Secretary, Sp. Educ. Liaisons, Four
Completion:
Rivers Administrative Coordinator
05/06/2012
Evidence of Completion of the Corrective Action:
Copies of parental rights for both students and parents will be placed in students file.
Agenda and notes of team meeting will be placed in student file. Meeting invitation and
list of attendees will be placed in file. A check list of necessary documentation will be at
the front of each student?s folder. A completed checklist will indicated complete
documentation
Description of Internal Monitoring Procedures:
We will review students who are nearing their eighteenth birthday at the weekly Special
Education Coordinators Meeting. We will discuss special education student documentation
to insure that students who turn eighteen sign their IEP. A check list of necessary
documentation will be at the front of each student?s folder. A completed checklist will
indicated complete documentation
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
Corrective Action Plan Status: Approved
SE 7 Transfer of parental rights at age of
Status Date: 06/06/2011
majority and student participation and
consent at the age of majority
Basis for Partial Approval or Disapproval:
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Department Order of Corrective Action:
Required Elements of Progress Report(s):
Submit a copy of the district's newly developed process for ensuring that that students
and parents receive the notice of transfer of parental rights one year before their 18th
birthday, and the requirements for student participation and consent at the age of
majority along with the name(s), title(s) and role(s) of staff responsible for tracking the
process by September 15, 2011.
Submit evidence that the district provided training on the new process to staff responsible
for tracking and ensuring the transfer of parental rights at the age of majority, including
agendas, signed attendance sheets with name(s), title(s), and
roll(s) and any materials used by September 15, 2011.
Conduct an internal review of a sampling of records of students whose Team meetings
were held after training and the implementation of corrective action who received
appropriate notice to parent and student one year prior to turning 18, or for whom, upon
reaching the age of 18, the school district implemented procedures to obtain consent from
the student to continue the students special education program and submit by February
15, 2012:
1) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance by February 15, 2012
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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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:
According to a review of student records and interviews, the district did not consistently
convene a Team meeting to determine whether the student is eligible for special
education within forty-five school working days after receipt of the parent's written
consent to an initial evaluation or a re-evaluation.
Description of Corrective Action:
When consent to evaluate is received documentation of each deadline is written at the
bottom of the consent by the Special Education Secretary and then returned to Special
Education Liaison. In weekly Special Education coordinators meeting, each student who
has a returned consent is reported on and the time lines for completion of evaluation and
IEP are established and recorded. The progress of each evaluation and reviewed weekly
Anticipated Results:
Required timelines
Title/Role(s) of responsible Persons:
Expected Date of
Director of Special Education, Special Education Secretary,
Completion:
Special Education Liaisons
05/06/2012
Evidence of Completion of the Corrective Action:
We will have evidence of the completion of the corrective action after each evaluation has
been completed and date of meeting is noted.
Description of Internal Monitoring Procedures:
We review the progress and timeline of all evaluations at the weekly Special Education
Coordinators Meeting.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
Corrective Action Plan Status: Approved
SE 9 Timeline for determination of
Status Date: 06/06/2011
eligibility and provision of documentation
to parent
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Provide a detailed description of the newly developed tracking and oversight system along
with the name(s), title(s) and role(s) of staff responsible for monitoring the system.
Provide evidence that training was provided to responsible staff on the newly developed
system for meeting timelines for determining eligibility and providing documentation to
the parent(s) within 45 working days of receiving a parent's written consent to an initial
evaluation or a re-evaluation. Submit an agenda, sign-in sheet and materials used by
September 15, 2011.
Conduct an internal review of a sampling of IEPs developed since the training and
implementation of the tracking system to determine if the district met timelines for
determinating eligibility and providing documentation to the parent(s) within 45 working
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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days of receiving a parent's written consent to an initial evaluation or a re-evaluation and
submit by February 1, 2012:
1) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance by February 15, 2012
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
CPR Rating:
SE 13 Progress Reports and content
Partially Implemented
Department CPR Findings:
According to a review of student records and interviews, progress reports did not
consistently address all goals in the IEP.
Description of Corrective Action:
At weekly Special Education Coordinators meeting, a consistent agenda item will include
due dates of progress reports. Submission date for special education progress reports will
be the same as school wide progress reports and will be mailed at the same time. Check
list of completed in incomplete progress reports will be conducted through central office
just as regular education progress reports are.
