MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services

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MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY
EDUCATION
Program Quality Assurance Services
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Charter School or District: 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
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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.
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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
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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.
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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
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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
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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
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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):
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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
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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.
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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.
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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.
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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).
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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.
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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
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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
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Gloucester CPR Corrective Action Plan
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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