MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Haverhill CPR Onsite Year: 2012-2013 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 11/06/2013. Mandatory One-Year Compliance Date: 11/06/2014 Summary of Required Corrective Action Plans in this Report Criterion SE 2 Criterion Title Required and optional assessments SE 9 SE 14 Timeline for determination of eligibility and provision of documentation to parent Review and revision of IEPs SE 18B Determination of placement; provision of IEP to parent SE 19 Extended evaluation SE 20 Least restrictive program selected SE 21 School day and school year requirements CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 22 Criterion Title IEP implementation and availability SE 25A Sending of copy of notice to Special Education Appeals SE 26 Parent participation in meetings SE 34 Continuum of alternative services and placements SE 36 SE 43 IEP implementation, accountability and financial responsibility Behavioral interventions SE 44 Procedure for recording suspensions SE 45 SE 49 Procedures for suspension up to 10 days and after 10 days: General requirements Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district FAPE (Free, appropriate, public education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education Related services SE 51 Appropriate special education teacher licensure SE 52 SE 53 Appropriate certifications/licenses or other credentials -related service providers Use of paraprofessionals CR 3 Access to a full range of education programs CR 7A School year schedules CR 18 Responsibilities of the school principal SE 46 SE 48 CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 2 Required and optional assessments Partially Implemented Department CPR Findings: A review of student records indicates that assessments are not consistently conducted upon receipt of parental consent. Specifically, the district does not always complete classroom observations, Educational Assessment A, which includes a history of the student's educational progress in the general curriculum, and Educational Assessment B, which includes an assessment of the student's current abilities in the general education curriculum, as well as an assessment of the student's attention skills, participation behaviors, communication skills, memory, and social relations. Description of Corrective Action: Professional development of Special education process via consultant qualified to complete training Title/Role(s) of Responsible Persons: Expected Date of School Psychologist, Education Team Facilitators, Special Completion: Education Teachers (Liaisons) 11/06/2014 Evidence of Completion of the Corrective Action: Evaluation plans and completed evaluations will have classroom observation, current abilities in the general education curriculum, and any other evaluation necessary to answer the referral questions. Description of Internal Monitoring Procedures: Charting of evaluations submitted to Special Education office, intermittent file reviews conducted during EFT meetings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 2 Required and optional assessments Corrective Action Plan Status: Partially Approved Status Date: 01/22/2014 Basis for Status Decision: The district did not specifically address the completion of educational assessments and observations for students identified on the Student Issues worksheet provided by the Department. Department Order of Corrective Action: Please complete the missing education assessments and observations for individual students identified by the Department on the Student Record Issues Worksheet and reconvene the IEP Team for each. Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures related to the completion of Educational Assessment A/B and observations, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. By March 3, 2014, provide a narrative description of the corrective actions taken for each student identified in the Student Record Issues Worksheet and include a copy of the Team Meeting invitation to the parent. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 3 By May 3, 2014, following implementation of the revised procedures and training, conduct an internal review of 5 student records per level (preK, elementary, middle, hs & including out-of-district) where parental consent was received for initial or re-evaluations. Submit a detailed analysis of the internal review, including the number of student records reviewed at each level; the number of records that contained observations as relevant; comprehensive Educational Assessments A (a history of the student's educational progress in the general curriculum); and B Current performance (teacher assessment that addresses attention skills, participation behaviors, communication skills, memory and social relations with groups, peers and adults). If non-compliance is identified, report the specific actions taken to correct each individual student file, identify and report the root cause(s) of the ongoing non-compliance and a plan to remedy it. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: A review of student records indicates that assessments are not always conducted within 30 school working days of receipt of parental consent to an initial evaluation or a reevaluation. Proposed IEPs and proposed placements for eligible students are not consistently provided to the parents within 45 school working days of receipt of parental consent. Description of Corrective Action: Specific training for educational team facilitators (ETF) and school administrators. Ongoing opportunity for supervision and alternate training for efficient and effective practices. Purchased technology to assist ETF in completing tasks in timely manner. Increase clerical support for ETFs Title/Role(s) of Responsible Persons: Expected Date of Educational Team Facilitators, School Administrators, Completion: 11/06/2014 Evidence of Completion of the Corrective Action: Proposed IEP and proposed placements for eligible students consistently provided to parents within 45 school working days of parental consent to evaluations. Description of Internal Monitoring Procedures: Monthly compliance reviews through Aspen X2 and regularly scheduled file monitoring for standards compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 9 Timeline for determination of Approved eligibility and provision of documentation Status Date: 01/22/2014 to parent Basis for Status Decision: The district's proposed corrective action does not address ensuring that assessments are completed within 30 school working days of parental consent to evaluations. Department Order of Corrective Action: Using the district's Aspen X2 system, develop a sample of student records from each school level (preK, elementary, middle, HS) with initial and re-evaluations conducted between April 2013 and October 2013. Conduct a root cause analysis by review each record for the dates of completion of consented-to assessments. The district's corrective actions should be based on patterns of noncompliance identified from this record review. The district's proposal must also include a method to track the timely completion of all assessments. Required Elements of Progress Report(s): By March 3, 2014, submit the results of the root cause analysis why consented-to assessments are not consistently completed within 30 days of receipt of parental consent. Submit a narrative description of the district's corrective actions based on the root cause analysis, ensuring the completion of assessments within 30 days of receipt of parental consent. Provide evidence of the district's corrective actions, including any revised procedures, staff training on these procedures, and oversight mechanism. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 5 By March 3, 2014, submit a narrative description of the district's revised procedures ensuring the proposal of IEPs/placements within 45 days of receipt of parental consent, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. By May 3, 2014, conduct a second internal record review of 5 student records per level (elementary, middle & hs) where parental consent was received for initial or reevaluations following the implementation of all corrective actions. Submit a detailed analysis of the second internal review, including the number of student records reviewed at each level & the number of records that had assessments completed within 30 days and IEP Teams convened within 45 days of receipt of parental consent. If non-compliance is identified, report the specific actions taken to correct each individual student file, identify and report the root cause(s) of the ongoing non-compliance and a plan to remedy it. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: A review of student records indicates that at all levels IEP Team meetings are not always held and IEPs are not always developed prior to the expiration date of the last accepted IEP. Description of Corrective Action: Train all special education staff, school administrators regarding timelines and implications of noncompliance to timelines. Provide specific training in IEP development and effective use of team meetings. Title/Role(s) of Responsible Persons: Expected Date of School Administrators, Education Team Facilitators, Special Completion: education Liaisons, Service Providers, 11/06/2014 Evidence of Completion of the Corrective Action: All newly proposed IEP and placements will be signed prior to the expiration of the previous IEP. Description of Internal Monitoring Procedures: Monthly compliance review through Aspen X2 and intermittent file reviews with ETFs. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Partially Approved Status Date: 01/22/2014 Basis for Status Decision: The district's proposed corrective actions do not indicate why annual reviews are not consistently conducted on or before the expiration of the previous IEP. Department Order of Corrective Action: Develop a sample of student records for annual Team meetings convened between April 2013 and October 2013 and conduct a root cause analysis to establish why annual meetings are not held on or before the anniversary date of student IEPs. The district's corrective actions should be based on patterns of noncompliance identified from this record review and must also include a oversight mechanism to ensure the timely scheduling of annual reviews. Required Elements of Progress Report(s): Using the district's Aspen X2 system, develop a sample of student records from each school level (preK, elementary, middle, HS) for annual Team meetings convened between April 2013 and October 2013. Conduct a root cause analysis to establish why annual meetings are not held on or before the anniversary date of student IEPs. The district's corrective actions should be based on patterns of noncompliance identified from this record review. By March 3, 2014, submit the results of the root cause analysis why annual Team meetings are not convened on or before the anniversary date of current IEPs. Submit a narrative description of the district's corrective actions based on the root cause analysis, along with evidence of the district's corrective actions, including any revised procedures, staff training on these procedures, and oversight mechanism. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 7 By May 3, 2014, following implementation of revised procedures and training, conduct a second internal record review of 5 student records each level (elementary, middle & hs) for students with annual Team meetings convened following the implementation of all corrective actions. Submit a detailed analysis of the internal review, including the number of student records reviewed at each level & the number of records with annual meetings held on or before the expiration of the current IEP. If non-compliance is identified, report the specific actions taken to correct each individual student file, identify and report the root cause(s) of the ongoing non-compliance and a plan to remedy it. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18B Determination of placement; provision of IEP to parent Partially Implemented Department CPR Findings: Student records indicate that the district does not always provide parents with the proposed IEP and proposed placement immediately following development at the Team meeting. Description of Corrective Action: Specific training for ETF and School Administrators regarding compliance, timelines and role responsibilities of the LEA representative and team chair. Increase clerical support for ETF. Purchase appropriate technology to make discussion and documentation effective and timely. Title/Role(s) of Responsible Persons: Expected Date of Education Team Facilitators and School Administrators Completion: 11/06/2014 Evidence of Completion of the Corrective Action: Proposed IEP and Placement provided to parents immediately following development at the Team meeting. Description of Internal Monitoring Procedures: Compliance monitoring through Aspen X2, receipt of documentation at the special education office, parent survey. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18B Determination of placement; provision of IEP to parent Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the updated procedures related to providing parents with two IEP/placement copies within ten days. Please establish a means to document the provision of 2 copies in the student record. Additionally, provide evidence of staff training on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Following implementation of revised procedures and training, conduct an internal record review of 5 student records each level (elementary, middle & hs) for evidence of (1) provision of the IEP within 10 days following the IEP development meeting and (2) provision of two copies of the proposed IEP to parents, with documentation in the student record. Submit a detailed analysis of the internal review, including the number of student records reviewed at each level; the number of records with 2 copies of the IEP immediately proposed to families; an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. This analysis is due May 3, 2014. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 9 *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 19 Extended evaluation Partially Implemented Department CPR Findings: Student records and interviews indicate that extended evaluations are considered placements and the district uses the extended evaluation process to place students in day programs, interim alternative educational settings and home tutoring settings for disciplinary reasons and behavioral infractions, and for periods of time that exceed eight weeks. Description of Corrective Action: Standard forms for extended assessments and tutorial services will be used throughout the district. All tutoring and extended assessment requests are handled through the special education office. Train school administrators and others through training sessions, team meetings and program developments. Assessment center developed to assist with extensive assessments needed including FBAs to assist home school in educating child in the least restrictive environment. Any long term tutoring is determined by medical necessity (procedures in place) and regularly monitored between special education office and medical community. Title/Role(s) of Responsible Persons: Expected Date of School Administrators, ETFs, Adjustment Counselors, Behavior Completion: teachers, Special Education Director 11/06/2014 Evidence of Completion of the Corrective Action: No student will be subject to the extended evaluation process to place students in day programs, interim alternative educational settings and home tutoring settings for disciplinary reasons and behavioral infractions, and for periods of time that exceed eight weeks. Extended assessments, a collaborative process with the home school, will be used to assess students needs in order to properly educate students in the least restrictive environment. Description of Internal Monitoring Procedures: Process monitoring by support staff through documentation received in the special education office. Monthly reports to be developed to include placements checks through Aspen X2 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 19 Extended evaluation Corrective Action Plan Status: Approved Status Date: 01/22/2014 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures related to the use of extended evaluations, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. Develop a sample of student records in which an extended evaluation was proposed following implementation of corrective actions. Review student records for evidence that MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 11 1) extended evaluations were conducted using the appropriate forms; 2) they were proposed to provide additional evaluation information so that Teams could develop a full IEP; 3) the evaluation period did not exceed 8 weeks; and 4) the extended evaluation was not used as a placement. By May 3, 2014, submit a detailed report of the internal review, including the number of student records reviewed at each level & the number of records with extended evaluations that meet the 4 conditions described above. If non-compliance is identified, report the specific actions taken to correct each individual student file, identify and report the root cause(s) of the ongoing non-compliance and a plan to remedy it. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 20 Least restrictive program selected Partially Implemented Department CPR Findings: Student records and interviews indicate that students placed in the district's three substantially separate Language Cognitive Classrooms, located at the Silver Hills Charter School, do not have access to less restrictive settings for content-area classes. Students in these substantially separate classrooms are not permitted to access the charter school's general education core content instruction. Interviews indicate that at the elementary level, the program selected for students is not always the least restrictive environment. Special education students do not have access to specials, such as art, music, library, technology and gym, in the general education setting. Students with IEPs participate in these classes in substantially separate environments because the general education classes are crowded. Description of Corrective Action: Train all staff on the requirements of LRE, complete program review and equitability, gather data, develop subcommittee to ensure equitability to access the general curriculum in the LRE exist in all schools throughout the district. Hire and train appropriate level of staff to ensure access to "specials" is available to all students. Topic to be included in ETF meetings/ file reviews. Title/Role(s) of Responsible Persons: Expected Date of District and school administrators, ETFs, general and special Completion: education teachers 09/01/2014 Evidence of Completion of the Corrective Action: Students placed in substantially separate classes participate in art, music, physical education, library, technology to an appropriate extent as evidenced through IEP development. Description of Internal Monitoring Procedures: Quarterly review of Grid pages and progress reports of students placed in substantially separate classrooms through support staff in the special education office. Follow up report to be submitted quarterly. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 20 Least restrictive program selected Corrective Action Plan Status: Partially Approved Status Date: 01/22/2014 Basis for Status Decision: The district's proposed corrective actions address how elementary students will have access to specials. However, the district did not address how it will ensure that students in Silver Hill Charter School's substantially separate programs will have access to its less restrictive settings for content-area classes. Department Order of Corrective Action: Submit a plan that describes in detail how students placed in substantially separate classes at Silver Hill Charter School will have access to content area classes. Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures related to placements and ensuring Least Restrictive Environment for elementary students MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 13 in substantially separate programs, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. By March 3, 2014, submit evidence of the district’s corrective action implementation to ensure that Pawtucket Elementary students with disabilities have access to specials such as art, music, library, technology, and gym. Include documentation such as schedules, teachers? names and licensure data, and district follow-up reporting. By March 3, 2014, submit the district's detailed plan to ensure that all eligible students placed in substantially separate programs at Silver Hill charter school will have access to content area classes. Following implementation of all corrective actions, review the schedules of all Pawtucket Elementary students in substantially separate placements for evidence of their access to art, music, gym, technology, and library activities. Submit a detailed analysis of this review of schedules, including the number of student schedules reviewed, and the number of schedules demonstrating access to specials. For any evidence of non-compliance, please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the non-compliance. This analysis is due by May 3, 2014. Following implementation of all corrective actions, conduct a second review of all students placed in the substantially separate programs at Silver Hill Charter School. Review student schedules for evidence of access to general education content classes. Submit an analysis of this review to include the number of student schedules reviewed, and the number of instances found to be non-compliant. For any continued noncompliance, please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the noncompliance. This second analysis is due by May 3, 2014. *Please note that when monitoring, the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of the person(s) who conducted the review, their role(s), and their signatures. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 14 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 21 School day and school year requirements Partially Implemented Department CPR Findings: Student records, staff and parent interviews indicate that students placed in substantially separate programs at the high school are dismissed from school 20 minutes early every day, even though they do not have a modified schedule with a shortened school day indicated in their IEPs. Specialized transportation schedules impede access to a full school day and program of instruction for these students. Description of Corrective Action: Identify programs subject to transportation issue, identify number of instructional minutes missed due to transportation. Brainstorm ways of rectifying situation, analyze options and ways and means of ensuring equitable instructional time. Review with all schools, teachers, and transportation providers. Implement plan. Students who require a shortened day due to disability will have it appropriately identified on the IEP. Title/Role(s) of Responsible Persons: Expected Date of Special Education Director, Director of Transportation and Completion: Director of Support Services, ETFs 09/01/2014 Evidence of Completion of the Corrective Action: Students in substantially separate programs will participate in a school day and instructional minutes, mirroring that of the general population. Description of Internal Monitoring Procedures: Quarterly monitoring of bus schedules. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 21 School day and school year requirements Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's detailed plan for ensuring that specialized transportation for high school students placed in substantially separate programs does not decrease students? instructional time, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. By May 3, 2014, submit a detailed report on the implementation of the district’s plan to ensure that specialized transportation does not impact high school students? instructional time. Provide schedules for students in each sub-separate high school class, reporting on each student whose consented-to IEP indicates a shortened school day and/or indicating the student’s transportation schedule. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 15 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 22 IEP implementation and availability Partially Implemented Department CPR Findings: A review of student records and interviews indicate that at the middle and high school levels, the district does not always implement the IEPs of eligible students who have been suspended more than 10 days and who are placed on home tutoring for indefinite periods of time. See also SE 45. Description of Corrective Action: Training for administrators regarding roles and responsibilities, manifestations of disabilities in the school environment, implications of suspending students with disabilities and conducting manifestation meetings. Ensure Functional Behavioral Assessments are utilized to help staff and student understand the purpose of a targeted behavior, Train staff in appropriate support plans. Include administration in this training and program development. Title/Role(s) of Responsible Persons: Expected Date of School and district administrators, Behavioral Support Staff. Completion: 09/01/2014 Evidence of Completion of the Corrective Action: All students who exhibit a pattern of suspensions or receives a 10 day suspension will have a manifestation meeting conducted and documented. Students whose behavior is a manifestation of the disability will have a plan for support developed to increase students skills and decrease behavioral difficulties. No student will be placed on home tutoring for an indefinite period of time. Description of Internal Monitoring Procedures: Monthly report of incident and suspension reports completed at each school. Intermittent student reviews conducted through Aspen X2. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 22 IEP implementation and Approved availability Status Date: 01/22/2014 Basis for Status Decision: See Department basis for decision for SE 45. Department Order of Corrective Action: See Department order of corrective action for SE 45. Required Elements of Progress Report(s): See required elements of progress reporting for SE 45. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 16 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 25A Sending of copy of notice to Special Education Appeals Partially Implemented Department CPR Findings: A review of student records indicates that when a parent rejects a proposed placement, the district does not send a copy of the notice to Special Education Appeals within five calendar days. Description of Corrective Action: ETF training on increasing parent engagement in hopes of decreasing the number of rejected IEP and placements. Ensure all ETF understand the implications of a rejected IEP. Ensure policy on Rejected IEPs is distributed to all parties and posted in sped share and Google docs. Title/Role(s) of Responsible Persons: Expected Date of ETF's and special education support staff, school administrators, Completion: special education director. 09/01/2014 Evidence of Completion of the Corrective Action: A notice will be sent to the Special Education Appeals within 5 calendar days for all rejected placements. Description of Internal Monitoring Procedures: Weekly checks through Aspen X2 conducted by special education office support staff. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 25A Sending of copy of notice to Special Education Appeals Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures ensuring that, within 5 calendar days of receiving parental notice of a rejected IEP or placement or request for a hearing, the district sends a copy of the notice to the Bureau of Special Education Appeals, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. By May 3, 2014, following implementation of revised procedures and training, using the district’s X2 system, develop a sample of approximately 20 records from across the district's schools that indicate the parent has rejected or not signed the IEP or placement. Review the sample of records for evidence that the district has sent notice of the rejection to the BSEA within 5 calendar days. Submit the results of the internal review, including the number of student records reviewed at each level & the number of records that demonstrated the district sent notice to the BSEA. If non-compliance is identified, report the specific actions taken to correct each individual student file, identify and report the root cause(s) of the ongoing non-compliance and a plan to remedy it. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 17 *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 18 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 26 Parent participation in meetings Partially Implemented Department CPR Findings: Student records indicate that when parents are unable to attend IEP Team meetings or manifestation determination meetings, the district does not use alternative methods to ensure parent participation, such as through individual or conference telephone calls or video conferencing. Description of Corrective Action: Train staff in ways of increasing parent engagement and alternative ways to increase engagement. Ensure Aspen X2 parent contact information is accurate and updated regularly. Identify baseline of current parent participation. Advertise increase of parent participation for each school. Title/Role(s) of Responsible Persons: Expected Date of School administrators, ETFs, school clerical staff Completion: 11/06/2014 Evidence of Completion of the Corrective Action: Parent participation in IEP and placement meetings will increase by x% at each school. Description of Internal Monitoring Procedures: Monthly monitoring through Aspen X2 completed by special education clerical support staff. (added to monthly report) CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 26 Parent participation in meetings Corrective Action Plan Status: Approved Status Date: 01/22/2014 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures ensuring the participation of parents in IEP meetings, including methods of increasing parent participation and emphasizing use of phone conferencing as an alternative to rescheduling the meetings, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. Re-scheduling, phone conferencing, and proceeding without the parent should be documented in the IEP Team Summary and the N1 (Notice of Proposed District Action). By May 3, 2014, submit the results of a record review from a sample of 5 students from each grade level (preK, elementary, middle, high school, out-of-district) with Team meetings scheduled post-training for evidence of parent participation, either in person or via phone conferencing. Indicate the total number of records reviewed and the number of records that demonstrated that 1) IEP development Teams were re-scheduled and successfully included parent participation; or 2) parents were included in IEP development during the Team meeting via phone conferencing in lieu of re-scheduling the meeting. Provide an analysis of this review to include the number of records reviewed, and the number of records found to be non-compliant. For any records found to be non-compliant, MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 19 please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the non-compliance. * Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 20 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 34 Continuum of alternative services and placements Partially Implemented Department CPR Findings: Staff interviews confirm that the district does not ensure that a continuum of services and placements is available to meet the needs of all students with disabilities. Specifically, interviews indicate that at the middle and high school levels, the district does not have enough space in its alternative day programs and Team chairpersons are unable to propose placements in these programs for students with discipline issues or behavioral infractions. The district unilaterally places students on home tutoring for extended periods of time of up to six months or longer until space becomes available in an alternative day program. The district then proposes the IEP and placement to parents for that program. Description of Corrective Action: A survey of the current programs across the district have been surveyed, data collected and discussions held to develop plan for programs needs and potential developments. Information with be shared with a subgroup to provide advice and provide feedback on program development. Title/Role(s) of Responsible Persons: Expected Date of Administrators, teachers, psychologists, ETF, adjustment Completion: counselors, behavioral staff. 11/06/2014 Evidence of Completion of the Corrective Action: Appropriate programs are available across schools and grade levels. Continuum of services will be outlined, entrance and exit criteria will be established. No student is placed on home tutoring for extended periods of time. Description of Internal Monitoring Procedures: Development of continuum plan, and programs, review IEPs in accordance with exit and entrance criteria, and least restrictive environment. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 34 Continuum of alternative services Approved and placements Status Date: 01/22/2014 Basis for Status Decision: While the district noted that its policy has been revised to ensure that no student is placed on home tutoring for extended periods of time, the district must provide either a list of students still receiving home tutoring or provide its assurance that all students have since been placed in school programs. Department Order of Corrective Action: Provide a list of all middle and high school students receiving home tutoring in lieu of placement in the district's alternative programs or the district's assurance that all students have since been placed in school programs. Required Elements of Progress Report(s): By March 3, 2014, provide a list of all middle and high school students receiving home tutoring in lieu of placement in the district's alternative programs or provide the district's assurance that all students have since been placed in school programs appropriate for their IEPs and consented to by parents. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 21 By March 3, 2014, submit a narrative description of the updated procedures related to placement of middle and high school students in the district's behavioral/alternative placements, including entrance and exit criteria established for these programs, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. By March 3, 2014, submit the results from the district's internal review of student IEPs related to the alternative programs' exit and entrance criteria and least restrictive environment considerations, student programming needs identified by the district, and feedback from other groups on developing the district's continuum of placements for students with disciplinary and/or behavioral infractions. By May 3, 2014, submit the district's detailed plan for developing the district's continuum of supports for students with disciplinary and/or behavioral infractions, including timelines for implementation, identified staff, etc. Following implementation of revised procedures and training, conduct an internal record review of all middle and high school students referred to the alternative schools or other settings for evidence of appropriate IEPs and immediate placements implemented for these students. Submit a detailed analysis of the internal review, including the number of student records reviewed; the number of records with immediate & appropriate IEPs and placements; an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. This analysis is due May 3, 2014. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 22 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 36 IEP implementation, accountability and financial Partially Implemented responsibility Department CPR Findings: See SE 22. Description of Corrective Action: Training for administrators regarding roles and responsibilities, manifestations of disabilities in the school environment, implications of suspending students with disabilities and conducting manifestation meetings. Ensure Functional Behavioral Assessments are utilized to help staff and student understand the purpose of a targeted behavior, Train staff in appropriate support plans. Include administration in this training and program development. Ensure special education liaisons will have regular scheduled contact and documented contact with general education teachers to review students needs. Title/Role(s) of Responsible Persons: Expected Date of School administrators, ETFs, special education liaisons Completion: 11/06/2014 Evidence of Completion of the Corrective Action: All special education students will have an IEP and placement meeting in line with the students identified needs. Students whose behavior is a manifestation of the disability will have a plan for support developed to increase students skills and decrease behavioral difficulties. No student will be placed on home tutoring for an indefinite period of time. Description of Internal Monitoring Procedures: Monthly monitoring through Aspen X2 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 36 IEP implementation, accountability and financial responsibility Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): See progress reporting requirements for SE 22 and SE 45. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 23 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 43 Behavioral interventions Partially Implemented Department CPR Findings: A review of student records and interviews indicate that the district does not consistently conduct functional behavioral assessments or utilize positive behavioral interventions for students whose behavior impedes their learning or the learning of others. Description of Corrective Action: Train behavioral support staff in FBA and development of support plans. Identify and share resources for support staff throughout the district. Standardize FBA process, support plan development and inclusion of parents and appropriate personnel. Standardize incident reporting, behavioral reports and suspension reporting. Ensure students identified with behavioral difficulties have a positive support plan. Title/Role(s) of Responsible Persons: Expected Date of Administrators, special education teachers, behavioral support Completion: staff, adjustment counselors 11/06/2014 Evidence of Completion of the Corrective Action: All schools will utilize positive behavioral intervention for students whose behavior impedes their learning or the learning of others, Description of Internal Monitoring Procedures: Monthly report of incident and suspension reports completed at each school. Intermittent student reviews conducted through Aspen X2. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 43 Behavioral interventions Corrective Action Plan Status: Approved Status Date: 01/22/2014 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's detailed plan for ensuring that functional behavioral assessments and behavioral supports will be provided to eligible students, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. Following the implementation of all corrective actions, using the district’s monthly incident and suspension reports completed at each school, develop a sample of approximately 1520 students for record review to determine whether school personnel have developed appropriate behavioral supports for students showing a pattern of incidents, including FBAs, behavioral intervention plans, and other means of behavioral support. Submit a detailed analysis of this record review, including the number of records reviewed and the number of records found have evidence of behavioral supports. For any records found to be non-compliant, please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the non-compliance. This analysis is due by May 3, 2014. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 24 *Please note that when monitoring, the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of the person(s) who conducted the review, their role(s), and their signatures. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 25 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 44 Procedure for recording suspensions Partially Implemented Department CPR Findings: Student records, documentation and interviews indicate that while the district has designated Evaluation Team Leaders as responsible for conducting manifestation determinations, the recorded student suspension data is not available to them. As a result, Evaluation Team Leaders are not informed of when a student has been suspended longer than 10 consecutive days or a series of suspensions occurred that constitutes a pattern, but are shorter than 10 consecutive days; manifestation determinations are not consistently conducted when a suspension constitutes a change in placement. See SE 46. Description of Corrective Action: Train school clerical staff to gather incident and suspension reports form Aspen X2 and school administrators. Clerical staff will ensure this information is accurately logged into Aspen X2. (All ETFs have access to Aspen X2.) School based Monthly reports regarding incidents and suspensions shared with the special education office will also be shared with the ETF at each building. Title/Role(s) of Responsible Persons: Expected Date of School Clerical Support, ETF, School Administrators Completion: 11/06/2014 Evidence of Completion of the Corrective Action: All special education students who experience a series of suspensions or a 10 day suspension will have a manifestation meeting conducted and documented and a positive support plan will be developed as appropriate. Description of Internal Monitoring Procedures: Monthly reports. Intermittent reviews of student files. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 44 Procedure for recording suspensions Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures for ensuring that ETFs and other relevant special education staff have access to current special education student suspension data, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. Progress Report Due Date(s): 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 26 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 45 Procedures for suspension up to 10 days and after 10 Partially Implemented days: General requirements Department CPR Findings: Student records indicate that when a student has been suspended beyond 10 days in a school year, the district does not always provide the services indicated on the consentedto IEP for the student to continue to receive a free and appropriate public education. Description of Corrective Action: Given the standard monitoring of suspension those students in need of additional supportive services or procedural safeguards to receive FAPE will be identified through the team meetings and manifestations determination meetings. Supportive plans and services will be developed and documented. Plans will be reviewed with progress reports or sooner depending on the need. Title/Role(s) of Responsible Persons: Expected Date of School Administrators, special education liaisons, ETF, Completion: counselors, special education director 11/06/2014 Evidence of Completion of the Corrective Action: Decrease in suspension rates for students with disabilities. Description of Internal Monitoring Procedures: Monthly reports of incident and suspension. Intermittent record review of students with behavioral difficulties. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 45 Procedures for suspension up to Approved 10 days and after 10 days: General Status Date: 01/22/2014 requirements Basis for Status Decision: The district's proposed corrective action does not include the development of procedures for ensuring and providing consented-to related services and FAPE for students who are removed from school for extended periods of time due to infractions involving possession of drugs, weapons, and assault or felony charges as per MGL 71 37H 1/2 and placed in Interim Alternative Education Settings (IAES). Department Order of Corrective Action: Develop specific procedures for ensuring FAPE to students with disabilities who are excluded from school for infractions involving drugs, weapons, physical assault or felony charges for periods of time beyond 10 days. Required Elements of Progress Report(s): By March 3, 2014, submit district procedures for ensuring provision of FAPE for students removed from school for infractions involving drugs, weapons, physical assault or felony charges, along with evidence of staff training that includes relevant special education staff and principals. This evidence includes, but is not limited to, signed attendance sheets, training agendas, and examples of training materials. By May 3, 2014, conduct an internal review of students currently in IAES or long-term home tutoring for evidence that students are receiving FAPE and all consented-to services. Submit a detailed analysis that includes the number of student in home tutoring MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 27 and/or IAES for infractions involving drugs, weapons, physical assault or felony charges, who are receiving FAPE & consented-to services AND the number of students in long-term exclusions (e.g., beyond 10 days) for non-37H1/2 issues. For any records found to be non-compliant, please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the non-compliance. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 28 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 46 Procedures for suspension of students with disabilities Partially Implemented when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Department CPR Findings: Student records indicate that the district does not implement required procedures when a suspension or pattern of suspensions exceeds 10 days. Specifically, the district does not consistently conduct a manifestation determination when there is a change in placement, such as when a student is suspended longer than 10 consecutive days or when the student has a series of suspensions that are shorter than 10 consecutive days but constitutes a pattern. In addition, the district routinely places students in interim alternative educational settings for over 45 days for behaviors that do not involve weapons, drugs, or the infliction of serious bodily injury. Description of Corrective Action: Given the standard monitoring of suspension those students in need of additional supportive services or procedural safeguards to receive FAPE will be identified through the team meetings and manifestations determination meetings. Supportive plans and services will be developed and documented. Plans will be reviewed with progress reports or sooner depending on the need. Train staff on the use appropriate use of alternative 45 day placements. Title/Role(s) of Responsible Persons: Expected Date of School Administrators, special education liaisons, ETF, Completion: counselors, special education director 11/06/2014 Evidence of Completion of the Corrective Action: Decrease in school suspensions. Only those students who exhibit behaviors involving drugs, weapons or inflict serious bodily injury will be in alternative 45 days placements. Description of Internal Monitoring Procedures: -Monthly incident and suspension reports. Team meeting and file review of students placed in 45 day settings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 46 Procedures for suspension of Approved students with disabilities when Status Date: 01/22/2014 suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Basis for Status Decision: The district's corrective action does not including training administrators, principals, and staff on the requirements of conducting manifestation determinations and required procedures when a suspension or pattern of suspensions exceeds 10 days or the requirements for placing students into interim alternative educational settings. Department Order of Corrective Action: The district will train all administrators, Team chairs and applicable staff on the requirements and procedures for conducting manifestation determinations and the MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 29 appropriate use of placement into interim alternative educational settings. Required Elements of Progress Report(s): By March 3, 2014, submit evidence of staff training that includes relevant staff, administrators, and principals on the requirements for conducting manifestation determinations when a suspension or pattern of suspensions exceeds 10 days and the requirements for placing student in IAES settings. This evidence includes, but is not limited to, signed attendance sheets, training agendas, and examples of training materials. By May 3, 2014, conduct an internal record review following the implementation of all corrective actions. Using the district's Aspen X2 database and monthly incident/suspension reports, review the records of all students for evidence that 1) manifestation determinations were conducted for students who received a suspension that exceeds 10 days or had pattern of suspensions that exceeds 10 days; and 2) student who are placed in IAES settings (e.g., 45 days or longer) had infractions involving possession of drugs, weapons, and assault or felony charges. For any records found to be noncompliant, please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the non-compliance. This analysis is due by May 3, 2014. Upon completion of the district’s corrective action activities, the Department will conduct an onsite review of student records. This onsite visit will be scheduled during the 20132014 school year. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels 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): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 30 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 48 FAPE (Free, appropriate, public education): Equal Partially Implemented opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education Department CPR Findings: Student records and interviews indicate that special education students at Pawtucket Lake Elementary School do not have an opportunity to participate in specials, such as music, library, technology and gym. Description of Corrective Action: Train all staff on the requirements of Free and Appropriate Public Education. Complete program review and equitability, gather data, develop subcommittee to ensure equitability to access the general curriculum in the LRE exist in all schools throughout the district. Hire and train appropriate level of staff to ensure access to "specials" is available to all students. Topic to be included in ETF meetings/ file reviews. Title/Role(s) of Responsible Persons: Expected Date of District and school administrators. Completion: 09/01/2014 Evidence of Completion of the Corrective Action: Students placed in substantially separate classes participate in art, music, physical education, library, technology to an appropriate extent as evidenced through IEP development. Description of Internal Monitoring Procedures: Review of student and teacher schedules through Aspen X2. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 48 FAPE (Free, appropriate, public education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): See progress reporting requirements for Pawtucket Elementary students' access to music, art, gym, technology, and library classes described in SE 20. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 31 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 49 Related services Partially Implemented Department CPR Findings: See SE 22. Description of Corrective Action: Training for administrators regarding roles and responsibilities, manifestations of disabilities in the school environment, implications of suspending students with disabilities and conducting manifestation meetings. Ensure Functional Behavioral Assessments are utilized to help staff and student understand the purpose of a targeted behavior, Train staff in appropriate support plans. Include administration and related support staff in this training and program development. Title/Role(s) of Responsible Persons: Expected Date of administrators, related service providers, ETFs Completion: 11/06/2014 Evidence of Completion of the Corrective Action: All students who exhibit a pattern of suspensions or receives a 10 day suspension will have a manifestation meeting conducted and documented. Students whose behavior is a manifestation of the disability will have a plan for support developed to increase students skills and decrease behavioral difficulties. No student will be placed on home tutoring for an indefinite period of time. Description of Internal Monitoring Procedures: Monthly report of incident and suspension reports completed at each school. Intermittent student reviews conducted through Aspen X2. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 49 Related services Corrective Action Plan Status: Approved Status Date: 01/22/2014 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): See progress reporting requirements for SE 22 & SE 45. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 32 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 51 Appropriate special education teacher licensure Partially Implemented Department CPR Findings: A review of documentation indicates that several special education teachers throughout all grade levels are not appropriately licensed. Description of Corrective Action: Review personnel records of all special education staff. Determine if each is working in field of certification. Develop plan and timeline for staff to obtain appropriate certification. Title/Role(s) of Responsible Persons: Expected Date of District and School administrators Completion: 09/01/2014 Evidence of Completion of the Corrective Action: All special education staff are appropriately certified through the MASS DESE. Description of Internal Monitoring Procedures: Review identified staff through DESE online records. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 51 Appropriate special education teacher licensure Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, upon reviewing district personnel files, provide a complete list of all special education teachers who are not appropriately licensed for their grade level or assignment. Also due on March 3, 2014, submit a detailed plan to ensure that appropriately licensed or waivered special education teachers are providing services. Include specific actions for each individual, along with timelines for implementation. In addition, if the district hires new personnel, provide that individual's name, role, title, and license information. Progress Report Due Date(s): 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 33 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 52 Appropriate certifications/licenses or other credentials -Partially Implemented related service providers Department CPR Findings: A review of documentation indicates that several related service providers, including social workers, guidance counselors, speech language pathologists, adaptive physical education teachers, nurses, occupational therapists and board certified behavior analysts, are not appropriately certified, licensed or board-registered, as appropriate. Description of Corrective Action: Review personnel records of all related service providers. Determine if each is working in field of certification. Develop plan and timeline for staff to obtain appropriate certification. Title/Role(s) of Responsible Persons: Expected Date of School and District Administrators Completion: 09/01/2014 Evidence of Completion of the Corrective Action: All related service providers are appropriately licensed and certified through appropriate licensing agency and the MASS DESE . Description of Internal Monitoring Procedures: Review identified staff through DESE online records. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 52 Appropriate certifications/licenses or other credentials -- related service providers Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, upon reviewing district personnel files, provide a complete list of all related service providers, including social workers, guidance counselors, speech language pathologists, adaptive physical education teachers, nurses, occupational therapists and board certified behavior analysts, who are not appropriately certified, licensed or boardregistered, as appropriate. Also due on March 3, 2014, submit a detailed plan to ensure that appropriately licensed related service personnel are providing services. Include specific actions for each individual, along with timelines for implementation. In addition, if the district hires new personnel, provide that individual's name, role, title, and license or certification information. Progress Report Due Date(s): 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 34 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 53 Use of paraprofessionals Partially Implemented Department CPR Findings: Interviews report that paraprofessionals are not always supervised by a licensed and certified professional who is proximate and readily available to provide such supervision. Description of Corrective Action: Provide training to all on roles and responsibilities for each member of the team. Train teachers and ESPs on models of teaching, teaming, lesson plan development (including the tasks and responsibilities of all adults in the classroom)Ensure schedule of supervision for ESP are in place and followed. Title/Role(s) of Responsible Persons: Expected Date of School administrators, ETF, special education teachers, Completion: educational support personnel (ESP) 11/06/2014 Evidence of Completion of the Corrective Action: All instruction special education ESP are supervised by the appropriate licensed and certified professional. Description of Internal Monitoring Procedures: Supervision schedules and intermittent lesson plan reviews. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 53 Use of paraprofessionals Corrective Action Plan Status: Approved Status Date: 01/22/2014 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures ensuring that paraprofessionals are always supervised by a licensed and certified professional who is proximate and readily available to provide such supervision, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. By March 3, 2014, submit a sample of supervision schedules for paraprofessionals to demonstrate the proximity of licensed and/or certified professionals available to provide supervision. Progress Report Due Date(s): 03/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 35 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 3 Access to a full range of education programs Partially Implemented Department CPR Findings: See SE 20. Description of Corrective Action: Review of student access to programs, advertising of academic, occupational and vocational programs through step up, student (and family) school tours, web pages, news tweets, etc. Career and Interest inventories will be completed on each students in grade 8 or higher. Student support programs through guidance, adjustment counselors, athletics, and dropout prevention programs are available to all students. Identify gaps in programming and develop or adjust offerings where necessary. Title/Role(s) of Responsible Persons: Expected Date of District and School Administrators, Guidance, ETFs Completion: 11/06/2014 Evidence of Completion of the Corrective Action: All students participate in interest inventories and meet with guidance prior to reaching high school. Description of Internal Monitoring Procedures: Semester review teacher and student schedules through Aspen X2. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 3 Access to a full range of education programs Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): See progress reporting requirements for SE 20. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 36 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7A School year schedules Partially Implemented Department CPR Findings: See SE 21. Description of Corrective Action: Identify programs subject to transportation issue, identify number of instructional minutes missed due to transportation. Brainstorm ways of rectifying situation, analyze options and ways and means of ensuring equitable instructional time. Review with all schools, teachers, and transportation providers. Implement plan. Students who require a shortened day due to disability will have it appropriately identified on the IEP. Title/Role(s) of Responsible Persons: Expected Date of Special Ed. Director, Director of Transportation and Director of Completion: Support Services, ETFs, Guidance 11/06/2014 Evidence of Completion of the Corrective Action: All students elementary school students will have 900 hours of structured learning time unless otherwise specified on IEP or 504 plans. All secondary students will receive 990 hours of structured learning time unless otherwise specified on IEP or 504 plans. Description of Internal Monitoring Procedures: School calendar, bus schedules, and selected students schedules will be reviewed each semester. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 7A School year schedules Corrective Action Plan Status: Approved Status Date: 01/22/2014 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): See progress reporting requirements for SE 21. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 37 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 18 Responsibilities of the school principal Partially Implemented Department CPR Findings: A review of student records indicates that when a student is referred for an evaluation to determine eligibility for special education, the principal does not ensure that documentation on the use of instructional supports, such as remedial instruction, Student Assistance Team interventions or response to intervention supports, is provided as part of the evaluation information reviewed by the Team when determining eligibility. Description of Corrective Action: Annually train all school administrators of roles and responsibilities regarding Student and Teacher Assistance Teams ADA and IDEA requirements. Share intervention strategies and resources among school teams. Standardize and distribute STAT procedures along with 504 and IDEA referral process and eligibility requirements. Follow up at leadership meetings. Title/Role(s) of Responsible Persons: Expected Date of School and District administrators Completion: 11/06/2014 Evidence of Completion of the Corrective Action: All schools will have regularly scheduled STAT teams utilizing a standardized process to ensure equitability. Description of Internal Monitoring Procedures: Training sign in sheets, leadership meeting agendas. observation of STAT meetings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 18 Responsibilities of the school principal Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 01/22/2014 Department Order of Corrective Action: Required Elements of Progress Report(s): By March 3, 2014, submit a narrative description of the district's revised procedures ensuring that documentation on the use of instructional supports, such as remedial instruction, Student Assistance Team interventions or response to intervention supports, is placed in student files and available as part of the evaluation information reviewed by Teams when determining eligibility, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, signed attendance sheet and copies of the materials presented. Following implementation of all corrective actions, develop an appropriate sample of at least 5 students per level (elementary, middle, HS) who were referred for determination of eligibility for special education services after receiving instructional support and STAT reviews. Review their records for evidence of documentation on the use of instructional supports, such as remedial instruction, Student Assistance Team interventions or response to intervention supports. Submit a detailed analysis of this internal review, including the number of records reviewed and the number of records found to contain MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 38 evidence of instructional support. For any records found to be non-compliant, please provide an analysis of the root cause(s) and any steps that the district has taken to remedy the non-compliance. This analysis is due by May 3, 2014. Progress Report Due Date(s): 03/03/2014 05/03/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 39 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Haverhill Public School District Corrective Action Plan Forms Program Area: English Learner Education Prepared by: MARY MALONE/ASSISTANT SUPERINTENDENT CAP Form will expand to as many lines as necessary. Before completing and emailing to pqacap@doe.mass.edu, please see separate Instructions for Completing Corrective Action Plans. All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report to the school or district. Mandatory One-Year Compliance Date: April 21, 2015 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 40 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 18 Records of ELL Students Department CPR Finding: A review of student records and staff interviews indicate that the district does not issue progress reports to parents of English learner education students. Narrative Description of Corrective Action: The HPS has always issued progress reports to all students. Last year it was brought to our attention that we needed a separate progress report for ELLs. We developed a progress report that is specific to ELL Language Development and is issued to all ELLs according to the same progress report distribution schedule as all other students. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent, ELE Corrective Action Activity: Corrected in Director, Principals 2012-2013-Progress Reports were sent out to all ELLs in the 2012-2013 school year. Evidence of Completion of the Corrective Action: Yes Description of Internal Monitoring Procedures ELE Director and Building Principals observe the distribution of progress reports to ELLS. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 18 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 41 Required Elements of Progress Report(s): Provide a blank copy of the ELL progress report. Submit evidence of ELL staff training on the development and distribution of ELL progress reports, including signed attendance sheets (with name and title) and agenda. This progress report is due September 5, 2014. The district will conduct an internal review of 20 ELE student records, representing a crosssection of the district’s schools, for evidence of ELL progress reports, translated as needed. Provide a summary of the record review, including the total number of records reviewed, the number of records found in compliance and the number of any records identified for noncompliance. If continued noncompliance was identified, please determine a root cause of noncompliance and indicate the corrective action to address such noncompliance. Please submit the results of the review by December 1, 2014. *Please note 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 levels for the records reviewed; b) Date of the review; c) Name of the person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): September 5, 2014; December 1, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Haverhill CPR Corrective Action Plan 42