Anticipated Results:
Each special education student will have a timely and complete progress report.
Title/Role(s) of responsible Persons:
Expected Date of
Director of Special Education, Special Education Secretary,
Completion:
Special Education Liaisons,
05/06/2012
Evidence of Completion of the Corrective Action:
We will know that we have successfully corrected this action when completed progress
reports have been mailed and Semstracker indicates we have been timely and through. A
check list of necessary documentation will be at the front of each students folder. A
completed checklist will indicated complete documentation
Description of Internal Monitoring Procedures:
The special education progress reports will be monitored through the central office the
same way that regular education progress reports are monitored. They will also be
tracked and documented through Semstracker. A check list of necessary documentation
will be at the front of each students folder. A completed checklist will indicated complete
documentation
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 13 Progress Reports and content
Corrective Action Plan Status: Approved
Status Date: 06/06/2011
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Provide a detailed description of the newly developed procedure for monitoring progress
reports and ensuring they contain all required elements by September 15, 2012.
Provide training to appropriate staff, including staff responsible for maintaining the central
office checklist, to ensure that student progress reports that parents receive, address all
annual goals in the IEP. Submit an agenda, sign-in sheets with name(s), title(s) and
role(s) and any materials used by September 15, 2012.
Conduct an internal review of a sampling of student progress reports developed after the
implementation of corrective actions to determine if progress reports address all annual
goals in the IEP and submit by February 15, 2012:
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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1) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance.
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
10
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
CPR Rating:
SE 14 Review and revision of IEPs
Partially Implemented
Department CPR Findings:
According to a  review of student records and interviews, the Team did not
consistently hold a meeting at least annually to consider the student’s progress and to
review, revise, or develop a new IEP or refer the student for a re-evaluation, as
appropriate.
Description of Corrective Action:
Special Education Director and Secretary will keep a master list if all annual IEP dates.
These dates will be discussed at each weekly Special Education Coordinators Meeting. At
this meeting dates for IEP meeting will be established. Adjustments to the established
dates will only be made based on parent request. The requests for change of dates will
be documented in students file. In addition, a school wide weekly student of concern
meeting is held. It is attended by administrators and teachers. All students of concern
are discussed at this meeting.
Anticipated Results:
Required timelines will be met consistently.
Title/Role(s) of responsible Persons:
Expected Date of
Director of Special Education , Special Education Secretary and
Completion:
Special education Liaisons
05/06/2012
Evidence of Completion of the Corrective Action:
: We will have evidence of the completion of the corrective action after each IEP date of
meeting is noted on master sheet and placed in student file. A check list of necessary
documentation will be at the front of each students folder. A completed checklist will
indicated complete documentation
Description of Internal Monitoring Procedures:
We will keep current the mast list of all IEP dates. Master list will be updated weekly. The
special education secretary and director will review the master sheet weekly and check
progress of compliance. A check list of necessary documentation will be at the front of
each students folder. A completed checklist will indicated complete documentation
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 14 Review and revision of IEPs
Corrective Action Plan Status: Approved
Status Date: 06/06/2011
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Submit a master list of all annual IEP dates for the 2011-2012 school year along with a
detailed description, including staff responsible for its implementation, of the newly
developed internal oversight and tracking system by September 15, 2011.
Provide evidence of training on oversight and tracking system to responsible staff,
including agenda, signed attendance sheets with name(s), title(s), and role(s) and
materials used by September 15, 2011.
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
11
Conduct an internal review of a sampling of IEPs developed since the implementation of
the tracking system and training to determine if all annual timelines were met and submit
by February 15, 2012:
1) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance.
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
12
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
CPR Rating:
SE 15 Outreach by the School District (Child Find)
Partially Implemented
Department CPR Findings:
According to a review of documentation and interviews, the district does not provide
information to parents and students about how students in need of special education
within the school may be identified.
Description of Corrective Action:
In order to provide frequent outreach, Four Rivers will include information regarding the
referral process in our school wide newsletter. In addition, the referral process will be a
standard agenda item for the PAC meeting.
