MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Gloucester 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 06/03/2011. Mandatory One-Year Compliance Date: 06/03/2012 Summary of Required Corrective Action Plans in this Report Criterion SE 20 Criterion Title Least restrictive program selected SE 32 SE 37 Parent advisory council for special education Procedures for approved and unapproved out-of-district placements Instructional grouping requirements for students aged five and older Special education facilities and classrooms SE 40 SE 55 CPR Rating Partially Implemented Not Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 20 Least restrictive program selected Partially Implemented Department CPR Findings: Student records indicated that when a student is removed from general education, the IEP Team does not always state why the removal is considered critical to the student´s program and the basis for its conclusion that the education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. Description of Corrective Action: The Director of Special Education in collaboration with the 7 coordinators/supervisors in the district and school administrators, will conduct professional development for all special education teachers, related service providers, and any other identified staff member in order to develop common standards to ensure that when a student is removed from general education, the IEP Team clearly states why the removal is considered critical to the student's program and the basis for its conclusion that the education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be satisfactorily achieved Anticipated Results: Student records will clearly indicate why the student was removed from general education, and the basis for its conclusion that the education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Special Education supervisors (2) Completion: and coordinators (5) 11/23/2011 Evidence of Completion of the Corrective Action: The record will clearly indicate the above as evidenced by narrative text in the N1 letter as well as in the section of the IEP, "Non-participation Justification". Description of Internal Monitoring Procedures: The Director of Special Education will select a sample of student records from each building. If any record in the review does not contain the required information, the director will 1.) remedy the student file by sending the parent the justification and copying it for the record and 2.) determine if additional professional development is needed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 20 Least restrictive program selected Corrective Action Plan Status: Approved Status Date: 07/05/2011 Basis for Partial Approval or Disapproval: The Department accepts the district's corrective action plan as proposed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit evidence such as agendas and sign-in sheet that all special education staff and related service personnel received training on the need to develop common standards to ensure that when a student is removed from general education, the IEP Team clearly MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 2 states why the removal is considered critical to the student's program and the basis for its conclusion that the education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be satisfactorily achieved. This progress report is due November 4, 2011. Subsequent to the staff training, please select a sample of student records to conduct internal monitoring. Please be sure that the sample selected is representative of elementary, middle, and high school. Please submit a narrative report of the results, including the number of records reviewed and the number to found in compliance. This progress report is due February 3, 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 student names and grade level for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s) Progress Report Due Date(s): 11/04/2011 02/03/2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 32 Parent advisory council for special education Not Implemented Department CPR Findings: Staff interviews and a review of the documentation indicated that the district does not currently have an active Parent Advisory Council. Description of Corrective Action: The Director of Special Education, in collaboration with other district and school administrators, will identify parents interested in serving on a Parent Advisory Council. An advertisement will be placed in the 2 local newspapers as well as on the district website (September 2011) inviting parents to an introductory meeting (October 2011) in order to describe the role and responsibilities of the Parent Advisory Council and conduct a workshop on the rights of students and their parents and guardians under the state and federal special education laws. Anticipated Results: The formation of an active Parent Advisory Council with established by-laws regarding officers and operational procedures. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education Completion: 05/10/2012 Evidence of Completion of the Corrective Action: Copies of the advertisements will be provided, along with the sign in sheet from the workshop/introductory meeting, schedule of meetings for the rest of the year, and bylaws. Description of Internal Monitoring Procedures: The Director will determine whether the previously identified noncompliance has been corrected and provide feedback to the Superintendent of Schools, School Committee, and staff. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 3 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 32 Parent advisory council for special Status Date: 07/06/2011 education Basis for Partial Approval or Disapproval: The Department accepts the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit evidence of the districts efforts to identify parents to serve as members of Parent Advisory Council (PAC). Once the parents have been identified, please submit evidence that bi-laws and operational procedures have been established. Finally, please conduct a workshop in conjunction with the PAC for students and their parents on their rights under state and federal special education law. This progress report is due February 3, 2012. Progress Report Due Date(s): 02/03/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 37 Procedures for approved and unapproved out-of-district Partially Implemented placements Department CPR Findings: A review of student records revealed no evidence of monitoring plans for students who are placed in out-of-district placements. Description of Corrective Action: The Director will immediately remedy the issue by having the monitoring plan placed in the District's Policy and Procedures Manual as page 35A. The Director will conduct professional development for any staff member who is the liaison to an out of district student. Internal monitoring will be conducted to verify that the plan is being kept up to date. Anticipated Results: Monitoring plans will be available and updated in each out of district student folder. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, 2 Special Education Supervisors Completion: 09/12/2011 Evidence of Completion of the Corrective Action: 1.) Page 35A in the Policy and Procedures Manual (Sept. 2011) 2.) Professional development sign in sheet (Sept. 2011) 3.) All students who are in out of district placements will have a monitoring plan in their folder. (Sept. 2011) Description of Internal Monitoring Procedures: 1.) An internal analysis will be conducted to determine if monitoring plans are being used consistently (Jan. 2012) 2.) If continued noncompliance is identified, the administrator will review procedures with staff immediately. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 37 Procedures for approved and Status Date: 07/06/2011 unapproved out-of-district placements Basis for Partial Approval or Disapproval: The Department accepts the district correction action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please conduct monitoring of the provision of services and programs for those students placed in out-of-district programs identified by the Department. Please submit evidence of the monitoring conducted for those students identified by the Department. Please ensure that the documentation of monitoring is placed in the file of all students placed in out-ofdistrict placements. Additionally, please conduct an analysis to determine the root cause of noncompliance. Along with a narrative explanation of the results of the analysis, please submit evidence of professional development conducted for special education staff on the requirement to conduct monitoring of the provision of services to students in out-ofdistrict placements. Please include as part of the training, the district’s internal procedures for documenting out-of-district monitoring. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 5 This progress report is due November 3, 2011 Please select a sample of records of students placed in out-of-district placements to ensure that the documentation of monitoring is placed in the student record. Please submit a narrative of the result of the internal monitoring. Please include the number of record reviewed and the rate of compliance. If non-compliance is identified, please remedy the student file and conduct an analysis to determine if additional professional development is needed. This progress report is due February 3, 2012. Progress Report Due Date(s): 11/04/2011 02/03/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 6 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: The review of documentation indicated there are instructional groupings at the high school that exceed the class size requirements. Staff interviews verify that the district has not provided written notification to the Department and parents of all group members regarding the increase in instructional group size. Description of Corrective Action: The Director of Special Education, in collaboration with GHS staff will monitor the class sizes of the instructional groupings at GHS. If the size exceeds the requirements, the parents and DESE will be notified. Anticipated Results: All instructional groupings at the high school will not exceed class size requirements, but if they do, the district will provide written notification to the DESE and parents of all group members regarding the increase in instructional group size. