MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Holyoke 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 03/20/2013. Mandatory One-Year Compliance Date: 03/20/2014 Summary of Required Corrective Action Plans in this Report Criterion SE 2 Criterion Title Required and optional assessments SE 3 SE 4 Special requirements for determination of specific learning disability Reports of assessment results SE 6 Determination of transition services SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority IEP Team composition and attendance SE 8 SE 9 Timeline for determination of eligibility and provision of documentation to parent CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 10 Criterion Title End of school year evaluations SE 12 Frequency of re-evaluation SE 13 Progress Reports and content SE 14 Review and revision of IEPs SE 18A IEP development and content SE 18B Determination of placement; provision of IEP to parent SE 20 Least restrictive program selected SE 24 SE 25 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Parental consent SE 27 Content of Team meeting notice to parents SE 29 Communications are in English and primary language of home Continuum of alternative services and placements SE 34 SE 37 SE 40 SE 41 SE 46 Procedures for approved and unapproved out-of-district placements Instructional grouping requirements for students aged five and older Age span requirements SE 51 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 Appropriate special education teacher licensure SE 54 Professional development 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 Partially Implemented Partially Implemented Criterion SE 55 Criterion Title Special education facilities and classrooms CR 3 Access to a full range of education programs CR 7 Information to be translated into languages other than English Accessibility of extracurricular activities CR 8 CR 9 CR 10 Hiring and employment practices of prospective employers of students Anti-Hazing Reports CR 10A Student handbooks and codes of conduct CR 11A Designation of coordinator(s); grievance procedures CR 12A CR 18 Annual and continuous notification concerning nondiscrimination and coordinators Counseling and counseling materials free from bias and stereotypes Non-discriminatory administration of scholarships, prizes and awards Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion Use of physical restraint on any student enrolled in a publicly-funded education program Responsibilities of the school principal CR 20 Staff training on confidentiality of student records CR 21 Staff training regarding civil rights responsibilities CR 23 Comparability of facilities CR 24 Curriculum review CR 25 Institutional self-evaluation CR 26A Confidentiality and student records CR 14 CR 15 CR 16 CR 17A 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 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: Student records and staff interviews indicated that the district does not consistently provide educational assessments, including a history of the student's educational progress in the general curriculum and teacher assessment that addresses attention skills, participation behaviors, communication skills, memory and social relations with groups, peers and adults. Student records also indicated that in some cases, the district did not complete consented-to assessments in the area of suspected disability. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 02 Required and Optional Assessments. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion #2. By 01MAR14, review 1 completed evaluation IEP from each team leader (13) for inclusion of an educational assessment and completion of consented to assessments. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/20/2014 Evidence of Completion of the Corrective Action: Updated Special Education Handbook documents - SE 02 Required and Optional Assessments, SE 22 Generation of Draft and Completed IEPs, SE 22 SpEd Admin Review and Mailing of Completed IEPs to the Parent/Guardian, and PD attendance sheet(s) for all personnel identified in the Description Section. Review data for each submitted evaluation IEP packet. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 02 and SE 22, and complete review of 13 submitted evaluation IEP packets. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 2 Required and optional assessments Corrective Action Plan Status: Partially Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: The district's proposal does not describe a method to internally track receipt of consent forms and the completion of all assessments indicated on the consent form on an ongoing basis. Department Order of Corrective Action: Establish a method to track receipt of consent forms and the completion of all assessments indicated on the consent form. Please note increased sample size for each Team Leader for internal monitoring. Required Elements of Progress Report(s): The district will provide a narrative description of their new procedures related to the completion of Educational Assessment A and B forms 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. Please submit this to the Department on or before by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 4 Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of 3 student records for each Team Leader. Indicate the number of records reviewed, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 5 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 3 Special requirements for determination of specific learning Partially Implemented disability Department CPR Findings: Student records and staff interviews indicated that the district does not consistently complete the required written eligibility determination and the four components used to determine eligibility: Historic review and educational assessment (SLD 1), Area of concern and evaluation method (SLD 2), Exclusionary factors (SLD 3) and Observation (SLD 4) for students suspected of having a specific learning disability. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 03 Requirements for completion of SLD forms. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 03. By 01MAR14, review 1 submitted evaluation IEP from each team leader in which the student was found eligible due to an SLD. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/20/2014 Evidence of Completion of the Corrective Action: Updated document - SE 03 Requirements for completion of SLD forms, and PD attendance sheet(s) for all personnel identified in the Description Section, reviews of submitted evaluation IEPs in which the student was found eligible due to an SLD. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 03, and complete review of submitted evaluation IEPs from each team leader in which the student was found eligible due to an SLD. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 3 Special requirements for Approved determination of specific learning Status Date: 05/09/2013 disability Basis for Partial Approval or Disapproval: The district's proposal does not describe a method to internally track completion of SLD forms for a determination of SLD. Department Order of Corrective Action: Establish a method to internally track the completion of all components of the SLD eligibility process. Please note increased sample size for each Team Leader for internal monitoring. Required Elements of Progress Report(s): The district will provide a narrative description of their new procedures related to the completion of forms and the written determination for specific learning disabilities (SLD) form 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. Please submit this to the Department on or before by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 6 Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of three student records for completion of SLD forms from each Team Leader. Indicate the number of records reviewed, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 7 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 4 Reports of assessment results Partially Implemented Department CPR Findings: Student records and staff interviews indicated that assessment summaries do not always include the procedures employed or diagnostic impressions and do not provide details that identify the student's educational needs or offer explicit means of meeting the needs. Student records also indicated that the assessment summaries are not always available for parents two days prior to the Team meeting. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 04 Contents for Assessment Reports; send to each evaluator, a letter describing requirements of them to meet this criteria. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion #4. By 01MAR14, all related service provider supervisors or designees where no supervisor exists, shall review 1 completed assessment from each related service therapist/assessor to evaluate compliance with this criterion. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/20/2014 Evidence of Completion of the Corrective Action: Updated document - SE 04 Contents for Assessment Reports, and PD attendance sheet(s) for all personnel identified in the Description Section. A completed review of a completed assessment by each related service therapist/assessor. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 04, and collect and review each completed review. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 4 Reports of assessment results Corrective Action Plan Status: Partially Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: The district's proposal does not describe a method to internally track completion of assessment reports and the assessment summary availability if parents request them two days prior to the Team meeting. Note increased sample size from 1 record to 2 per individual. Department Order of Corrective Action: Establish an internal oversight and tracking system to ensure that assessment summaries contain all required content and are available two days prior to IEP meetings should parents request them. This internal oversight system will be an ongoing part of district practices. Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to content for assessment reports (procedures employed, diagnostic impressions, details on educational needs and a description of how to meet the needs), as well as availability of assessment summaries prior to Team Meetings along with evidence of staff training on MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 8 these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of two student records for each assessor for 1) content of assessment summaries and 2) their completion/availability 2 days prior to the date of the IEP meeting. Indicate the number of records reviewed, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 9 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 6 Determination of transition services Partially Implemented Department CPR Findings: Student records and staff interviews indicated that 14-year old students are not consistently invited to Team meetings. Student record review also demonstrated that Transition Planning Forms are not annually updated for all students of transition age. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 22 IEP Implementation and Availability. Prior to15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion #6, On 12APR 13, provide professional development by DDS personnel to team leaders on transition planning. By 01MAR14, review 1 submitted IEP, for a student age 14 or older, for each team leader working with students age 14 or older. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/20/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 22 IEP Implementation and Availability, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of each reviewed IEP for a student age 14 or older Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 22, and collect and evaluate each completed review. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 6 Determination of transition services Corrective Action Plan Status: Partially Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: The district's proposal does not describe a method to internally track the annual review of the TPF on an ongoing basis. Department Order of Corrective Action: Establish a method to internally track the completion and annual updating of the TPF on an ongoing basis. Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to inviting 14 year old students to IEP Team meetings and the process used to update Transition Planning Forms annually 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. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 10 Submit the results of an administrative review of student records for (a) invitation to the Team meeting and (b) annual updates to the Transition Planning Form. Indicate the number of records reviewed at each middle school and high school, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 11 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 7 Transfer of parental rights at age of majority and student Partially Implemented participation and consent at the age of majority Department CPR Findings: Student records and staff interviews indicated that notice informing parents of the transfer of educational decision-making rights from the parent/guardian to the student is not consistently provided one year prior to students turning 18 years of age. According to student record review, the district does not consistently implement procedures to obtain consent from students with educational decision-making rights to continue special education services. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 07 Transfer of Parental Rights. Prior to 15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion #7. By 01MAR14, review 1 submitted IEP, for a student age 17 or older, for each team leader working with students age 17 or older. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/01/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 07 Transfer of Parental Rights, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of each reviewed IEP for a student age 17 or older Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 07, and collect and evaluate each completed review. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 7 Transfer of parental rights at age of Approved majority and student participation and Status Date: 05/09/2013 consent at the age of majority Basis for Partial Approval or Disapproval: The district's proposal does not describe a method to internally track student's decisionmaking, thereby enabling the district's subsequent action. Department Order of Corrective Action: Establish a method to track the consent to continue IEP services if the student maintains decision making or completion of the form for shared or delegated decision making with the addition of signatures from the school representative and a witness. Please note increased sample size for internal monitoring. Required Elements of Progress Report(s): Provide a copy of the training agenda and sign-in sheet as evidence of high school staff training regarding notifying families one year prior to the student reaching age 18 of the transference of educational decision-making to the student upon attainment of age of majority. Also include in the training the district's responsibility to secure consent from the student for continued IEP services or consent that matches the decision making made by the student by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 12 Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Subsequent to the training on age of majority, submit the results of an administrative review of student records for age of majority. Indicate the number of records reviewed at each high school, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 13 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 8 IEP Team composition and attendance Partially Implemented Department CPR Findings: Student records indicated that required IEP Team members are not consistently excused with parental consent; in addition, there was no evidence of the required Team members providing written input to the parent and the IEP Team for the development of the IEP prior to the meeting. Required Team members who were not excused included both special and general education teachers. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 08 IEP Team Composition and Attendance. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special and general education teachers on the requirements of SE Criterion 08. By 01MAR14, review 1 submitted IEP from each team leader in which a required team member was not signed in on the attendance sheet. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 08 IEP Team Composition and Attendance, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews each submitted IEP in which a required team member was not signed in on the attendance sheet. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 08, and collect and evaluate each completed review. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 8 IEP Team composition and Approved attendance Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: The district's proposal does not describe a method to internally track excusal of required Team members on an ongoing basis. Department Order of Corrective Action: Establish a method to track excusal of required Team members in writing and submission of written input for development of the IEP in advance of the meeting. Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to the Team Meeting excusal process 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. Please submit this to the Department by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 14 Submit the results of an administrative review of student records for excusal of Team members. Indicate the number of records reviewed, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 15 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: According to student record review, the district does not consistently convene Team meetings within 45 school working days after receipt of parents' written consent to initial evaluations or re-evaluations. Staff interviews indicated that a shortage of school psychologists caused the delay in meeting timelines for eligibility determination. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 09 Timeline for determination of eligibility and provision of documentation to parent, and SE 12 Frequency of Re-evaluation. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 09. By 01MAR14, Collection of data for evaluation IEPs for the 2013/14 school year for compliance with this indicator. Notification of both the Superintendent and the Finance Director of the need for additional staff. Also, 1 School Psychologist has been added to the 2013-2014 budget plan. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 09 Timeline for determination of eligibility and provision of documentation to parent, and SE 12 Frequency of Re-evaluation, PD attendance sheet(s) for all personnel identified in the Description Section, and Collection of data for compliance with this indicator. Copy of notification of both the Superintendent and the Finance Director of the need for additional staff. Copy of line item added to the 2013-2014 budget plan. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD; review Special Education Handbook sections SE 09 Timeline for determination of eligibility and provision of documentation to parent, and SE 12 Frequency of Re-evaluation; on-going collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 9 Timeline for determination of Status Date: 05/09/2013 eligibility and provision of documentation to parent Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a detailed narrative description of the root cause(s) of the noncompliance and the steps the district has taken to address the issues related to the delays in convening initial and re-evaluation Team meetings within the 45 day timeline. Also, submit a description of the internal oversight and tracking system that identifies the person(s) responsible for MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 16 oversight of the timelines and the training provided to the persons responsible for oversight. Include the agenda, signed attendance sheets, indicating title/role of staff and the name and title of the presenter by October 17, 2013. Subsequent to the training, please conduct a review of student records for eligibility timelines. Select a sample of 5 student records for each level, e.g., the preschool, elementary, middle, high school and out of district placements with the most recent IEP activity either an initial evaluation to determine eligibility, or a reevaluation. Review the records to determine whether the 45 day timeline has been met. Submit the number of student records reviewed by school level, the number of records that complied with the requirements and for any record found in continued noncompliance, determine the root cause(s) of the noncompliance and provide the district's plan to remedy the identified noncompliance with this criterion by January 6, 2014. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department onsite upon request: a) List of student names, building names and grade levels of the records reviewed: b) the date of the review: c) Name(s) of the person(s) who conducted the review, their role(s) and their signature(s). Progress Report Due Date(s): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 17 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 10 End of school year evaluations Partially Implemented Department CPR Findings: Student records indicated that when consent for an evaluation is received between 30 and 45 school working days before the end of the school year, the district does not always ensure that a Team meeting is scheduled to enable the provision of a proposed IEP or a written finding of no eligibility no later than 14 days after the end of the school year. Description of Corrective Action: Prior to 01SEP13, update the district Special Education Handbook, SE 10 Consents Received at End of School Year. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special and general education teachers on the requirements of SE Criterion 10. By 01MAR14, Collection of data for every evaluation when consent for an evaluation is received between 30 and 45 school working days before the end of the school year IEP for the 2012/13 school year for compliance with this indicator. Notification of both the Superintendent and the Finance Director of the need for additional staff. Also, 1 School Psychologist has been added to the 2013-2014 budget plan. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/20/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 10 Consents Received at End of School Year, PD attendance sheet(s) for all personnel identified in the Description Section, and completed data collection for evaluation IEPs in which consent for an evaluation is received between 30 and 45 school working days before the end of the school year. Copy of notification of both the Superintendent and the Finance Director of the need for additional staff. Copy of line item added to the 2013-2014 budget plan. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 10 Consents Received at End of School Year, on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 10 End of school year evaluations Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to end of school year evaluations 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. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 18 person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for end of school year evaluations, Indicate the number of records reviewed, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 19 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 12 Frequency of re-evaluation Partially Implemented Department CPR Findings: Student records indicated that the district does not consistently conduct re-evaluations every three years. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 12 Frequency of reevaluation Guidelines, Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 12. By 01MAR14, Collection of data for every reevaluation IEP completed in the 2013/14 school year for compliance with this indicator. Notification of both the Superintendent and the Finance Director of the need for additional staff. Also, 1 School Psychologist has been added to the 2013-2014 budget plan. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 12 Frequency of re-evaluation Guidelines, PD attendance sheet(s) for all personnel identified in the Description Section, and collection of data for every reevaluation IEP completed in the 2013/14 school year for compliance with this indicator. Copy of notification of both the Superintendent and the Finance Director of the need for additional staff. Copy of line item added to the 2013-2014 budget plan. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 12 Frequency of re-evaluation Guidelines, on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 12 Frequency of re-evaluation Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to ensuring that re-evaluations are conducted every 3 years unless the parent and district agree it is not necessary. 