Anticipated Results:
The anticipated results will be that both parents and students will be provided with
adequate information regarding the referral process.
Title/Role(s) of responsible Persons:
Expected Date of
Dir. of Spec.Educ, Spec.Educ. Secretary, Admin. Coordinator,
Completion:
05/06/2012
Evidence of Completion of the Corrective Action:
We will know that we have completed the corrective action when the Four Rivers
newsletters have included the referral information and that PAC meeting have been held
an the referral process has been discussed. Both the newsletter and PAC meeting agenda
will be filed.
Description of Internal Monitoring Procedures:
Director of Special Education will check with Admin. Coordinator to ensure that
information regarding referral process is included in the newsletter and Director of Special
Education will create and adhere to PAC meeting agenda.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
Corrective Action Plan Status: Approved
SE 15 Outreach by the School District
Status Date: 06/06/2011
(Child Find)
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Submit a copy of the school newsletter(s) containiing the information about the referral
process, and a copy of the PAC agenda for the meeting in which the referral process was
discussed, by February 15, 2012.
Progress Report Due Date(s):
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
13
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:
According to student record reviews and interviews, the district did not provide the parent
with two (2) copies of the proposed IEP and proposed placement immediately following
the development of the IEP, or as an alternative a summary which must, at a minimum,
include (a) a completed IEP service delivery grid describing types and amounts of special
education and/or related services proposed by the district, and (b) a statement of the
major goal areas associated with these services.
Description of Corrective Action:
A copy of team meeting notes that delineate service, placement and intended goals will
be provided to parent at the conclusion of IEP meeting. In addition a form indicating
service, placement and intended goals will be completed by meeting chair and provided to
parents at conclusion of meeting. Parents will be asked to initial that they have received
this form. Upon completion of IEP 2 copies will be sent to students parents. One copy is to
be signed and returned to school and one copy is for the parents.
Anticipated Results:
The anticipated results are that we will provide parents with adequate information
regarding placement, service delivery and anticipated goals in a timely and informative
manner.
Title/Role(s) of responsible Persons:
Expected Date of
Director of Special Education, Special Education Secretary and
Completion:
Special education Liaisons.
05/06/2012
Evidence of Completion of the Corrective Action:
The evidence of completion will be the signature of parents that they have received the
form delineating service, goals and placement. Further evidence will be in students folder
with the team meeting notes that will also delineate service, goals and placement. In
addition a completed IEP with parents signature will be in each students folder. A check
list of necessary documentation will be at the front of each students folder. A completed
checklist will indicated complete documentation
Description of Internal Monitoring Procedures:
: A check list will be placed in each students meeting folder. This folder will be used for
each team meeting. The check list will include form delineating service and completed
team meeting notes among other documentation that needs to be completed either at the
IEP meeting or upon completion of the IEP. A check list of necessary documentation will
be at the front of each students folder. A completed checklist will indicated complete
documentation.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
Corrective Action Plan Status: Approved
SE 18B Determination of placement;
Status Date: 06/06/2011
provision of IEP to parent
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Submit a copy of the district's newly developed procedure for provision of the IEP to the
parent, along with evidence of training on the procedure provided to Team chairs and
other responsible staff, including agenda, sign in sheet with name(s), title(s), and role(s)
by September 15, 2011.
Submit a copy of the form indicating service, placement and intended goals that parents
will receive and initial at the conclusion of the IEP TEAM meeting by September 15, 2011.
Conduct an internal review of a sampling of student records containing IEPs developed
after the new procedure was implemented to determine if parents were issued two (2)
copies of the proposed IEP immediately following the IEP Team meeting, or a summary of
proposed special education and related services and the major goals associated with them
at the conclusion of the Team meeting and submit by February 15, 2012:
1) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance.
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
15
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:
Interviews and document review reveal that while district personnel have some
understanding of the requirements, the district's suspension procedures do not address all
necessary requirements.  The procedures do not address: the steps the Team must
take when the behavior is a manifestation of the disability;  that no later than the
date of any disciplinary action, the district notifies the parent of the decision and provides
written notice of procedural safeguards; steps that should be taken if the student's
behavior was the result of the district's failure to implement the IEP; provision of a
functional behavioral assessment and behavioral intervention services and modifications
to address the behavior so that it does not recur; provision of services in other settings to
enable the student to continue in the general curriculum and to continue receiving
services identified on the IEP. Additionally, suspension procedures do not address
provisions for placing a student in an interim alternative educational setting (IAES) for up
to 45 school day as determined by the Team if the behavior involves weapons, controlled
substances, infliction of bodily injury, or other unique circumstances, or on the authority
of a hearing officer, when the district provides evidence that the student is
"substantially likely" to injure him/herself or others.