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, GHS administrators Completion: 09/30/2011 Evidence of Completion of the Corrective Action: 1.) Memo sent in July 2011 informing GHS administrators about instructional grouping requirements to prevent this issue. 2) Submission of instructional groupings to Director by 09/15/2011 3.) If necessary, letter to parents and DESE which provides written notification that the instructional groupings exceed the class size requirements by 09/30/2011. Description of Internal Monitoring Procedures: Director will repeat above procedure by 01/15/2012 to insure compliance with this criterion. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 40 Instructional grouping Status Date: 07/06/2011 requirements for students aged five and older Basis for Partial Approval or Disapproval: The Department accepts the district's corrective action plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): Please provide evidence of the memo sent to Gloucester High School administrators on the regulatory requirements for instructional groupings. Additionally, please provide the Department with a copy of the notification to parents should an instructional grouping exceed the requirements. Finally, please provide the Department with the instructional groupings submitted to the director on September 15, 2011. This progress report is due November 3, 2011. Please conduct internal monitoring of the instructional groupings at GHS to ensure MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 7 regulatory compliance. Should a class size exceed the requirements please provide the parents and the DESE with formal notification as required by regulation. This progress report is due February 3, 2011. Progress Report Due Date(s): 11/04/2011 02/03/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 55 Special education facilities and classrooms Partially Implemented Department CPR Findings: Observations at the Veterans Elementary School indicated that special education students receive related services in the library. Observations at the high school indicated that the locations of some special education programs (two therapeutic programs and life skills classroom) do not maximize the inclusion of eligible students into the life of the school. Description of Corrective Action: Students with disabilities are receiving related services in the Veteran's School library, which does not minimize the separation or stigmatization of these students. The same situation is found at GHS, where two programs are located in the same wing of the school. The Director of Special Education in collaboration with the Superintendent, Asst.Superintendents, and principals of Veteran's School and GHS will remedy the situation by relocation where possible or, in collaboration with the Facilities Director, a physical alteration. Anticipated Results: The students at Veteran's School will receive related services in another location 1.) the library will be modified to provide the average physical standards of general education facilities with a smaller computer lab with partitions for instructional space, or 2) two substantially separate SPED classes be moved to other elementary schools or, 3) the music room would be used for additional space, with partitions, and music would be conducted in classrooms. We believe that we have the financial resources to go with option 1 and that it will be completed by the end of December 2011. 2.) The "FAST" program at GHS will be relocated immediately (prior to the 2011-2012 school year) Title/Role(s) of responsible Persons: Expected Date of Superintendent, Asst.Superintendent, Director of Special Ed. Completion: Principals (2),Facility Director 12/31/2011 Evidence of Completion of the Corrective Action: 1.) Students at Veteran's will not receive related services in the library unless there have been modifications to the space there, which is comparable to general education standards or they will be moved into an other room there. 2.) The "FAST" program at GHS will no longer be located in the same wing as the "STEP" program Description of Internal Monitoring Procedures: The responsible persons listed above will conduct a "walk through" in order to ascertain that this partial implementation of this criterion has been rectified. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 55 Special education facilities and Status Date: 07/06/2011 classrooms Basis for Partial Approval or Disapproval: The Department accepts the district's corrective cation plan as designed. Department Order of Corrective Action: Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 9 The Department will contact the district to arrange an onsite verification date before November 4, 2011. Please submit the date of the onsite visit as your progress report. Progress Report Due Date(s): 11/04/2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 10 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Gloucester Public Schools Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Name of School/District Staff Member CAP Form will expand to as many lines as necessary. Before completing and emailing to pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans. All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report to the school or district. Mandatory One-Year Compliance Date: May 18, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7 Rating: Partially Implemented Department CPR Finding: A review of the documentation indicated that the district does not translate information into any other language. Additionally, staff interviews indicated that the district does not have an established system of oral translation. Furthermore, the district does not provide recruitment and promotional materials translated into the major languages spoken by residents with limited English skills. For additional information please see CVTE 4. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 11 Narrative Description of Corrective Action: The district is arranging to contract with a translation service and it will be purchasing translation software to ensure that translations of all notifications will be available to students and to their parents. information provided to students about extracurricular activities and school events is provided to LEP students in a language they understand. All notifications will be translated into the primary language of the home. Notification about individual students will include a child’s level of English Proficiency and explain a parent’s rights with respect to the ELL program. Translation services and software programs will be purchased to provide information regarding activities, responsibilities and academic standards to LEP students in a language and mode of communication that they can understand. A second certified ELL teacher for grades 7-12 will be hired for the fall of 2011. This teacher will work collaboratively with the career and technical education department to ensure that LEP students have access. A stipended position will be established for an ELL Program Director. This position will oversee the above elements of the ELL program. See appendix for possible translation services. Title/Role of Person(s) Responsible for Implementation: ESL Coordinator, ESL Teachers, Building Principals, Guidance Counselors, Vocational Director/Assistant Principal Expected Date of Completion for Each Corrective Action Activity: January 2012 Evidence of Completion of the Corrective Action: Translated materials, availability and use of oral translation service Description of Internal Monitoring Procedures: Building Principals and ESL Coordinator will oversee the translation procedures on an annual basis. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district submitted a list of potential translation services. Additionally, the district submitted a statement indicating that the district will provide notifications, including information pertaining to extracurricular and non-academic programs to LEP students in a language or mode that they can understand. The district’s proposal lacks the specificity to ensure that the translation procedures will be implemented systemically. For example, the district does not include information regarding the building based coordination and logistics of ensuring that information is provided to families in their primary language who require it. The district also does not include information on providing training to staff on newly developed translation procedures. The district’s proposal indicates that the translated material will be provided to those students who are identified as LEP. While Chapter 71A requires translated information be provided to parents and guardians, it is important to note that parents and guardians of students who are not identified as LEP are also entitled to receive information their primary language of communication. For example, parents of students who have been re-designated as Formerly Limited English Proficient may continue to require translated information and notices as well families of students who were assessed and found to be fluent English speakers. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 12 Department Order of Corrective Action: Once the district identifies and secures translation resources for both oral and written language, please develop a system for ensuring that families receive information in their primary language. Additionally, please provide training to staff on the newly developed translation procedures. Required Elements of Progress Report(s): Please provide evidence that the district secured a means of translating information, both oral and written, including low-incidence languages. Please submit a narrative description of the system developed to ensure that translated information is provided to those families who require it. Be sure to include building based coordinators as well as any elements of the system that may be centralized. Please provide evidence, such as agendas and sign-in sheets, that staff were trained on the district’s translation procedures. This progress report is due November 4, 2011. Progress Report Due Date(s): November 4, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 10A Rating: Partially Implemented Department CPR Finding: A review of the district’s documentation indicated the following: The high school handbook’s procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans are incomplete. The procedures do not include information regarding the district’s responsibility to convene members of the IEP Team to conduct a manifestation determination. Additionally, the procedures do not include information regarding the use of an Interim Alternative Education Setting (IAES) and the behaviors or circumstances that allow the district to place a student in an IAES. The middle school does not provide information on the disciplinary procedures for students with a Section 504 Accommodation plan. Additionally, the school’s code of conduct does not include procedures 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. The elementary schools codes of conduct do not provide the schools’ procedures 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 Gloucester CPR Corrective Action Plan 13 Narrative Description of Corrective Action: The district will submit revised student handbooks from all schools in the district which will include procedures and definitions of students with a disability, students on a 504 plan, and students not yet determined eligible for special education, in English and in translation. The language to be added to the Handbooks on the procedures for the discipline of Special Education and students on 504 plans can be found in the appendix to this report. Regarding the issue of harassment, language from the non-discrimination policy and grievance procedures found in Title VI, Title IX, Section 504, ADA, Age Discrimination Act M.G.L.c. 76 §5, M.G.L. c.151C, 603 C.M.R. §26.08 will be placed in the handbooks for the middle and elementary schools. PLEASE SEE THE APPENDIX FOR THE SPECIFIC LANGUAGE. Title/Role of Person(s) Responsible for Implementation: Superintendent, Assistant Superintendent, Principals, Assistant Principals Expected Date of Completion for Each Corrective Action Activity: September 2011 Evidence of Completion of the Corrective Action: Special Education and 504 discipline information, and Harassment procedures will be incorporated in respective students handbooks. Description of Internal Monitoring Procedures: Administrators will ensure placement of procedures in handbooks, and monitor and review cases involving discipline and harassment throughout the school year(s). MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 14 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 10 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposal to submit the revised student handbooks as evidence of completion is accepted by the Department. However, upon review, the information regarding the discipline of students with disabilities is incomplete. The district’s language does not include the specific outcomes and procedural obligations of the IEP Team process for determining whether or not the student’s action(s) was caused by or had direct and substantial relationship to the student’s disability (a manifestation determination). Department Order of Corrective Action: Please revise the language for the discipline of students with disabilities to include the specific outcomes and procedural obligations of the IEP Team process for determining whether the students action(s) was caused by or had direct and substantial relationship to the student’s disability- i.e. a ‘manifestation determination’. Required Elements of Progress Report(s): Please submit a copy of the revised student handbook and a description of the dissemination methods to students, parents, and guardians. Progress Report Due Date(s): November 4, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 14 Rating: Partially Implemented Department CPR Finding: A review of documentation and staff interviews verified that the district does not provide Limited English Proficient (LEP) students with the opportunity to receive guidance and counseling in a language they understand Narrative Description of Corrective Action: A translation service will be contracted, and translation software will be purchased to provide information regarding activities, responsibilities and academic standards to LEP students in a language and mode of communication that they can understand. A second certified ELL teacher for grades 7-12 will be hired for the fall of 2011. This teacher will work collaboratively with the career and technical education department to ensure that LEP students have access. Title/Role of Person(s) Responsible for Implementation: ESL Coordinator, Building Principals, Guidance Counselors and ESL teachers Expected Date of Completion for Each Corrective Action Activity: Translations by Jan. 2011. Trainings by May 2012 Evidence of Completion of the Corrective Action: Written notices will be translated into the language of the home, and arrangements for oral translations when necessary will be in place and implemented. Description of Internal Monitoring Procedures: The ESL teacher, building Principal and guidance counselors at a school will oversee decisions on material to be translated. The ESL Coordinator will schedule trainings, annually. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 15 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 14 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The districts proposal does not include a process for determining when a LEP student requires counseling in their primary language, or the specific information regarding the building based personal responsible for the coordination of counseling. Additionally, the district’s proposal does include any training for staff explaining the new procedures. Department Order of Corrective Action: Please develop a clear process for determining when a LEP student should require counseling in their primary language. Please be sure to include specific information including the building based personnel responsible for the coordination of counseling services Additionally, conduct training for staff explaining the procedures. Required Elements of Progress Report(s): Please submit a description of the process developed to determine when a LEP student should require counseling in their primary language. Please be sure to include specific information including building based personnel responsible for the coordination of counseling services. Please provide the dates of training, attendance sheets and agenda for the staff training. Progress Report Due Date(s): November 4, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 16 Rating: Partially Implemented Department CPR Finding: A review of documentation indicated that the letter informing students of their enrollment status within 10 days of their 15th consecutive unexcused absences is incomplete. The letter does not state that the student and the parent or guardian may meet with a representative of the district within ten days from the date the notice was sent. Additionally, the district did not submit evidence that notification is sent to former students annually for two consecutive years after leaving school without earning a competency determination and informing them of publicly funded post-high school academic support programs. Narrative Description of Corrective Action: Written notices will be developed for the following: 1. Notice to Student 18 years of Age or Over (Non-SpEd 2. Notice to Student 18 years of Age or Over (SpEd) 3. Notice to Parents/Guardians of Student under 18 years of age (SpEd) 4. Notice to Parents/Guardians of Student under 18 years of age (Non-SpEd) These notices will be provided both in English and the primary language of the home) PLEASE SEE APPENDIX FOR SPECIFIC LETTERS MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 16 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Superintendent, Director of Special Corrective Action Activity: Implementation Education, Building Principals, Guidance Counselors, and by September 2011 ESL Coordinator Evidence of Completion of the Corrective Action: Letters have been developed and will be implemented. Description of Internal Monitoring Procedures: The building principal will oversee implementation of these letters and associated counseling services. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 16 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: As part of the proposal, the district submitted examples of notification sent to students who have left school without earning a competency determination. These examples should be considered evidence of completion, and submitted as part of the district’s progress reports. However, upon review, the Department would like to provide the district with an opportunity to remedy the content to align with the requirements of the legal standard. According to MGL 76 §18, the district is required to notify students who are age 16 or older and have left school without earning a competency determination of their enrollment status. The examples of the notifications submitted as part of the district’s proposal, indicate that notification would only be provided to students who are either age 18 or over or age 18 and under. Students, who are under the age of 16, are legally required to attend school and this notification would be inappropriate for truant students. Additionally, the district submitted examples of separate notification sent to students with disabilities, informing them of the opportunity to reconvene the IEP in the event of 15 unexcused absences. It is important to note that the while the district can continue to notify students with disabilities under separate cover of their enrollment status, there are no procedural obligations under state and federal special education law to provide separate notice. Moreover, there is also no regulatory language requiring that the district reconvene the IEP Team should a student with a disability reach 15 unexcused absences. The district’s proposal did not include information that students who are age 16 or older and have left school without earning a competency determination will be provided annual notice of publicly funded post-high school opportunities for two years. Department Order of Corrective Action: Please submit a description of the dissemination methods at Gloucester High School to ensure that students are who are age 16 or older and have left school without earning a competency determination have been notified. Please submit a copy of the letter used to notify student, as well as a copy of the notification sent to students for two years once that have left school with earning a competency determination. Please ensure that the staff members responsible for the provision of the notice are aware that such a notice is appropriate only to students who are 16 or older. Required Elements of Progress Report(s): Please submit the district finalized example of notification(s) as well as a description of the dissemination methods at GHS, including any personnel assigned. Progress Report Due Date(s): November 4, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 17 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 25A Rating: Not Implemented Department CPR Finding: A review of documentation indicated that the district does not annually evaluate its programs to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status have equal access to all programs, including athletics and other extracurricular activities. Narrative Description of Corrective Action: : A system will be established which calls upon administrators to conduct an ongoing evaluation of all aspects of the district’s K-12 programs for accessibility using a variety of data, as well as input from parent, teachers and where appropriate, students. The district will make changes to its programs based on the results of these evaluations. Using the student information system, and of course enrollment in district programs, we will be able to assess equal access. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Superintendent, Assistant Corrective Action Activity: Superintendent, Superintendent, Principals, Guidance, IT Dept. Assistant Superintendent, Principals, Guidance, IT Dept. Evidence of Completion of the Corrective Action: Evaluation system will be in place Description of Internal Monitoring Procedures: The superintendent will be requiring evaluation reports on an annual or semi-annual basis. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 25 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department accepts the district proposal as designed. Department Order of Corrective Action: None Required Elements of Progress Report(s): Please submit a description of the system established to evaluate the various aspects of the accessibility of the k-12 program. Progress Report Due Date(s): November 4, 2011 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 18 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Gloucester Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Gloucester Public Schools 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: May 18, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 3 Initial Identification Rating: Partially Implemented Department CPR Finding: Student records indicated that the home language survey used to initially identify students who are limited English proficient (LEP) is only provided in English. Narrative Description of Corrective Action: The home language survey will be provided in other languages than English. A translation service will be used by the district. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, ESL Corrective Action Activity: November 2011 Teachers and Building Principals Evidence of Completion of the Corrective Action: Surveys in different languages available Description of Internal Monitoring Procedures: ESL teachers will use appropriate surveys and will place in student records which will be reviewed by the building Principal or their designee on an annual basis. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposal does not include specific details on revisions made to the current procedures of administering the home language survey to parents. Additionally, the proposal does not include notification to building level administrators of the procedures, and of the availability of home language surveys in multiple languages. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 19 Department Order of Corrective Action: Please examine the procedures of the district to administer the home language survey to parents. Please adjust the current procedures to ensure that families receive a translated home language survey or oral translation in the event that a survey is unavailable in their primary language. Please inform building administrators of the revisions made to the procedures Required Elements of Progress Report(s): Please submit a description of the districts system of administering the home language survey. Please include any procedures to ensure that families have access to oral translations should the survey not be available in their primary language. Additionally, please provide evidence that all building level administrator have been notified of the changes and of the availability of translated home language surveys. Please provide translated copes of the home language survey. Progress Report Due Date(s): February 3, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 4 Waiver Procedures Rating: Partially Implemented Department CPR Finding: A review of documentation and student records indicated the district has confused the waiver procedures with the opt-out procedures. The district uses waiver procedures for those parents who do not wish to enroll their child in the SEI Program. Staff interviews indicated that once a parent signs a waiver, the student is removed from the SEI program and the student does not receive any English language support Narrative Description of Corrective Action: A specific waiver form is included in the district’s ELE Information Guide. An opt-out form will be created and included in the guide for opt-out procedures. Procedures for using these forms will be communicated in accordance with the legal standard regarding students under and over the age of 10. The Parent Notification letter will include a statement that lets a parent/guardian know that they can waiver these services or decline (opt out) of services. If a parent opts out or declines service, ESL students will still receive Sheltered English immersion support in the classroom. See attached waiver and opt out forms. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, ESL Corrective Action Activity: September 2011 Teachers and Building Principals Evidence of Completion of the Corrective Action: Appropriate Form included in the District’s ESL Guide. Teachers and Principals made aware of the form and procedures. Description of Internal Monitoring Procedures: ESL teachers and Building Principals will review procedures for waiver and opt out. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 4 Status of Corrective Action: Approved Partially Approved MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan Disapproved 20 Basis for Partial Approval or Disapproval: The district’s proposal does not include specific steps taken to ensure that relevant district personnel will receive training and/or notification of the district’s waiver procedures which clarifies that a waiver out of SEI into an alternative English language development program (such as entering into a Transitional Bilingual Education or Two-Way program) is different from opting-out of SEI. Please see ELE 8 concerning the corrective action elements for Opt-Out procedures and requirements. Department Order of Corrective Action: Please provide notification to all relevant staff members (i.e. building administrators, ESL coordinators, ESL teachers) of the district’s waiver procedures. Please see ELE 8 concerning opt-out. Required Elements of Progress Report(s): Please submit evidence of training on the waiver procedures to the appropriate staff. Please identify if the district has received any waiver requests, indicate how the district responded to those requests and how the district implemented programming if the district granted a waiver. This progress report is due February 3, 2012. Progress Report Due Date(s): February 3, 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 Gloucester CPR Corrective Action Plan 21 Department CPR Finding: Sheltered English immersion (SEI) is a program model for limited English proficient (LEP) student composed of two parts—English as a second language (ESL)/English Language Development (ELD) and sheltered content instruction. ESL is explicit, direct instruction about the English language, delivered to LEP students only and designed to promote the English language development of LEP students. Sheltered content instruction is an approach for teaching content to LEP students in strategic ways that make the subject matter concepts comprehensible while promoting the LEP students’ English language development. A review of district documents and interviews indicate that the district has an ESL curriculum that is based on the Massachusetts English Language Proficiency Benchmarks and Outcomes. Content instruction is based on the appropriate Massachusetts Curriculum Framework; however, LEP students are not receiving sheltered content instruction, as the majority of teachers have not completed the four required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, as described in the Commissioner’s Memorandum of June 2004. Documentation indicates that across the three elementary schools, only three teachers have completed category 3 and only one has completed category 4. Teachers have not completed any category training at the middle school. Only two teachers at the high school have completed categories 1, 2 and 4. Also, the district did not provide a detailed SEI PD plan indicating a timeline for teachers in the district to complete the four categories of SEI PD. Therefore, the district does not offer a sheltered English immersion (SEI) program as required by Chapter 71A. Documentation and interviews indicated ESL instruction at all schools is insufficient and is inconsistent with the Department’s September 2009 guidance document: “Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students." High school LEP students receive the least amount of instruction, inconsistent with the guidance of the Department, for all LEP student proficiency levels. All schools concentrate their hours of instruction efforts in levels 1-3 and provide minimal (if any) English language support for students with levels 4 and 5. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 22 Narrative Description of Corrective Action: Training in categories 1-4 has not been sufficient to include all teachers who have LEP students in their classrooms. The district will complete the following: 1. Consolidate LEP students into three of five elementary schools and train one teacher per grade in the ESL Category training from 2011 – 2012. 2. Consolidate LEP students at the middle school within a single teacher team structure for each grade 6-8 and provide the required category training for these teacher teams. 3. At the high school level, train a teacher in each subject and at each grade 9-12 in the required categories. 4. ESL instruction at all schools will be scheduled to meet the department’s September 2009 guidance document: “Guidance on Using MEPA Results to Plan Sheltered English Immersion Instruction and Make Reclassification Decisions for Limited English Proficient Students”. Currently, the district uses multiple assessments to assess students and place them accordingly. Unfortunately, students have not received the number of instructional hours consistent with the Dept guidelines due to a lack of teachers. A second certified ESL teacher will be hired in the spring of 2011 so as to provide the appropriate instructional time to students at the different instructional levels 1-5 for the fall of 2011. This teacher will instruct students in grades 7-12 and will group students according to need based on assessment results including the MEPA. The teacher will work closely with Gloucester’s current certified K-8 ESL teacher to ensure compliance in instructional time by proficiency level, record keeping and necessary translations for ESL notifications. The K-8 ESL teacher will also become the district’s ESL Program Leader with a stipend to support the resolution of some of the compliance issues. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, Building Corrective Action Activity: Teacher hired Principals and ESL Teachers and Guidance in June 2011 for Fall 2011. Training in Counselors categories completed in spring 2012 or 2013. Evidence of Completion of the Corrective Action: Hired ESL teacher, Schedules of ESL students with instructional times and records of groupings based on assessments that determine proficiency levels. The district will keep a list as it does now for teachers trained in the different categories. Description of Internal Monitoring Procedures: The ESL teachers, ESL coordinator and building Principals will review schedules, instructional times and proficiency assessments on an annual basis. Training agendas and lists of teachers trained will be kept by the ESL Coord. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district has an enrollment of over 50 English language learners. More than half of the ELLs are enrolled in elementary school; most of the other ELLs are in middle school, and a few are enrolled in high school. The district has a plan for complying with the Corrective Action Plan for this criterion. However, the MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 23 district capacity to provide ESL services to middle and high schools students was contingent upon the hiring of a second ESL teacher for the Fall 2011. The ESL teacher for the elementary grades will have both teaching ESL and administrative responsibilities. With more than half of the ELE students in the early grades the plan may not be sustainable long term. This may be especially so, if the number of ELE students in the early grades continues to grow. Department Order of Corrective Action: Please submit the following: Names of individuals responsible for implementation. Evidence of teachers at all grade levels having completed Structured English Immersion (SEI) category training to date (elementary, middle and high school). Evidence that content area teachers have been trained in SEI. Evidence of hours of ESL instruction that are consistent with the Department’s recommended guidelines. Evidence that placement of ELLs is with content area teachers who completed SEI category training. Required Elements of Progress Report(s): Please submit the following by February 3, 2012: Schedules of ESL teachers for elementary and upper grades Spreadsheet listing ELLs English proficiency level and corresponding hours of instruction they are receiving. Please submit the following by April 13, 2012: Training agendas for SEI Category trainings A spreadsheet listing teachers per school and the SEI training categories they completed to date along with dates when the training was completed. See also ELE 9. Progress Report Due Date(s): February 3, 2012; and April 13, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 6 Program exit and readiness Rating: Partially Implemented MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 24 Department CPR Finding: The documentation review of the district’s procedures determined that students who score at Level 4 on the MEPA are reclassified as Formerly Limited English Proficient (FLEP). Additionally, district policies indicated that consideration is given to the student’s overall academic and classroom performance. However, interviews confirmed that the decision to reclassify a student as FLEP is often relegated to the student’s ESL teacher, and is not the result of a clear process involving input from the student’s classroom teachers. Furthermore, the district does not provide follow up support or monitoring for two years as required. See also ELE 13. Narrative Description of Corrective Action: The district will use the form in Gloucester’s ELE Information Guide entitled “Formally Limited English Proficient Exit & Monitoring Form” to reclassify a student as Formerly Limited English Proficient (FLEP) and will include the student’s classroom teacher (s), ELE teacher and counselor in a collaborative decision-making process based on data and teacher recommendation(s). Documented follow-up support/monitoring will be provided. When a second ELE teacher is hired by the district, there will be 2 ELE teachers who can appropriately exit and monitor FLEP students. See attached exit criteria and forms. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Teachers, guidance Corrective Action Activity: Jan. 2011 counselors, Building Principals and ESL Coordinator Evidence of Completion of the Corrective Action: Student records for FLEP students in their files as well as documentation of follow-up support. Description of Internal Monitoring Procedures: Building Principals will support classroom teachers, guidance counselors and ESL teachers in collaborating about the needs of students who could possibly be exited and monitored. ESL teachers will report to the ESL Coordinator. Student records will be reviewed regularly by the building Principal or their designee. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion & Topic: ELE 6 Program exit and readiness Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district submitted two forms to document exit criteria to determine students’ eligibility to exit the ELE program. It was unclear which of these forms will ultimately be used. The information contained in each of the two forms could be collapsed to create a single form. In addition, the form entitled: Gloucester Public Schools Exit Criteria for ELL Students did not specify, for each tests listed, please specify what cut off points will be used for a re-classification decision. No schedule was provided for Internal monitoring activities. Department Order of Corrective Action: Please submit the following: Evidence that the district is using consistent criteria to reclassify ELE students from limited English proficient (LEP) to formerly limited English proficient (FLEP) students. Schedule of internal monitoring activities. Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 25 Please submit by February 3, 2012: Names of individuals responsible for CAP implementation if specific to this criterion. A revised exit form with clear re-classification criteria. Progress Report Due Date(s): February 3, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 7 Parental Involvement Rating: Partially Implemented Department CPR Finding: Although the district provides parents of LEP students with interpreters at parent teacher conferences, a review of the documentation submitted and staff interviews verified that the district does not provide any information regarding academic programs and services in the primary language of the home. See also ELE 11. Narrative Description of Corrective Action: This criterion was found to be fully implemented in the initial response to the CPR findings in May 2011. Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: Evidence of Completion of the Corrective Action: Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 7 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district indicated that the rating status for this criterion was changed during the Draft Report comment period and as a result did not submit a corrective action plan proposal. The Department’s response to this criterion did result in a revision of the original comment’s language. However, the rating status was not changed and a finding in this criterion remained. Therefore, the district is required to take correction action to remedy the noncompliance identified. Department Order of Corrective Action: Please ensure that parents who require translated communications receive communications regarding their child’s academic and nonacademic programs in their primary language. Required Elements of Progress Report(s): Please submit a narrative description of the steps taken to ensure that that parent’s of LEP students receive communication regarding academic and nonacademic programs in their primary language. Progress Report Due Date(s): February 3, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 26 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 8 Declining entry to a Rating: Partially Implemented program Department CPR Finding: The review of student records indicated that LEP students eligible for special education services under IDEA are “reclassified” as special education students and therefore, do not receive a Sheltered English Immersion (SEI) program and do not receive any English language support. Student records and staff interviews indicated that in some instances, parents are asked to sign a waiver form indicating that they do not wish to enroll their child in the SEI program. For additional information, please also see ELE 4. Narrative Description of Corrective Action: Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: Evidence of Completion of the Corrective Action: Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 8 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s form noted under “ELE 4” for opt-out procedures is inconsistent with the requirements. Sheltered English Immersion consists of two components. Sheltered content instruction and direct English language development, which in Massachusetts is English as a Second Language (ESL) services from a licensed ESL teacher. The district’s letter indicates the student’s parent would be declining ESL services to the student. This is incorrect, and would not meet the requirements of federal law. The district must revise its opt-out letter to clarify that the student would not be placed in an SEI program. The student, however, consistent with Title VI, would still be entitled to receive English language development consistent with Title VI. The district’s proposal does not include any internal monitoring procedures to ensure that once a student has chosen to ‘opt-out’; they are still provided with an opportunity to have their language needs met as required by Title VI of the Civil Rights Act of 1964. Department Order of Corrective Action: Please provide staff training on the meaning of “opt-out” and how students who opt-out will receive English Language Development consistent with Title VI. Please conduct internal monitoring of student records to ensure that once a parent chooses to decline enrollment in the program, the student is still afforded the opportunity to have their language needs met as required by Title VI of the Civil Rights Act of 1964. Title VI requires that students receive English language development, which in Massachusetts, is ESL services from a licensed ESL teacher. Required Elements of Progress Report(s): Please see progress report for ELE 4. Progress Report Due Date(s): February 3, 2012; April 13, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 27 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: Interviews at the high school confirmed that students identified as Limited English Proficient are grouped in an ESL class without consideration of the students’ English language proficiency levels. See also, ELE 5. Narrative Description of Corrective Action: The district will be hiring a certified ESL teacher for grades 7-12. Students will be grouped and scheduled for instruction based on their levels of English proficiency. Instruction will be at the appropriate proficiency level, based on the English language Proficiency Benchmarks and Outcomes and of the appropriate length of time. At the high school level in particular, scheduling will need to accommodate these instructional settings. The hiring of a second certified teacher will also allow the elementary ESL teacher time to establish the appropriate instructional hours based on proficiency levels at the elementary level. Some consolidation of students is occurring at the elementary level as well (3 of 5 schools) and one teacher per grade. This will help to focus the program and the training on fewer teachers. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL teachers, Guidance Corrective Action Activity: November 2011 Counselors, Building Principals and ESL Coordinator Evidence of Completion of the Corrective Action: Schedules of students with instructional hours Along with evidence of proficiency level and placement. Description of Internal Monitoring Procedures: The ESL Coordinator in conjunction with ESL teachers, guidance counselors and building Principals will oversee appropriate scheduling and record keeping regarding proficiency levels and placement on an annual basis. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See also comments ELE 5. The district should note that for any grouping of ELLs for the purpose of ESL/ELD instruction, the students’ English proficiency assessment (MEPA level) must be considered. For instance, the district can mix students by grade levels, but care must be taken that the students’ English proficiency level is similar. For example, ELLs in levels 1 and 2 can be grouped together as well as ELLs in levels 4 and 5. However, ELLs in level 3 should be mixed only with other level 3 English proficient students. Thus, the district can mix students by up to three grade levels as long as long as students’ level of English proficiency is similar. Other factors could also be considered for grouping ELLs such as the students’ maturity, literacy level, and/or cultural background. Department Order of Corrective Action: MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 28 Please provide the following: Evidence of appropriate grouping of students (English proficiency level or mixed grades and similar English Proficiency Level). See also ELE 5. Required Elements of Progress Report(s): Please submit the following by February 3, 2012 A spreadsheet listing ELE students and ESL services (individual or group) being provided to ELLs. Please be sure to include the students name, grade, school assignment, and language proficiency level. Provide three to five samples of student’s group schedules and name(s) of ESL staff. Include group (s) in the early grades, middle school, and high school. Progress Report Due Date(s): February 3, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 10 Parental Notification Rating: Partially Implemented Department CPR Finding: A review of student records indicated that the parent notification is not translated into the primary language of the home, does not include the child’s level of English proficiency and does not explain the parents’ right to decline enrollment of their child in the program. Additionally, staff interviews indicated that parents of LEP students are notified upon initial identification of their child’s designation as LEP, but do not receive annual notification of their child’s LEP status and enrollment in the SEI program Narrative Description of Corrective Action: The parent notifications will be translated into the primary language of the home. The notification will include a child’s level of English Proficiency and explain a parent’s right to decline enrollment. Currently, the parent notification letter in the district’s ELL Information Guide (p.12) includes the child’s level of English proficiency and a section for a parent to decline enrollment. Annual notification of a child’s LEP status and enrollment in the SEI program will be instituted more consistently. Currently, this annual letter goes out to K-8 students parents. It will also go out to 9-12 students/parents. See attached Parent Notification letter. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Guidance Counselors, ESL Corrective Action Activity: December 2011 teachers, Building Principals and ESL Coordinator Evidence of Completion of the Corrective Action: Notifications in languages parents can understand, forms in a student’s record. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 29 Description of Internal Monitoring Procedures: Records reviewed by building Principal or their designee and the ESL teachers. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposal does not include information regarding notification to relevant staff members on the requirement to notify parents upon initial identification of the student as LEP and placing the student in the SEI program and annually thereafter. Additionally, the proposal does not include any evidence of internal monitoring to ensure that families receive the notification in their primary language of communication upon initial identification and annually thereafter. Finally, while the example of the parent notification letter the district submitted includes the results of the language assessment conducted, it does not provide the parent with information of the student’s overall language proficiency level. Department Order of Corrective Action: Please include training to the relevant staff on the procedures used to notify parents upon initial identification of the student’s LEP status and the notification annually thereafter. Please develop a system to ensure that notification is sent, including the building-based personnel responsible. Additionally, please ensure that the parent notification letter includes an overall language proficiency level. Finally, please conduct internal monitoring of student records to ensure that the parent notification has been sent upon initial identification of LEP status and annually thereafter. Required Elements of Progress Report(s): Please submit the evidence of the training provided to staff. Please submit a narrative description of the steps taken to ensure that notification is sent. Additionally, please submit a revised copy of the parent notification letter to include an overall language proficiency level. This progress report is due February 3, 2012. Please submit a narrative description of the results of the internal monitoring. The results must include the number of records reviewed, the number of records found in compliance, and for any record not in compliance, the district’s corrective actions. This progress report is due April 13, 2012. Progress Report Due Date(s): February 3, 2012; April 13, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal access to academic Rating: Partially Implemented programs and services Department CPR Finding: Staff interviews indicated the district does not provide information regarding activities, responsibilities, and academic standards to LEP students in a language and mode of communication that they can understand. Additionally, the district does not have teachers who have received training in all four categories for sheltering content required by the Department; therefore LEP students do not have equal access to a full range of academic opportunities. Furthermore, the district does not provide LEP students access to career and technical education. For additional information, please see CVTE 4 and CVTE 5. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 30 Narrative Description of Corrective Action: A translation service/software will be purchased to provide information regarding activities, responsibilities and academic standards to LEP students in a language and mode of communication that they can understand. The district is going to consolidate efforts in terms of placing LEP students in three out of five elementary schools with one teacher per grade trained at the elementary schools; one team per grade at the middle school and one team of core teachers at the high school. Training in the four categories for sheltering content will be planned and implemented over the next two years. The Northeast DSAC is currently planning category training that the Gloucester District will participate in. Gloucester participated in the spring of 2011 in category 1 training sponsored by the Northeast DSAC. A second certified ELL teacher for grades 7-12 will be hired for the fall of 2011. This teacher will work collaboratively with the career and technical education department to ensure that LEP students have full access. A 9-12 schedule will be developed that will allow not only for appropriate instructional time but for opportunity to access career and technical education. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, Building Corrective Action Activity: Translations by Principals, Guidance Counselors and ESL Jan. 2011. Trainings by May 2012 or 2013. teachers Evidence of Completion of the Corrective Action: Agendas for trainings and lists of teachers trained. Copies of translated materials. Schedules of students. Description of Internal Monitoring Procedures: The ESL teacher, building Principal and guidance counselors at a school will oversee decisions on material to be translated. Trainings will be scheduled yearly by the ESL Coordinator. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 11 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposal regarding translation lacks the specificity required to ensure that LEP students will be provided information regarding activities, responsibilities and academic standards in a language and mode of communication that they can understand. Also, the district’s proposal does not include information related to notifying staff of translation procedures. The districts proposal regarding the high school ESL teacher’s collaboration and coordination with the CVTE liaison to ensure LEP students have access to CVTE program lacks specificity. Department Order of Corrective Action: Please develop a system to ensure that LEP students receive information regarding activities, responsibilities and academic standards in a language and mode of communication that they can understand. Please indicate building based personnel responsible for administering and tracking translated information. Finally, please notify all relevant building based staff of the translation procedures. Please create a process, in collaboration with the CVTE liaison, to ensure that LEP students will have access to all CVTE programs. Please identify building based personnel responsible for the coordination of services and providing written and oral translations to LEP students and their families if necessary. Required Elements of Progress Report(s): Please submit narrative description of the system developed to ensure that LEP students receive information regarding activities, responsibilities and MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 31 academic standards to LEP students in a language and mode of communication that they can understand. Please submit a description of the procedures created, in collaboration with the CVTE liaison to ensure that LEP students have access to all CVTE programs. Progress Report Due Date(s): February 3, 2012. COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 12 Equal access to nonRating: Partially Implemented academic programs and services Department CPR Finding: Staff interviews indicated that information provided to students about extracurricular activities and school events is not provided to LEP students in a language they understand. Narrative Description of Corrective Action: A translation service/software will be purchased to ensure that information provided to students about extracurricular activities and school events is provided to LEP students in a language they understand. Building Principals along with the ESL Coordinator, the ESL teachers and the Guidance Counselors will determine the important documents to be translated and they will submit extracurricular notices and school events to a translation service. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, ESL Corrective Action Activity: Jan. 2011 Teachers, Building Principals, Guidance Counselors Evidence of Completion of the Corrective Action: Translated materials Description of Internal Monitoring Procedures: Building Principals and ESL Coordinator will oversee the translation procedures on an annual basis. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 12 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposal lacks specific detail to ensure that LEP students will consistently receive notice of extracurricular activities and school events in a language they understand. Additionally, the district’s proposal does not include information regarding formal notification to all relevant staff members expected to implement the newly developed translation system. Department Order of Corrective Action: Please develop a system to ensure that any notifications regarding extracurricular activities and school events students are provided to LEP students in a language and mode that they understand. Please identify building based personnel responsible of this activity. Please formally notify all school based administrators and any other relevant staff members of the newly developed system. Required Elements of Progress Report(s): Please submit a description of the newly developed translation system established, including building based personnel responsible for the administration MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 32 and tracking of translations. Please submit evidence that formal notification has been provided to all building administrators and any other relevant staff members of the newly developed system. Progress Report Due Date(s): February 3, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 13 Follow-up support Rating: Partially Implemented Department CPR Finding: Staff interviews at the high school indicated students who exited the English learner education program are not monitored for progress in the regular education program. A second certified ESL teacher for grades 7-12 will be hired for the fall of 2011. This teacher will have the time to properly support and monitor ELL students’ progress after exiting the English Learner Education Program. The current ESL K-8 teacher will then be responsible for only K-6 students and will have time to more appropriately exit and monitor ELL students and work more collaboratively with the classroom teacher in support of students. See the form entitled “Formally Limited English Proficient Exit and Monitoring Form”. Also see Gloucester’s “ELL Program Record Form”. Narrative Description of Corrective Action: Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL teacher, Guidance Corrective Action Activity: Nov. 2011 Counselors and classroom teachers, Building Principal Evidence of Completion of the Corrective Action: Student records Description of Internal Monitoring Procedures: Records will be reviewed by the building Principal or their designee on an annual basis. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 13 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposal does not include information regarding notification to staff on the requirements to monitor students designated as Formerly Limited English Proficient (FLEP) for two consecutive years. Additionally, the district’s proposal does not include any internal monitoring of student records to ensure that monitoring of students designated as FLEP is documented for two consecutive years. Department Order of Corrective Action: Please notify the appropriate staff, including general education content teachers of the requirements to monitor students designated as FLEP for two consecutive years. Additionally, please conduct internal monitoring of student records to ensure that the monitoring of students designated as FLEP has been documented and placed in the student records for two consecutive years. Required Elements of Progress Report(s): Please submit evidence, such as a sign-in sheet, that all staff have been have been notified of the requirement to monitor student’s who have been redesignated as FLEP for two consecutive years. This progress report is due February 3, 2012. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 33 Please submit the results of the internal monitoring of student record conducted. Please indicate the number of students identified as FLEP, the number of records that demonstrate monitoring of the student’s progress, and any corrective action initiated if the district identifies students who were not monitored to ensure progress in the general curriculum. Please describe what actions were taken if the district identified students who are not making progress. This progress report is due April 13, 2012. Progress Report Due Date(s): February 3, 2012; April 13, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 14 Licensure requirements Rating: Partially Implemented Department CPR Finding: Documentation indicated that the two teachers at the high school in the role of ESL teachers hold foreign language certificates for grades 5-12 and do not hold ESL licensure. Narrative Description of Corrective Action: A 7-12 certified ESL teacher will be hired for the fall of 2011. The current K-8 teacher is licensed and will work collaboratively with the new 712 teacher. She will also be given a stipend to act as an ESL Program Leader to partially oversee the work towards compliance along with the ESL Coordinator and others. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, Corrective Action Activity: June 2011 for Superintendent fall 2011 Evidence of Completion of the Corrective Action: Certified ESL teacher formally appointed by the Superintendent Description of Internal Monitoring Procedures: Evaluated by Principals CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Please submit evidence that the new hire has appropriate credential for the position. Required Elements of Progress Report(s): Please submit a copy of the new hire’s ESL certificate by February 3, 2012. Progress Report Due Date(s): February 3, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 34 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Development Rating: Partially Implemented Department CPR Finding: Based on a review of documentation submitted by the district, teachers who provide content instruction to Limited English Proficient students have not completed all four categories of the Sheltered English Immersion training required by the Department. Please see ELE 5 for additional information Narrative Description of Corrective Action: Category 1 and 2 has been offered in the district. Additional category training will occur over the next 2 years for elementary, middle and high school teachers. The district is developing a plan to consolidate LEP students within three elementary schools, and a team of core teachers in middle and high school so that training efforts will be more focused. As well, at the elementary level, one teacher per grade will be further trained to again focus efforts. The Northeast DSAC is planning training to support districts in setting up category training. The Race to the Top grant will provide some funds as well. I can not provide a specific timeline of training because the district is depending on DSAC sponsored training in FY12. However, we had about 25 teachers trained in Category 1 in FY11 and will want to support about 46 K-12 teachers in Category 2 and 4 training in FY12 and FY13. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, Building Corrective Action Activity: May 2012 or Principals and Consultants 2013. Evidence of Completion of the Corrective Action: Training Agendas and List of trained teachers in each category Description of Internal Monitoring Procedures: ESL Coordinator will monitor the training process annually. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district intends to comply with the CAP by consolidating ELE students within three elementary schools rather that enrolling them in all elementary schools in the district. The plan also involves working with teams of core teachers in middle and high school, so that its training efforts can be more focused in all schools. At the elementary level the district plans to train one teacher per grade level in the SEI categories whereas in the middle school SEI category training will take place within teacher-teams; one teacherteam for each grade 6-8. In high school, the district plans to train one teacher in each subject and at each grade 9-12 in all the SEI categories. The only caveat to this plan is that the district must have sufficient capacity to easily replace any teacher’s temporary/permanent absence. Also, the district should note that the Department will be phasing out the MELA-O, therefore the MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 35 district is required to have only sufficient numbers of trained MELA-O staff to meet the assessment needs of current and incoming ELLs, but is no longer required to train all teachers in Category 3. The district must continue to train teachers in Categories 1, 2 and 4. Department Order of Corrective Action: See ELE 5. 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 16 Equitable facilities Rating: Partially Implemented Department CPR Finding: The facilities observation at Veterans Elementary School determined that LEP students receive services in the library which is not comparable to the facilities for instruction provided to the overall student population Narrative Description of Corrective Action: A plan is being developed to provide “comparable facilities for instruction” at Veteran’s Memorial School. Three options include: 1) A smaller computer lab with partitions for instructional space. 2) Two substantially separate SPED classes be moved to other elementary schools 3) Music room is used for additional space and music is conducted in classrooms. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Superintendent, Principal, ESL Corrective Action Activity: Dec. 2011 Coordinator and Facilities Director Evidence of Completion of the Corrective Action: a comparable instructional space for ESL exists Description of Internal Monitoring Procedures: The Superintendent, Principal and ESL Coordinator will oversee completion of the plan. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 16 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department accepts the district’s corrective action proposal as designed. Department Order of Corrective Action: None Required Elements of Progress Report(s): The Department will conduct onsite verification as correction of noncompliance. The Department will contact the district to arrange a date for onsite verification. The district will submit that agreed upon date in its progress report to the Department. Progress Report Due Date(s): February 3, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 36 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 17 Program evaluation Rating: Partially Implemented Department CPR Finding: A review of the documentation indicated that the district proposed procedures for conducting an evaluation of the English Language Education program. However, there is no evidence that the district implemented the proposed procedures and conducted an evaluation of the program Narrative Description of Corrective Action: The district will use its proposed procedures to conduct an evaluation of the English Language Education program in the spring of 2012 after a full year in which two certified ESL teachers will be in place. See attached evaluation procedures. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Coordinator, ESL Corrective Action Activity: June 2011 teachers, Building Principals, Guidance Counselors and Classroom teachers Evidence of Completion of the Corrective Action: Evaluation report. Description of Internal Monitoring Procedures: Superintendent, ESL Coordinator and Building Principals will ensure that an evaluation report is completed for the district which would include input from each school. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 17 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department accepts the district’s corrective action plan as designed. No further progress reports are necessary for this criterion. Department Order of Corrective Action: None Required Elements of Progress Report(s): None Progress Report Due Date(s): None COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 Records of LEP students Rating: Partially Implemented Department CPR Finding: The review of student records indicated that the records were missing information regarding the student’s previous school experience, home languages surveys, and evidence of follow-up monitoring. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 37 Narrative Description of Corrective Action: Records will be reviewed annually for information regarding student’s previous school experience (when available) home language surveys, and evidence of follow-up monitoring. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL teachers, ESL Corrective Action Activity: June 2011 Coordinator, Building Principal, Guidance Counselors Evidence of Completion of the Corrective Action: Appropriate Records in student files. Description of Internal Monitoring Procedures: A checklist of records will be used to monitor student records on an annual basis. All “blank” records are available in the District’s English Language Learner Information Guide. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Please notify all building level administrators and relevant staff of the elements that are required in the file of each LEP student. Please select a sample of records representative of elementary, middle, and high school to conduct internal monitoring. Please review each file to ensure the record contains all of the required elements. If noncompliance is identified, please conduct an analysis to determine the root cause and remedy the individual student fie. Required Elements of Progress Report(s): Please submit evidence of notification to all building administrators and other relevant staff members of the elements required in the file of each LEP student. Please submit a narrative description of the results of internal monitoring. Please include the number of records reviewed and the rate of compliance identified. Should noncompliance be identified, please submit a description of the district’s corrective action(s). Progress Report Due Date(s): April 13, 2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Gloucester CPR Corrective Action Plan 38