Description of Corrective Action:
In order to ensure that the district personnel addressed the necessary requirements for
procedures for suspension of students with disabilities, we will put the Legal Standard for
that procedure in our Student and Family Handbook for the 2011-2012 school year.
District personnel will be notified that the Legal Standard is now a part of our Handbook.
Anticipated Results:
All procedures that the team must take will be fully implemented when the behavior is a
manifestation of a disability
Title/Role(s) of responsible Persons:
Expected Date of
Special Education Director, Dean of Students,
Completion:
05/06/2012
Evidence of Completion of the Corrective Action:
Evidence will be in the 2011/2012 Four rivers Charter School handbook.
Description of Internal Monitoring Procedures:
Director of Special education will notify Dean of Students of the handbook changes and
verify that the changes have been made.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 46 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;
Corrective Action Plan Status: Approved
Status Date: 06/06/2011
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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responsibilities of the district
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Submit a copy of the pages from the 2011-2012 Student and Family Handbook that
contain the revised suspension procedures along with evidence that appropriate staff were
trained in the requirements of those procedures. Include agendas, sign in sheets with
name(s), title(s), and role(s) and materials used by September 15, 2011.
Submit the results of an administrative review of student suspensions taking place after
the implementation of corrective actions by February 15, 2012.
Include:
) The number of student records reviewed
2) The number of student records in compliance
3) For all records not in compliance with this criterion, determine the root cause(s) of the
non-compliance; and
4) The district's plan to remedy the non-compliance.
Please note that when conducting internal monitoring the district must maintain the
following documentation and make it available to the Department upon request: a) List of
students names and grade levels for the record review; b) Date of the review; c) Name of
person(s) who conducted the review, their role(s), and their signature(s)
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
17
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
CPR Rating:
SE 54 Professional development
Partially Implemented
Department CPR Findings:
According to a review of documentation and staff interviews, the district did not
consistently provide training on: state and federal special education requirements and
related local special education policies and procedures; analyzing and accommodating
diverse learning styles of all students to achieve inclusion in the regular classroom;
methods of collaboration among regular education and special education teachers and
paraprofessionals to accommodate diverse learning styles of students in the regular
classroom.
Description of Corrective Action:
In an effort to consistently provide training, a staff professional development time will be
devoted to training of all staff on the special education referral process and procedures
and State and Federal Special Education requirements. In addition all staff will be
encouraged to attend workshops and seminars addressing the needs of diverse learners.
Related professional articles will be shared with staff. Weekly Division meeting that
includes special education as well and regular education will include discussion regarding
accommodations.
Anticipated Results:
It is anticipated that staff will be adequately trained on state and federal special education
requirements and related local special education policies and procedures.
Title/Role(s) of responsible Persons:
Expected Date of
Principal, Special Education Director
Completion:
05/06/2012
Evidence of Completion of the Corrective Action:
Professional development of all staff will take place before the start of the school year.
Work on this will be ongoing throughout the 2011-2012 school year.We will have evidence
of the training because each staff member will sign that they have attended the training.
In addition an account of staff professional development will be kept. Notes of weekly
division meeting are kept.
Description of Internal Monitoring Procedures:
Special Education Director will coordinate professional development with Four Rivers
Principal.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 54 Professional development
Corrective Action Plan Status: Partially
Approved
Status Date: 06/06/2011
Basis for Partial Approval or Disapproval:
The district submitted a plan to provide professional development on local, state and
federal special education requirements, but not specifically on analyzing and
accommodating diverse learning styles of all students in order to achieve an objective of
inclusion in the regular classroom of students with diverse learning styles; and methods of
collaboration among teachers, paraprofessionals and teacher assistants to accommodate
diverse learning styles of all students in the regular classroom
Department Order of Corrective Action:
The district must provide training on state and federal special education requirements and
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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related local special education policies and procedures; analyzing and accommodating
diverse learning styles of all students to achieve inclusion in the regular classroom;
methods of collaboration among regular education and special education teachers and
paraprofessionals to accommodate diverse learning styles of students in the regular
classroom
Required Elements of Progress Report(s):
Submit a proposed schedule and agendas of the required trainings and a description of
materials that will be used by September 15, 2011.
For any training conducted by this date (September 15, 2011), submit sign-in sheets,
agendas and materials used.
Submit an updated training schedule with agendas and descriptions of materials to be
used by February 15, 2012. For any training conducted by this date (February 15, 2012),
submit sign-in sheets, agendas and materials used.
Progress Report Due Date(s):
09/15/2011
02/15/2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
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MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
COORDINATED PROGRAM REVIEW
Charter School or District: Four Rivers Public Charter School
Corrective Action Plan Forms
Program Area: Civil Rights
Prepared by: Peter Garbus, Principal
CAP Form will expand to as many lines as necessary. Before completing and emailing to
pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans.
All corrective action must be fully implemented and all noncompliance corrected as soon as
possible and no later than one year from the issuance of the Coordinated Program Review Final
Report to the school or district.
Mandatory One-Year Compliance Date: April 28, 2012
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: CR 3 Access to a full range of
Rating: Partially Implemented
educational programs
Department CPR Finding: See ELE 5 and ELE 11 (Document review and interviews indicate that
the one ELL student is not receiving adequate levels of ESL instruction and that content area teachers
are not trained in how to shelter content, affecting the student’s ability to access the full range of
academic opportunities.)
Narrative Description of Corrective Action: In addressing ELE 5, the CAP calls for changes in the
level of ESL instruction as well as training teachers in SCI. The actions described will ensure equal
access to the full range of academic opportunities.
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Andy Stenson, Academic
Corrective Action Activity: August 1, 2011
Support Director
Evidence of Completion of the Corrective Action: Individual student schedules for ELL(s). SCI
Professional Development Plan.
Description of Internal Monitoring Procedures: As described in ELE 5.
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: CR 3 Access to a full range
of educational programs
Status of Corrective Action:
Approved
Partially Approved
Disapproved
Basis for Partial Approval or Disapproval: See ELE 5 and ELE 11
Department Order of Corrective Action:
Required Elements of Progress Report(s): See ELE 5
Progress Report Due Date(s): See ELE 5
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
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COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: CR 10A Student handbooks and
Rating: Partially Implemented
codes of conduct
Department CPR Finding: The district’s handbook and code of conduct did not include appropriate
procedures for the discipline of students with special needs and students with Section 504
Accommodation Plans.
Narrative Description of Corrective Action: The school will work with DESE and school counsel to
determine what procedures are incorrect or missing and will revise the handbook and code of conduct
to include all appropriate procedures for the discipline of students with special needs and students with
Section 504 Accommodation Plans.
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Matt Leaf, Dean of Students
Corrective Action Activity: August 1, 2011
Evidence of Completion of the Corrective Action: A corrected handbook and code of conduct.
Description of Internal Monitoring Procedures: Verification by the Principal.
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: CR 10A Student handbooks
and codes of conduct
Status of Corrective Action:
Approved
Partially Approved
Disapproved
Basis for Partial Approval or Disapproval:
Department Order of Corrective Action:
Required Elements of Progress Report(s): The district will revise its handbook to include
appropriate procedures for the discipline of students with special needs and students with Section 504
Accommodation Plans and Submit copies of those pages from its revised handbook by September 15,
2011.
Progress Report Due Date(s):
September 15, 2011.
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: CR 16 Notice to students 16 or
over leaving school without a high school diploma,
certificate of attainment, or certificate of completion
Rating: Partially Implemented
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Department CPR Finding: The written notices that the charter school provides for students who have
fifteen consecutive unexcused absences, and for former students who have not yet earned their
competency determination and who have not transferred to another school, do not meet all the
requirements.
The notice regarding absences goes out after the student is in the process of withdrawing, rather than
after 15 consecutive absences. The letter does not state that the parent or guardian may meet with a
representative within 10 days from the date the notice is sent, or that the district may agree to extend
the time of the meeting for up to 14 days, at the request of the parent or guardian. The letter does not
state that at the meeting participants will discuss the reasons that the student is leaving school and
alternate educational or other placements.
The notice to students who have left school without earning a competency determination does not
inform them of the availability of publicly funded post-high school academic support programs or
encourage them to participate in those programs.
Narrative Description of Corrective Action: The school will issue a notice after 15 consecutive
absences for students and former students who have not yet earned their competency determination and
transferred to another school. It will also state that the parent or guardian may meet with a
representative with 10 days from the date the notice is sent. The letter will also state that meeting
participants will discuss the reasons that the student is leaving school and alternate educational
placements.
The notice to students who have left school without earning a competency determination will inform
them of the availability of publicly funded post-high school academic support programs or encourage
them to participate in those programs.
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Leslie Taylor, Administrative
Corrective Action Activity: August 1, 2011
Coordinator
Evidence of Completion of the Corrective Action: Corrected letter template in the files.
Description of Internal Monitoring Procedures: Verification by the Principal.
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: CR 16 Notice to students 16
Status of Corrective Action:
or over leaving school without a high
Approved
Partially Approved
school diploma, certificate of
attainment, or certificate of completion
Basis for Partial Approval or Disapproval:
Disapproved
Department Order of Corrective Action:
Required Elements of Progress Report(s):
Submit drafts of the two notices; one for students who have 15 consecutive unexcused absences, and a
second for students who have left school without earning a competency determination and have not
transferred to another school by September 15, 2011.
Submit copies of notices it has sent out to students since drafting the notices, if there are any students
who fit either category by February 15, 2012.
Progress Report Due Date(s):
September 15, 2011, February 15, 2012
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
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MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
COORDINATED PROGRAM REVIEW
Charter School or District: Four Rivers Charter Public School
Corrective Action Plan Forms
Program Area: English Learner Education
Prepared by: Andy Stenson, Academic Support Director
CAP Form will expand to as many lines as necessary. Before completing and emailing to
pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans.
All corrective action must be fully implemented and all noncompliance corrected as soon as
possible and no later than one year from the issuance of the Coordinated Program Review Final
Report to the school or district.
Mandatory One-Year Compliance Date: April 28, 2012
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: ELE 5 Program Placement and
Structure
Rating: Partially Implemented
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Department CPR Finding: Document review indicates that the one ELL in the district is not receiving
sufficient English language instruction. The ELL is a beginner, who receives 62 minutes of ESL
instruction three days a week plus 152 minutes of ESL instruction twice per week for a total of 8.2
hours of instruction per week. Beginners should be receiving 2.5 hours of English language instruction
per day for a total of 12.5 hours per week.
Content instruction is based on the appropriate Massachusetts Curriculum Framework; however,
ELLs are not receiving sheltered content instruction, as the majority of teachers have not completed
the 4 required categories of SEI professional development, which focuses on the skills and knowledge
necessary for sheltering instruction, as described in the Commissioner’s Memorandum of June 2004.
As reported, the one ELL participates in general education for his/her content area courses; however,
there is no mention of SEI category trained content teachers to facilitate this. Documents show that
content teachers work with a certified ESL teacher but this does not ensure that they, themselves are
trained. Therefore, the school does not offer a sheltered English immersion program as required by
Chapter 71A.
Review of documentation submitted by the district indicates that the district’s SEI PD plan includes
training all teachers in all four categories by 2013, and that they are conducting training in SEI
categories 1 and 2 in this current year. However, this will leave a void for categories 3 and 4. In
addition, the district’s plan assumes no growth in the ELL population at any of the levels of English
language proficiency, and does not address what will occur when the one ELL progresses to the next
level of ELS instruction.
In addition, Four Rivers does not have an ESL/ELD curriculum, although it is noted that said
curriculum is being developed. However, there was no timeline listed as to when this would be
accomplished.
Narrative Description of Corrective Action:
(1) English Language Instruction: Next year’s schedule is being developed and our one beginning
level ELL will receive three 52 minute periods of ESL instruction each day. This will mean that
the student is receiving more than the required 2.5 hours per day. Based upon ongoing annual
assessment and determination of level of need, the amount of scheduled ESL time for each
subsequent year will be matched to the state recommendations. Future ELL students will be
scheduled to receive the appropriate amount of ESL instruction, based on initial identification
and annual assessments. This will be overseen by the Academic Support Director in conjunction
with the assistant principal.
(2 & 3) SEI Professional Development:
The current SEI professional development plan will be amended to address current issues and
ensure compliance in the future. As a first step, it will call for category 2 training of all teachers
in the grades which our one ELL student will be in for the next two years. The long term PD plan
will be developed in the summer of 2011. It will address training needs based on our current
faculty and student body as well contingency plans for enter ELL’s.
(4) An ESL curriculum has been developed for beginning level ELL’s. It is based on the English
Language Proficiency Benchmarks and Outcomes. The curriculum guide will be
amended by the ESL teacher, with oversight from the ASD, and will take place in
response to newly identified ELL’s as well as changes in the level of our current ELL
student.
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Title/Role of Person(s) Responsible for
Implementation: Andy Stenson, Academic Support
Director
Expected Date of Completion for Each
Corrective Action Activity:
(1) July 1, 2011
(2) August 1, 2011
(3) August 1, 2011
(4) December 1, 2011
Evidence of Completion of the Corrective Action:
(1) Individual student schedule for ELL student.
(2) Completed SEI professional development plan.
(3) Completed SEI professional development plan.
(4) Completed ESL curriculum.
Description of Internal Monitoring Procedures:
(1) Academic Support Director (ASD) will work with the assistant principal to schedule the
one current ELL according to current guidelines. The ASD will notify the assistant
principal of any newly identified ELL’s and will monitor individual schedules to ensure
ongoing compliance.
(2) and (3) The ASD will complete an annual review of the category trainings for current and
newly hired teachers and will work with the school principal to ensure that SCI trainings
in areas of concern are offered as needed.
(3) The ASD will work with the ESL teacher to oversee the development of the ESL
curriculum. Monthly meetings will be held beginning July 1 to monitor progress and
determine next steps. The ESL curriculum will be completed by December 1, 2011.
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: ELE 5 Program Placement
and Structure
Status of Corrective Action:
Approved
Partially Approved
Disapproved
Basis for Partial Approval or Disapproval: Four Rivers Charter Public School has very low
incidence of English language learners (ELLs). Only one ELL was enrolled at the time of the
Comprehensive program review (CPR). This student is reported to be a beginner. A MEPA level of
English Proficiency was not specified.
Four Rivers has formulated an action plan (CAP) that addresses all the elements of the Department’s
CPR findings. However, the district should note that the Massachusetts English Language Proficiency
Benchmarks and Outcomes (ELPBO) will be phased out in the coming months. Therefore, the district
is no longer expected to base its ESL curriculum on the ELPBO; nevertheless, the district is expected
to develop an ESL curriculum, which should be able to stand alone and withstand changes as needed.
Department Order of Corrective Action:
Provide the following:
1) An ESL curriculum.
2) Amended SEI professional development plan.
3) Evidence that teachers teaching the one ELL or any newly identified ELL(s) have completed
SEI category training in all four categories.
4) Evidence that the one ELL and any newly identified ELL(s) are receiving the recommended
hours of ESL instruction.
5) Evidence that the one ELL and any newly identified ELL(s) are placed with teacher(s) who
have been SEI trained in all four categories.
6) Results of internal monitoring activity.
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Required Elements of Progress Report(s):
Please submit the following by September 15, 2011:
1) Submit a completed ESL curriculum or any progress to date.
2) Amended SEI professional development plan addressing this CAP’s PD issues.
3) A spreadsheet indicating the categories of SEI training each teacher in the school has
completed to date. Submit an update by February 15, 2012
4) For the one ELL, submit a schedule that shows the student’s hours of ESL instruction per week
along with his MEPA level of English proficiency.
5) A sample schedules for the one ELL indicating placement with a teacher or teachers who are
SEI trained in all four categories.
6) A summary of results of internal monitoring activities. Include any non-compliance findings
and action taken to remedy such non-compliance.
Progress Report Due Date(s): September 15, 2011; February 15, 2012
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: See ELE 5
Narrative Description of Corrective Action: See ELE 5
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Andy Stenson, Academic Support Corrective Action Activity: August 1, 2011
Director.
Evidence of Completion of the Corrective Action: See ELE 5
Description of Internal Monitoring Procedures: See ELE 5
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 – Program Placement and Structure.
Department Order of Corrective Action: See ELE 5 – Program Placement and Structure.
Required Elements of Progress Report(s): See ELE 5 – Program Placement and Structure.
Progress Report Due Date(s): See ELE 5 – Program Placement and Structure.
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
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COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: ELE 11 Equal Access to
Rating: Partially Implemented
Academic Programs and Services
Department CPR Finding: Document review and interviews indicate that the one ELL student is not
receiving adequate levels of ESL instruction and that content area teachers are not trained in how to
shelter content, affecting the student’s ability to access the full range of academic opportunities.
Narrative Description of Corrective Action: In addressing ELE 5, the CAP calls for changes in the
level of ESL instruction as well as training teachers in SCI. The actions described will ensure equal
access to the full range of academic opportunities.
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Andy Stenson, Academic support Corrective Action Activity: August 1, 2011
director.
Evidence of Completion of the Corrective Action: Individual student schedules for ELL(s). SCI
Professional Development Plan.
Description of Internal Monitoring Procedures: As described in ELE 5
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: ELE 11 Equal Access to
Academic Programs and Services
Status of Corrective Action:
Approved
Partially Approved
Disapproved
Basis for Partial Approval or Disapproval: See ELE 5
Department Order of Corrective Action:
Required Elements of Progress Report(s): See ELE 5
Progress Report Due Date(s): See ELE 5
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: ELE 14 Licensure Requirements
Rating: Partially Implemented
Department CPR Finding: Based on a review of documentation, the district does not have an ESL
provider who is appropriately licensed or holds a current waiver.
Narrative Description of Corrective Action:
Our current ESL teacher, Jessica Roll, is certified in the areas of moderate special needs, Spanish and is
considered “highly qualified” to teach English Language Learners. Ms. Roll has submitted her
credentials for review by the DOE. In conversation with the licensure office she has been informed that
payment of the $25 license fee is all that is required to complete the requirements.
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Andy Stenson, Academic Support Corrective Action Activity: August 1, 2011
Director
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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Evidence of Completion of the Corrective Action: ESL Teacher Certification
Description of Internal Monitoring Procedures: Andy Stenson will meet with Ms. Roll on July 10 to
review and July 31 to verify completion.
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: ELE 14 Licensure
Requirements
Status of Corrective Action:
Approved
Partially Approved
Disapproved
Basis for Partial Approval or Disapproval: None.
Department Order of Corrective Action: None.
Required Elements of Progress Report(s):
Submit a copy or document(s) received from DOE regarding licensure requirements as they become
available. Report on documentation status by September 15, 2011 or February 15, 2012
Progress Report Due Date(s): ): September 15, 2011; February 15, 2012
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
(To be completed by school district/charter school)
Criterion & Topic: ELE 15 Professional Development
Requirements
Department CPR Finding See ELE 5
Rating: Partially Implemented
Narrative Description of Corrective Action: See ELE 5
Title/Role of Person(s) Responsible for
Expected Date of Completion for Each
Implementation: Andy Stenson, Academic Support Corrective Action Activity: August 1, 2011
Director
Evidence of Completion of the Corrective Action: Professional Development Plan
Description of Internal Monitoring Procedures: See ELE 5
CORRECTIVE ACTION PLAN APPROVAL SECTION
(To be completed by the Department of Elementary and Secondary Education)
Criterion: ELE 15 Professional
Development Requirements
Status of Corrective Action:
Approved
Partially Approved
Disapproved
Basis for Partial Approval or Disapproval: See ELE 5 – Program Placement and Structure.
Department Order of Corrective Action: See ELE 5 – Program Placement and Structure.
Required Elements of Progress Report(s): See ELE 5 – Program Placement and Structure.
Progress Report Due Date(s): See ELE 5 – Program Placement and Structure.
MA Department of Elementary & Secondary Education , Program Quality Assurance Services
Four Rivers Charter Public (District) CPR Corrective Action Plan
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