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. Please submit this to the Department by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 20 Submit the results of an administrative review of student records for reevaluation to determine continued eligibility for special education. Indicate the number of records reviewed at each level (minimum 4 per preschool, elementary, middle, high and out-ofdistrict), the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 21 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 13 Progress Reports and content Partially Implemented Department CPR Findings: Student records indicated that the district does not consistently provide progress reports to parents as frequently as non-disabled students receive report cards (four times per year for secondary students, three times per year for elementary and middle school students and one time per year for preschoolers). The student records also indicated that not all progress reports provide information specific to the annual IEP goal. Record review also demonstrated that summaries of academic achievement and functional performance are not consistently developed for students who are graduating or whose eligibility terminates. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 13 Progress Reports and Content. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 13. By 01MAR14, each Building Principals will review 5 progress reports from each special education teacher in their school and complete a written report on progress report compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Dir of Sp Ed Completion: Adam Garand, Asst. Dir Sp Ed 03/10/2014 Building Principals Evidence of Completion of the Corrective Action: Updated document(s) - SE 13 Progress Reports and Content, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of progress reports. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 13 Progress Reports and Content, and collect and evaluate each building report. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 13 Progress Reports and content Corrective Action Plan Status: Partially Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Revised procedures do not specifically address ensuring that summaries of academic achievement and functional performance for students who graduate or age out of special education are provided in a timely fashion. Department Order of Corrective Action: Please ensure that the district's revised procedures for this criterion include the academic achievement and functional performance summaries. Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to progress reports and academic summaries for high school students 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. Please submit this to the MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 22 Department by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for frequency and content for progress reports. Indicate the number of records reviewed at each level (preschool, elementary, middle, high and out-of-district), the number found to be compliant, 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. Please submit this to the Department by January 6, 2014. For the summaries of academic achievement and functional performance, submit the results of a separate administrative review of student records for provision of the academic summary. Indicate the number of records reviewed for high school and out-ofdistrict aged-out and graduated students. Please include the number found to be compliant, 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. Please submit this to the Department by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 23 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: Student records and staff interviews indicated that annual IEP Team meetings are not consistently held on or before the anniversary date of the IEP. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 14 Review and Revision of the IEP. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 14. By 01MAR14, Collection of data for annual review IEPs completed in the 2013/14 school year for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 14 Review and Revision of the IEP, PD attendance sheet(s) for all personnel identified in the Description Section, and completed collection of data for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 14 Review and Revision of the IEP, and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Partially Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: The district has not proposed a root cause analysis to determine why annual IEP meetings are not held by the anniversary date of the IEP or developed an internal monitoring system to ensure ongoing compliance. Department Order of Corrective Action: Conduct a root cause analysis for IEP meeting dates beyond the anniversary date. Establish a tracking system to ensure staff are scheduling IEPs early enough to hold the IEP meeting prior to the anniversary date of the IEP. Required Elements of Progress Report(s): The district will provide a narrative description of the root cause analysis conducted on convening annual review Team meetings; update the procedures for holding annual IEP meetings consistent with the results of the root cause analysis; and train special education staff and related services staff on these updated procedures. Provide the root cause analysis description and evidence of training that includes attendance sheet, handouts and a sample of the tracking system by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 24 Submit the results of an administrative review of student records for convening annual review Team meetings. Indicate the number of records reviewed at each level (3 minimum for preschool, elementary, middle, high and out-of-district), the number found to be compliant, 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. Please submit this to the Department by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 25 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18A IEP development and content Partially Implemented Department CPR Findings: Student records indicated students on the autism spectrum and other students vulnerable to bullying, harassment and teasing do not consistently have IEPs that identify skills and proficiencies needed to avoid and respond to bullying, harassment and teasing. Document review also indicated that special education staff members had not yet been trained on how to document the services that build skills and proficiencies to address bullying, harassment and teasing for vulnerable students and students on the autism spectrum. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 18A IEP Development and Content. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 18A. By 01MAR14, review IEPs from the 2013/14 school year from each team leader for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 18A IEP Development and Content, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of IEPs from each team leader for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 18A IEP Development and Content, on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18A IEP development and content Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to documenting the consideration of vulnerability to bullying and the provision of skills and proficiencies to address or avoid bullying, harassment and teasing for students on the spectrum, students whose disability affects social skills development, and students identified as vulnerable to bullying. Additionally, the district will 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. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 26 implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for consideration of vulnerability to bullying and the documentation and provision of skills and proficiencies to address or avoid bullying, harassment and teasing. The district must include students on the spectrum in its record sample at each level. Indicate the number of records reviewed at each level (2 minimum preschool, elementary, middle, secondary and out-of-district), the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 27 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 indicated that following the development of the IEP, the district does not propose the IEP immediately or provide two copies of the proposed IEP and placement to the parent. In addition, students placed in an unapproved in-district day program do not have IEP placement decisions that reflect the setting in which services are being provided. Record review also demonstrated that translated IEPs are sometimes sent to the parent one to three months after the Team meeting, resulting in a delay in consent to new services. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 18B Determination of Placement; Provision of IEP to Parent, and SE 22 IEP Implementation and Availability. Prior to 15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion 18B. By 01MAR14, Collection of data for IEPs completed in the 2013/14 school year for compliance with this indicator. A translator has been added to the 2013-2014 budget plan. By the end of the 2012/13 school year, the unapproved in-district day program (CFE) will be closed. For the 2013/14 school year, students placed in the unapproved in-district day program will be placed into appropriate school settings. Title/Role(s) of responsible Persons: Expected Date of Holyoke School Committee Completion: Carol Hepworth, Dir of Sp Ed 03/10/2014 Adam Garand, Asst Dir of Sp Ed Evidence of Completion of the Corrective Action: Updated document(s) - SE 18B Determination of Placement; Provision of IEP to Parent, and SE 22 IEP Implementation and Availability; PD attendance sheet(s) for all personnel identified in the Description Section; and data for every IEP completed in the 2013/14 school year for compliance with this indicator. Copy of 2013/2014 budget plan. The unapproved in-district day program will be closed at the end of the 2012/13 school year, and for the 2013/14 school year, students placed in the unapproved in-district day program are placed into appropriate school settings. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 18B Determination of Placement; Provision of IEP to Parent, and SE 22 IEP Implementation and Availability; and on-going data collection for every IEP completed in the 2013/14 school year for compliance with this indicator. By end of 2012/13 school year, verify that the in-district day program is closed. By start of 2013/14 school year, verify students once placed in the unapproved in-district day program are placed into appropriate school settings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 18B Determination of placement; Approved provision of IEP to parent Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 28 The district has not addressed sending two copies of the IEP to families in its proposed corrective action. Department Order of Corrective Action: Please include the required provision of two copies of the proposed IEP to families in the revised district procedures and subsequent staff training. Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to providing parents with two IEP/placement copies within ten days. Provide the procedures for provision of a translated IEP to families who have had oral interpretation of the IEP during the Team meeting. 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. Please submit this to the Department on or before by October 17, 2013. For the students who had been placed at the unapproved in-district program, the district will provide a list of the students, evidence that IEP Teams were re-convened, and provide a copy of the placement page proposing their new placements by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for (1) immediate provision of two copies of the IEP and (2) oral interpretation of the IEP at the Team meeting and for the provision of the translated IEP within a reasonable period of time. Indicate the number of records reviewed at each middle school and high school, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 29 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 IEP Teams do not consistently and appropriately justify the student's removal from the general education classroom and state why the removal is considered critical to the student's program or the basis for the removal. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 20 Least Restrictive Program Selected. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 20. By 01MAR14, review IEPs from the 2013/14 school year from each team leader for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 20 Least Restrictive Program Selected, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of 3 IEPs from each team leader for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 20 Least Restrictive Program Selected , and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 20 Least restrictive program selected Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to a Team's justification for removing a student from the general education environment, 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. Please submit this to the Department by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for non-participation justification statements for the removal of students from the general education environment. Indicate the number of records reviewed at each level (preschool, MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 30 elementary, middle and high school), the number found to be compliant, 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. Please submit this to the Department by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 31 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 24 Notice to parent regarding proposal or refusal to initiate or Partially Implemented change the identification, evaluation, or educational placement of the child or the provision of FAPE Department CPR Findings: Student records and staff interviews indicated that the district does not consistently provide notice to propose an evaluation within five days of receipt of the referral. Student records also did not consistently contain the Notice of Proposed School District Action (N1) to propose the IEP and summarize the Team's decisions and considerations. Additionally, when this notice was present in the file, the following required information was not consistently included in the form: rejected options and the reason for the rejection, evaluation procedures, and other relevant factors for the school district's decisions. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 24 Notices to Parents, and SE 09 Timeline for determination of eligibility and provision of documentation to parent. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 24. By 01MAR14, review IEPs from the 2013/14 school year from each team leader for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 24 Notices to Parents, and SE 09 Timeline for determination of eligibility and provision of documentation to parent, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of IEPs from each team leader for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 24 Notices to Parents, and SE 09 Timeline for determination of eligibility and provision of documentation to parent, and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 24 Notice to parent regarding Status Date: 05/09/2013 proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of its updated procedures related to timely MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 32 sending of a consent form to parents for evaluations, including requests for evaluations from walk-ins, and IEPs as well as the notice for a finding of no eligibility, 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. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for referral and for notice of the proposal to act or refusal to act. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 33 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 25 Parental consent Partially Implemented Department CPR Findings: Student records and staff interviews indicated that when parents fail to provide consent or refuse to participate, the district does not consistently contact parents in a timely manner or document its attempts to secure consent. Some records with documentation showed that instead of using a variety of methods to obtain consent, written notice would be sent out multiple times. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 25A Sending of Copy of Notices to the BSEA. Prior to 15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion 25A. By 01MAR14, review a sample of student records from the 2013/14 school year from each team leader for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 25A Sending of Copy of Notices to the BSEA, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of student records for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 25A Sending of Copy of Notices to the BSEA, and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 25 Parental consent Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to securing consent for reevaluations and for IEPs 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. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of 20 student records for documenting effort and securing consent to reevaluations and for IEPs. Indicate the number of records MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 34 reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 35 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 27 Content of Team meeting notice to parents Partially Implemented Department CPR Findings: Student records indicated that the district uses a variation of the Meeting Invitation (N3) that does not include required information, specifically the persons invited to the IEP Team meeting and the purpose of the Team meeting. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 27 Content of Team Meeting Notice to Parents. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 27. By 01MAR14, review IEPs from the 2013/14 school year from each team leader for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 27 Content of Team Meeting Notice to Parents, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of IEPs from each team leader for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 27 Content of Team Meeting Notice to Parents, and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 27 Content of Team meeting notice to Status Date: 05/09/2013 parents Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to inviting parents/guardians to Team meetings as well as the attendance sheet so parents can see who will participate in the Team meeting, 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. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of 20 student records for Team meeting MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 36 invitation (N3). Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 37 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 29 Communications are in English and primary language of Partially Implemented home Department CPR Findings: Student records and staff interviews indicated that not all important special education documents, such as IEPs, notices, and assessment summaries, are translated in parents' primary languages. Record review demonstrated that it may take up to three months for parents to receive a translated IEP. Document review and interviews confirmed that the district does not have a system to document oral interpretation or translation. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 29 Communications are in English and Primary Language of Home. Prior to 15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion 29. By 01MAR14, review IEPs from the 2013/14 school year from each team leader for compliance with this indicator. An additional translator has been added to the budget. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 29 Communications are in English and Primary Language of Home, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of 1 IEP from each team leader for compliance with this indicator. Copy of budget. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 29 Communications are in English and Primary Language of Home, and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 29 Communications are in English and Approved primary language of home Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: The district's proposal does not describe a system to document oral interpretation or translation of all pertinent documents. Department Order of Corrective Action: Include in the procedures a system to document oral translations. Also include in the training other individuals who manage important documents that would require translation and the Principals for each building. Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to documenting translation and interpretation along with evidence of staff training, including principals, on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 38 Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of 20 student records for translation and documentation of oral translations. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 39 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 34 Continuum of alternative services and placements Partially Implemented Department CPR Findings: Documentation, student records and staff interviews indicated that the district is operating a public day program that has not been approved by the Department of Elementary and Secondary Education. The Center for Excellence is a program for special education students with behavior or emotional needs, located in a building separate from other grade-level peers. Description of Corrective Action: By the end of the 2012/13 school year, the unapproved in-district day program (CFE) will be closed. For the 2013/14 school year, students placed in the unapproved in-district day program will be placed into appropriate school settings. Title/Role(s) of responsible Persons: Expected Date of School Committee Completion: Carol Hepworth, Dir of Sp Ed 03/10/2014 Adam Garand, Asst Dir of Sp Ed Evidence of Completion of the Corrective Action: The unapproved in-district day program will be closed at the end of the 2012/13 school year, and for the 2013/14 school year, students placed in the unapproved in-district day program are placed into appropriate school settings. Description of Internal Monitoring Procedures: By end of 2012/13 school year, verify that the in-district day program is closed. By start of 2013/14 school year, verify students once placed in the unapproved in-district day program are placed into appropriate school settings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 34 Continuum of alternative services Status Date: 05/09/2013 and placements Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a list of the students who were previously enrolled in The Center for Excellence, evidence of the IEP Team meeting and the placement page that indicates where each student will receive special education services by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 40 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: According to record review, out-of-district contracts do not consistently include all required content, such as a statement requiring that all substantive and procedural rights will be provided to students and the requirement to allow the placing district and the Department to conduct announced and unannounced visits. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 37 OOD. Prior to 15SEP13, review and revise out-of-district contract template for the 2013/13 school year leader for compliance with this indicator, and provide professional development to: out of district team leader on the requirements of SE Criterion 37. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Director of Special Education Completion: Adam Garand, Assistant Director of Special Education 03/10/2014 Evidence of Completion of the Corrective Action: Updated document(s) - SE 37 OOD, PD attendance sheet(s) for all personnel identified in the Description Section, and revised of out-of-district contract template for the 2013/13 school year. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 37 OOD, and collect and evaluate revised of out-of-district contract template for the 2013/13 school year. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 37 Procedures for approved and Status Date: 05/09/2013 unapproved out-of-district placements Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide the district's out-of-district contract that includes the updated content & language by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 41 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: Documentation, staff interviews and facilities observations indicated that instructional groupings do not conform to class size requirements for students aged five and older in the following programs: 1) Holyoke High School exceeds the required class size in Resource Room Block A, Block B, Block C, Block E, Block F, RISE program and two sessions of adaptive physical education (APE); 2) the Center For Excellence has one instructional group that exceeds class size requirements; and 3) the Peck School exceeds class size in two Functional Academic sessions and in the Visualizing/Verbalizing class. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 40 Student Groupings by Number of Students. Prior to 01SEP13, provide professional development to all building principals on the requirements of SE Criterion 40. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 40. Prior to 01NOV13, building principals will assess instructional group size for all instructional groups in their buildings and provide that information to the Director of Special Education. Title/Role(s) of responsible Persons: Expected Date of Building Principals Completion: Carol Hepworth, Dir Sp Ed 03/10/2014 Adam Garand, Asst Dir Sp Ed Evidence of Completion of the Corrective Action: Updated document(s) - SE 40 Student Groupings by Number of Students, PD attendance sheet(s) for all personnel identified in the Description Section, and completed assessment of all Instructional groups for the 2013/13 school year for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 40 Student Groupings by Number of Students , and collect and evaluate the completed assessment of all Instructional groups for the 2013/13 school year . CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 40 Instructional grouping Status Date: 05/09/2013 requirements for students aged five and older Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to instructional groupings for children over 5 years of age in classes for all IEP students, MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 42 along with evidence of staff training, including Principals, on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of instructional groupings for all levels (elementary, middle and secondary). Indicate the number of groups reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 43 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 41 Age span requirements Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that student age span exceeded 48 months without Departmental approval in the following schools and programs: 1) Holyoke High School Resource Room Block F and the RISE classroom; 2) Donahue School's RISE program and third grade math pull-out support; 3) Peck School's RISE K-4 and the RISE programs. Age-span data was incomplete for the Peck School's Functional Academic classes and the Sullivan School's Math Groups I and II. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 41 Age Span Requirements. Prior to 01SEP13, provide professional development to all building principals on the requirements of SE Criterion 41. Prior to 15SEP13, provide professional development to all: team leaders, related service provider supervisors, related service providers, and special education teachers on the requirements of SE Criterion 41. Prior to 01NOV13, building principals will assess age span requirements for all instructional groups in their buildings and provide that information to the Director of Special Education. Title/Role(s) of responsible Persons: Expected Date of Building Principals Completion: Carol Hepworth, Dir Sp Ed 03/10/2014 Adam Garand, Asst Dir Sp Ed Evidence of Completion of the Corrective Action: Updated document(s) - SE 41 Student Groupings by Age, PD attendance sheet(s) for all personnel identified in the Description Section, and completed assessment of all age span requirements for all instructional groups in their buildings. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 41 Student Groupings by Age, and collect and evaluate the completed assessment of age span requirements for all Instructional groups for the 2013/13 school year. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 41 Age span requirements Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to age span along with evidence of Principal and staff training on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 44 Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of special education classes or groups for age span. Indicate the number of groups reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 45 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 indicated that when a student is suspended for 10 consecutive or cumulative days, the student's behavioral plan is not consistently reviewed as part of the manifestation determination process. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 46 Discipline. Prior to 01SEP13, provide professional development to all: building principals Prior to 15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion 46. By 01MAR14, on-going review manifestation meeting forms for the 2013/14 school year, from each team leader for compliance with this indicator. Title/Role(s) of responsible Persons: Expected Date of Building Principals Completion: Carol Hepworth, Dir Sp Ed 03/10/2014 Adam Garand, Asst Dir Sp Ed Evidence of Completion of the Corrective Action: Updated document(s) - SE 46 Discipline, PD attendance sheet(s) for all personnel identified in the Description Section, and completed reviews of manifestation meeting forms for the 2013/14 school year from each team leader for compliance with this indicator. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 46 Discipline, and on-going data collection. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 46 Procedures for suspension of Status Date: 05/09/2013 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 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated procedures related to reviewing discipline support for special education and 504 students along with evidence of Principal and Team Leader training on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 46 Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of student records for manifestation determination meetings and forms. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 47 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 staff interviews indicated that students placed in the Center for Excellence do not have access to non-academic and extracurricular programs, such as athletics and recreational activities, which are available as part of the general education program for students in other district schools. Description of Corrective Action: By the end of the 2012/13 school year, the unapproved in-district day program (CFE) will be closed. For the 2013/14 school year, students placed in the unapproved in-district day program will be placed into appropriate school settings. Title/Role(s) of responsible Persons: Expected Date of School Committee Completion: Carol Hepworth, Dir of Sp Ed 03/10/2014 Adam Garand, Asst Dir of Sp Ed Evidence of Completion of the Corrective Action: The unapproved in-district day program will be closed at the end of the 2012/13 school year, and for the 2013/14 school year, students placed in the unapproved in-district day program are placed into appropriate school settings. Description of Internal Monitoring Procedures: By end of 2012/13 school year, verify that the in-district day program is closed. By start of 2013/14 school year, verify students once placed in the unapproved in-district day program are placed into appropriate school settings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 48 FAPE (Free, appropriate, public Status Date: 05/09/2013 education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a list of students who had been placed at The Center for Excellence and the current, consented to placement for each student by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 48 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 51 Appropriate special education teacher licensure Partially Implemented Department CPR Findings: Documentation indicated that the district employs four special education teachers who do not have current licensure or approved waivers. Description of Corrective Action: Prior to end of 2012/13 school year, identify special education teachers who do not have current licensure or approved waivers and notify them as such. Prior to start of 2013/14 school year, contact Human Resources to verify that all special education teachers have current licensure or approved waivers. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Dir of Sp Ed Completion: Adam Garand, Asst Dir of Sp Ed 03/10/2014 David Lawrence, Dir of HR Evidence of Completion of the Corrective Action: Written letter/email from Human Resources verifying that all special education teachers have current licensure or approved waivers. Description of Internal Monitoring Procedures: By start of 2013/14 school year, ensure that special education teachers are indentified and notified; ensure that Human Resources is notified; and ensure that prior to start of 2013/14 school year all special education teachers have current licensure or approved waivers. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 51 Appropriate special education Status Date: 05/09/2013 teacher licensure Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a narrative description of the process to ensure new hires have current licensure or an approved waiver and a description of how the tracking system is updated for current staff, including notifications for staff who are due for renewal by October 17, 2013. Submit the information for the four special education staff who did not have current licensure, approved waivers or notice of non-renewal for their teaching positions by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 49 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 54 Professional development Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district has not provided training on the required special education topics to all professional staff, including general educators, which includes state and federal special education requirements, local special education policies and procedures, analyzing and accommodating diverse student learning styles for inclusion of students, and collaboration methods among teachers and paraprofessional staff to accommodate all students with diverse learning styles in the regular education classroom. Description of Corrective Action: Prior to 01SEP13, Update the district Special Education Handbook, SE 54 Professional Development. Prior to 15SEP13, provide professional development to all: team leaders on the requirements of SE Criterion 14. Prior to 01NOV13, team leaders will provide professional development to all professional staff, including general educators, that fulfills the requirements of this indicator. Title/Role(s) of responsible Persons: Expected Date of Building Principals Completion: Carol Hepworth, Dir Sp Ed 03/10/2014 Adam Garand, Asst Dir Sp Ed Evidence of Completion of the Corrective Action: Updated document(s) - SE 54 Professional Development, PD attendance sheet(s) for all personnel identified in the Description Section. Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook sections SE 54 Professional Development. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 54 Professional development Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of the updated professional development along with evidence of staff training for all staff, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 50 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 55 Special education facilities and classrooms Partially Implemented Department CPR Findings: Facilities observations indicated the following: 1) Sullivan School has occupational therapy and physical therapy delivered in an open area that precludes privacy and confidentiality for students receiving these services; 2) At the Peck School, the K-2 RISE Autism classroom is located in a predominately middle school instructional area that does not facilitate the inclusion of these students with age-appropriate peers; 3) At the Donahue School, special education support services and speech and language services are conducted concurrently with other groups in an open space located between classrooms;4) Holyoke High School has a corridor of rooms in the basement where only specialized services such as special education are provided. Description of Corrective Action: By end of 2012/13 school year, notify the appropriate building principals, via written letter, of non-compliance issues so that they may take actions to ensure compliance by the start of the 2013-2014 school year. Site visit after corrective actions taken by principals. Obtain written assurance from appropriate building principals that areas of noncompliance have been rectified. Title/Role(s) of responsible Persons: Expected Date of Bldg Principals Completion: Carol Hepworth, Dir of Sp Ed 03/10/2014 Doug Arnold, Dir Stu Svcs Evidence of Completion of the Corrective Action: Written assurance from appropriate building principals that areas of noncompliance have been rectified. Description of Internal Monitoring Procedures: By 01MAR14, ensure letters to appropriate principals have been sent and received, site visit conducted, and written assurance from appropriate building principals received. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 55 Special education facilities and Status Date: 05/09/2013 classrooms Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide floor maps for Peck, Donahue and the high school and indicate the former and current locations of services that were found non-compliant by October 17, 2013. The Department will conduct an on-site to verify the location of services at Peck, Donahue and the high school before October 30, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 51 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: Documentation and staff interviews indicated that the students at the Center for Excellence do not have equal access to the full range of occupational/vocational education programs offered by the district. In addition, the district's documents and policies regarding access to a full range of education programs revealed that gender identity is not included as a protected category. Description of Corrective Action: The Center for Excellence will close at the end of the 2013 school year. The following statement will be added to all district policies and documents. All students, regardless of race, color, sex, gender identity, religion, national origin, sexual orientation, disability, or homelessness, have equal access to the general education program and the full range of any occupational/vocational education programs offered by the district. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Director of Special Education, Completion: Holyoke School Committee 06/25/2013 Evidence of Completion of the Corrective Action: School committee minutes. Directive to all departments and schools. Description of Internal Monitoring Procedures: Monthly audit of policies and documents. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 3 Access to a full range of education Status Date: 05/09/2013 programs Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide the list of students who were formerly enrolled in The Center for Excellence and indicate the current placement for each student by October 17, 2013. Provide evidence of dissemination and training for staff on the updated nondiscrimination statement with the added category of gender identity including a training agenda, attendance sheet and copies of the materials by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 52 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7 Information to be translated into languages other than Partially Implemented English Department CPR Findings: Documentation and staff interviews indicated that the district provides families who are low-incidence language speakers with Spanish translations, rather than the language of the home. Document review and interviews also demonstrated that the district does not have a system to document oral translations that are made for parents and students. Description of Corrective Action: Important information and documents, e.g. handbooks and codes of conduct, being distributed to parents will be translated into the language of the home; the district has established a system to document oral interpretation that assists parents/guardians with limited English skills, including those who speak low-incidence languages. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Director of English Language Completion: Learners. 03/20/2014 Evidence of Completion of the Corrective Action: Logs of oral translation. translation of documents Description of Internal Monitoring Procedures: Monitoring and audits of district documents. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 7 Information to be translated into Status Date: 05/09/2013 languages other than English Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Develop a system so that each building can identify any parent/guardian or student that requests or requires translation or interpretation of important documents. Also provide evidence of staff training on the procedures for translation and documentation of oral translations, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by October 17, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by October 17, 2013. Submit the results of an administrative review of translations for speakers of low incident languages. This review can include special education, ELE, or documents from student cumulative files. Indicate the number of files reviewed at each level, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 53 description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before by January 6, 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): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 54 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 8 Accessibility of extracurricular activities Partially Implemented Department CPR Findings: Documentation indicated that the district does not include the new protected class of gender identity in its documents and policies regarding accessibility of extracurricular activities. In addition, staff interviews and record review indicated that students enrolled in the district's Center for Excellence do not have access to the extracurricular activities or sports available to all other students. Description of Corrective Action: The Center for Excellence will close at the end of the 2013 school year. The following statement will be added to all district policies and documents. All students, regardless of race, color, sex, gender identity, religion, national origin, sexual orientation, disability, or homelessness, have equal access to the general education program and the full range of any occupational/vocational education programs offered by the district. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Director of Special Education, Completion: Holyoke School Committee 06/25/2013 Evidence of Completion of the Corrective Action: School committee minutes. Directive to all departments and schools. Description of Internal Monitoring Procedures: Monthly audit of policies and documents. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 8 Accessibility of extracurricular Status Date: 05/09/2013 activities Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Please see DESE requirements for CR 3. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 55 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 9 Hiring and employment practices of prospective employers Partially Implemented of students Department CPR Findings: Documentation and staff interviews indicated that the district does not require employers recruiting at the school to sign a statement that the employer complies with state and federal laws prohibiting discrimination. In addition, this employer statement does not include the new protected category of gender identity. Description of Corrective Action: The district will develop a form that employers recruiting at the school to sign that states that the employer complies with applicable federal and state laws prohibiting discrimination in hiring or employment practices and the statement specifically includes the following protected categories: race, color, national origin, sex, gender identity, handicap, religion and sexual orientation. The prospective employers to whom this criterion applies will include those participating in career days and work-study and apprenticeship training programs, as well as those offering cooperative work experiences. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Building Principals, Director of Completion: Human Resources. 03/20/2014 Evidence of Completion of the Corrective Action: Completed forms for all employers. Description of Internal Monitoring Procedures: List of employers and collection of forms. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 9 Hiring and employment practices of Status Date: 05/09/2013 prospective employers of students Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide the revised form for prospective student employers to sign by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 56 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 10 Anti-Hazing Reports Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district's anti-hazing disciplinary policy includes athletic groups, but not other district student groups and organizations, and unaffiliated student groups. Description of Corrective Action: Building Principal will insure that all district student groups and organizations, and unaffiliated student groups receive and have members read and sign district's anti-hazing policy. Director of Student Services will collect and file for district. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Building Principals Completion: 10/01/2013 Evidence of Completion of the Corrective Action: Submission of student groups' compliance documents. Description of Internal Monitoring Procedures: Review and audit one school per month. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 10 Anti-Hazing Reports Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a list of all student groups (affiliated and unaffiliated) at the high school and provide a sample of three different kinds of groups with the signature from the team leader that the anti-hazing policy was reviewed with the group by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 57 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 10A Student handbooks and codes of conduct Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district codes of contact do not include Section 504 in the discipline of students with disabilities. The student code of conduct does not cite M.G.L. c. 76, s.5 as required. The high school handbook and student code of conduct do not include gender identity as a protected category in its nondiscrimination statement. In addition, a review of the high school handbook and student code of conduct demonstrated that the procedure for accepting, investigating and resolving complaints alleging discrimination or harassment does not include the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. See also CR 11A. Description of Corrective Action: District Code of Conduct will include Section 504 in the discipline of students with disabilities. The code of conduct will cite M.G.L.c. 76, s.5 as required and will include the mandatory reference to gender identity. The following page will be added to the code of conduct and the high school handbook: Anti- Harassment Policy Harassment of students by other students will not be tolerated in the Holyoke Public Schools. This policy is in effect while students are on school grounds, School District property or property within the jurisdiction of the School District, school buses, or attending or engaging in school activities. Harassment prohibited by the District includes, but is not limited to, harassment on the basis of race, sex, creed, color, national origin, sexual orientation, gender identity, religion, marital status or disability. Students whose behavior is found to be in violation of this policy will be subject to disciplinary action up to and including suspension or expulsion. Harassment means conduct of a verbal or physical nature that is designed to embarrass, distress, agitate, disturb or trouble students when: # Submission to such conduct is made either explicitly or implicitly a term or condition of a student’s education or of a student’s participation in school programs or activities; # Submission to or rejection of such conduct by a student is used as the basis for decisions affecting the student, or; # Such conduct has the purpose or effect of unreasonably interfering with a student’s performance or creating an intimidating or hostile learning environment. Harassment as described above may include, but is not limited to: # Verbal, physical or written harassment or abuse; # Repeated remarks of a demeaning nature; # Implied or explicit threats concerning one’s grades, achievements, or other school matter. # Demeaning jokes, stories, or activities directed at the student. The District will promptly and reasonably investigate allegations of harassment. The Principal of each building will be responsible for handling all complaints by students alleging harassment. Retaliation against a student, because a student has filed a harassment complaint or assisted or participated in a harassment investigation or proceeding, is also prohibited. A student who is found to have retaliated against another in violation of this policy will be subject to disciplinary action up to and including suspension and expulsion. The Superintendent will develop administrative guidelines and procedures for the MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 58 implementation of this policy. Title/Role(s) of responsible Persons: Director of Student Services Expected Date of Completion: 03/20/2014 Evidence of Completion of the Corrective Action: Copy of Code of Conduct and High School Handbook Description of Internal Monitoring Procedures: Review and audit of disciplinary incidents CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 10A Student handbooks and codes of Status Date: 05/09/2013 conduct Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a copy of the Code of Conduct and the section(s) the school's procedure for accepting, investigating and resolving complaints alleging discrimination or harassment and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 59 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 11A Designation of coordinator(s); grievance procedures Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district's published information for Title IX and Section 504 coordinators lists only the Student Services Office and its phone number and address. In addition, the student handbook's grievance procedures do not specify how a complaint alleging discrimination based on sex or disability will be resolved promptly and equitably. Description of Corrective Action: The name of the Director will be published. The handbook will contain information on how the complaint will be resolved. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services Completion: 01/03/2014 Evidence of Completion of the Corrective Action: Copy of handbook with resolution statement. Description of Internal Monitoring Procedures: Review and audit of compliance monthly. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 11A Designation of coordinator(s); Status Date: 05/09/2013 grievance procedures Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide the revised handbooks by web link or WBMS upload by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 60 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 12A Annual and continuous notification concerning Partially Implemented nondiscrimination and coordinators Department CPR Findings: Documentation indicated that the district does not publish the office address and phone numbers of the persons designated as coordinators under Title IX and Section 504. In addition, document review indicated that the district's annual and continuous notification concerning nondiscrimination does not include gender identity as a protected category. Description of Corrective Action: Office address and phone numbers of persons designated as coordinators under Title IX and Section 504 will be published and includes on all documents produces by the district. Written materials and other media used to publicize a school will include a notice that the school does not discriminate on the basis of race, color, national origin, sex, gender identity, disability, religion, or sexual orientation. Title/Role(s) of responsible Persons: Expected Date of Director of Students Services Completion: 10/01/2013 Evidence of Completion of the Corrective Action: Written documents. Description of Internal Monitoring Procedures: Review and audit of written documents CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 12A Annual and continuous Status Date: 05/09/2013 notification concerning nondiscrimination and coordinators Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): See CR 3 and CR 11 A. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 61 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 14 Counseling and counseling materials free from bias and Partially Implemented stereotypes Department CPR Findings: Document review indicated that while the district has policies and procedures to ensure that counseling and counseling materials are free from bias and stereotypes, they do not include gender identity as one of the protected categories. Description of Corrective Action: Gender identity will be included as one of the protected categories to ensure that they are free from bias and stereotypes. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services Completion: 10/01/2013 Evidence of Completion of the Corrective Action: Submission of documents regarding counseling and counseling materials. Description of Internal Monitoring Procedures: Review of all documents to ensure gender identity is included. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 14 Counseling and counseling Status Date: 05/09/2013 materials free from bias and stereotypes Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): See CR 3 for the submission of documents that include the updated statement of nondiscrimination and assurance that staffs are trained on nondiscrimination. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 62 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 15 Non-discriminatory administration of scholarships, prizes Partially Implemented and awards Department CPR Findings: According to document review, the district's policies for the non-discriminatory administration of scholarships, prizes and awards do not include gender identity as a protected category. Description of Corrective Action: The district's policies for the non-discriminatory administration of scholarships, prizes and awards will include gender identity as a protected category. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services Completion: 10/01/2013 Evidence of Completion of the Corrective Action: Submission of Documents Description of Internal Monitoring Procedures: Regular review of all policy regarding scholarships, prizes and awards. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 15 Non-discriminatory administration Status Date: 05/09/2013 of scholarships, prizes and awards Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): See CR 3 for reporting requirements. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 63 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 16 Notice to students 16 or over leaving school without a Partially Implemented high school diploma, certificate of attainment, or certificate of completion Department CPR Findings: Documentation and staff interviews indicated that the written notice to students age 16 and over does not include an extension of the time for the meeting with a representative of the district. In addition, staff interviews indicated that the district does not send an annual written notice to former students who have not yet earned their competency determination and who have not transferred to another school. Description of Corrective Action: The district's notice will be revised to meet all regulatory requirements as noted in the CPR finding. In addition, the district will ensure that it sends a notice to former students who have not yet earned their competency determination explaining their options. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, High School Principals Completion: 10/01/2013 Evidence of Completion of the Corrective Action: Copy of letter for both high schools. Notification letter to all former students. Description of Internal Monitoring Procedures: Dropout survey documents will be sent the Director of Student Services for all students who dropout of school and will include letter sent to students and parents. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 16 Notice to students 16 or over Status Date: 05/09/2013 leaving school without a high school diploma, certificate of attainment, or certificate of completion Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a copy of the notice to students age 16 and over that includes an extension of time to meet with district representatives by October 17, 2013. Provide a copy of the notice for former students who have not reached competency or transferred to another school/program and a list of the students who will receive the notice by January 6, 2014. Progress Report Due Date(s): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 64 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 17A Use of physical restraint on any student enrolled in a Partially Implemented publicly-funded education program Department CPR Findings: Documentation and staff interviews indicated that the district has not provided annual training on physical restraint or provided staff with the names of resource persons who can administer physical restraints in each school building. Description of Corrective Action: The district will developed and implement staff training at least annually on the use of restraint consistent with regulatory requirements. Such training will occurs within the first month of each school year and, for employees hired after the school year begins, within a month of their employment. Each school will provide staff with the names of resource persons who can administer physical restraints in each school building. In buildings in which this not in place, provide professional development in administration of physical restraint. Title/Role(s) of responsible Persons: Expected Date of Asst Superintendent, Dir of Stu Svcs, Buld Principals, Dir HR Completion: 10/01/2013 Evidence of Completion of the Corrective Action: Provide a copy of the materials utilized and sign-in sheets for staff in attendance at the training. List of personnel in each school who are trained in the administration of physical restraint. Verify that one person in each building is trained in the administration of physical restraint. Description of Internal Monitoring Procedures: Provide a copy of the materials used and sign-in sheets for staff in attendance. Human Resources will keep a record of all staff trained. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 17A Use of physical restraint on any Status Date: 05/09/2013 student enrolled in a publicly-funded education program Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of overview trainings on physical restraint for staff within the first 30 days of school year that includes each school's signed attendance sheets and the names of resource persons for each building with current in-depth restraint training by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 65 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 18 Responsibilities of the school principal Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that instructional support teams do not function to propose instructional supports for students in Holyoke High School, Donahue School, Kelly School, McMahon School, Sullivan School and the Center for Excellence. In addition, record review and interviews demonstrated that students' instructional support documentation is not maintained in students' cumulative files. Description of Corrective Action: The district will redistribute the procedures and protocols for the IST (BBST), meet with the principals and chairs of these teams to ensure their function is to propose instructional supports for students. Training will be given by the Director of Students Services to new principals and BBST Chairs. These individual will train teachers. BBST chairs will ensure documentation is included in students' cumulative files. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education, Director of Student Services, Completion: Building Principals. 10/01/2013 Evidence of Completion of the Corrective Action: Documentation that building principals have received the procedures and protocols, have received training, and have trained building staff. Description of Internal Monitoring Procedures: Agendas and records and staff participation. Review and monitoring of cumulative files. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 18 Responsibilities of the school Status Date: 05/09/2013 principal Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of training for staff in the Holyoke High School, Donahue School, Kelly School, McMahon School, Sullivan School and Lawrence School on BBST procedures that includes but is not limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department by October 17, 2013. Conduct an administrative review of students who have been reviewed by the BBST to ensure that forms and paperwork related to BBST are filed in the cumulative files. Indicate the number of files reviewed at each school, the number found to be compliant, 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. Please submit this to the Department by January 6, 2014. Progress Report Due Date(s): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 66 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 20 Staff training on confidentiality of student records Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district does not currently provide training for school personnel on the confidentiality of student records. Description of Corrective Action: The Director of Students Services will train an Administer in each school building on the provisions of the Family Educational Rights and Privacy Act, M.G.L. c. 71, s. 34H, and 603 CMR 23.00 and on the importance of information privacy and confidentiality. Each principal will provide staff members in their building with the information by the first staff meeting of the year. Title/Role(s) of responsible Persons: Expected Date of Director of Students Services, Building Principals. Completion: 10/01/2013 Evidence of Completion of the Corrective Action: The district submits the agenda, handouts and attendance sheet with date, name and role of staff trained. Description of Internal Monitoring Procedures: The district submits the agenda, handouts and attendance sheet with date, name and role of staff trained. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 20 Staff training on confidentiality of Status Date: 05/09/2013 student records Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of training on Family Educational Rights and Privacy Act (FERPA) and state regulations for confidentiality of student records that includes but is not limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 67 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 21 Staff training regarding civil rights responsibilities Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district has not provided training on civil rights annually. Description of Corrective Action: The district will provides in-service training for all school personnel at least annually regarding civil rights responsibilities, including the prevention of discrimination and harassment on the basis of students? race, color, sex, gender identity, religion, national origin and sexual orientation and the appropriate methods for responding to it in the school setting. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services and the Assistant Superintendent. Completion: 11/30/2013 Evidence of Completion of the Corrective Action: The district submits the agenda, handouts and attendance sheet with date, name and role of staff trained. Description of Internal Monitoring Procedures: The district submits the agenda, handouts and attendance sheet with date, name and role of staff trained. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 21 Staff training regarding civil rights Status Date: 05/09/2013 responsibilities Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of training on civil rights responsibilities for all protected categories, including gender identity, that includes but is not limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 68 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 23 Comparability of facilities Partially Implemented Department CPR Findings: See SE 55. Description of Corrective Action: By end of 2012/13 school year, notify the appropriate building principals, via written letter, of non-compliance issues so that they may take actions to ensure compliance by the start of the 2013-2014 school year. Site visit after corrective actions taken by principals. Obtain written assurance from appropriate building principals that areas of noncompliance have been rectified. Title/Role(s) of responsible Persons: Expected Date of Bldg Principals Completion: Carol Hepworth, Dir of Sp Ed 03/10/2014 Doug Arnold, Dir Stu Svcs Evidence of Completion of the Corrective Action: Written assurance from appropriate building principals that areas of noncompliance have been rectified. Description of Internal Monitoring Procedures: By 01MAR14, ensure letters to appropriate principals have been sent and received, site visit conducted, and written assurance from appropriate building principals received. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 23 Comparability of facilities Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide the written assurance from principals for Holyoke High School, Peck School and Donahue School by October 17, 2013 as described in the district's proposed corrective action. See also SE 55. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 69 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 24 Curriculum review Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district does not have a system to ensure that individual teachers review all educational materials for simplistic and demeaning generalizations on the basis of race, color, sex, gender identity, religion, national origin and sexual orientation. Description of Corrective Action: For the 2013-2014 school year, principals will present CR Criterion #24 during a staff meeting to all staff prior to the end of the first term. As part of the opening day agenda for all staff for the 2013-2014 school year and future first teacher day openings, building principals will instruct all staff to review all curriculum materials used in classrooms throughout the year no matter what form of media used. The staffs are to review the curriculum for any demeaning generalizations, lacking intellectual merit on the basis of race, color, sex, religion, national origin, and sexual orientation and provide balance and context for any such stereotypes depicted in such materials. All professional staff will sign off on attending this staff meeting Materials will be monitored during administrative walkthroughs. Title/Role(s) of responsible Persons: Expected Date of Building Principals and Curriculum Directors. Completion: 02/01/2014 Evidence of Completion of the Corrective Action: The staff meeting agenda with the topic of Criterion #24, curriculum review, as well as the sign in sheet for the staff meeting at which this requirement was presented. Description of Internal Monitoring Procedures: Meeting agendas and walkthrough monitoring sheets CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 24 Curriculum review Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of training for staff on the review of educational materials for simplistic and demeaning generalizations on the basis of race, color, sex, gender identity, religion, national origin and sexual orientation that includes but is not limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 70 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that although the district does evaluate different areas of its programming, it does not annually evaluate all aspects of the K-12 program to ensure that all students regardless of race, color, sex, gender identity, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status have equal access to all programs. Description of Corrective Action: The district intends to develop a self-evaluation checklist/instrument and conduct a selfevaluation, and administer it to staff, to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, gender identity, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities. Title/Role(s) of responsible Persons: Expected Date of Curriculum Directors, Building Principals, Directors of Student Completion: Services and Special Education. 02/13/2014 Evidence of Completion of the Corrective Action: Submit a copy of the newly developed checklist/instrument developed to administer to staff to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, gender identity, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities by February 31, 2014. Submit a summary of the findings, including a description of any changes made based on those findings by May 1, 2014. Description of Internal Monitoring Procedures: Monthly review of all schools and programs. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Approved Status Date: 05/09/2013 Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide the checklist to ensure access to all programs by October 17, 2013. Submit the narrative summary of the implementation of the self-evaluation by January 6, 2014. Progress Report Due Date(s): 10/17/2013 01/06/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 71 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 26A Confidentiality and student records Partially Implemented Department CPR Findings: Student records and staff interviews indicated that the district does not maintain student records in accordance with state and federal requirements; specifically, the special education student records did not consistently contain a log of access. In addition, student records contained misfiled documentation containing personally identifiable information from other students. Description of Corrective Action: Prior to 01SEP13, update Special Education Handbook to address requirement of 603 CMR 23.00 Student Records. Prior to 15SEP13, provide professional development to all: team leaders, and special education clerks on the requirements of CR Criterion 26A. By 01MAR14, Team Leaders at each school and Clerks at central office will review special education records to ensure compliance with this criterion. Title/Role(s) of responsible Persons: Expected Date of Carol Hepworth, Dir of Sp Ed Completion: Adam Garand, Asst Dir of Sp Ed 03/10/2014 Doug Arnold, Dir Student Svcs Evidence of Completion of the Corrective Action: Updated Special Education Handbook to address requirement of 603 CMR 23.00 Student Records, PD attendance sheet(s) for all personnel identified in the Description Section, and review special education records at each school and at central office Description of Internal Monitoring Procedures: By 01MAR14, document completion of PD, review Special Education Handbook to include 603 CMR 23.00 Student Records, and collect and evaluate completed review of special education records . CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 26A Confidentiality and student Status Date: 05/09/2013 records Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of staff training that includes but is not limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department by October 17, 2013. Progress Report Due Date(s): 10/17/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 72 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW HOLYOKE PUBLIC SCHOOLS Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Holyoke Public Schools/Vida Zavala, Interim Director of English Language Education 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: January 8, 2015 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 Department CPR Finding: District documentation indicated that at the time of the review some level four and five students were not provided with direct ESL instruction. The documentation submitted by the district also stated that some level three, four and five students were only receiving ESL support in ELA classrooms instead of direct ESL instruction as described in Department guidelines. Since ESL support cannot be a substitute for ESL instruction and all ELL students should receive ESL instruction tailored to their English proficiency levels, the SEI program provided in the district is not consistent with G.L. c. 71A. Please see the “Transitional Guidance on Identification, Assessment, Placement, and Reclassification of English Language Learners August 2013” as found on http://www.doe.mass.edu/ell/guidance_laws.html Narrative Description of Corrective Action: In accordance the Department of Justice Settlement Agreement with the Holyoke Public Schools, as part of the SEI program of instruction, the district will schedule ELL students (levels 1-5) for their recommended hours of ESL instruction consistent with the MADESE Guidelines and as outlined in the DOJ Settlement Agreement (paragraph 27). The district is actively recruiting and hiring qualified teachers for ESL and SEI teaching positions who are bilingual (in English and Spanish), dually licensed in ESL and a core content area, and core content teachers dually licensed in ESL license or with SEI Endorsement. The district will also offer opportunities for core academic teachers to obtain an ESL license. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 73 Title/Role of Person(s) Responsible for Implementation: Director of ELE Expected Date of Completion for Each Corrective Action Activity: July 15, 2014 and annually thereafter as stipulated in the Department of Justice Settlement (expected to be finalized in Spring 2014). Evidence of Completion of the Corrective Action: On July 15 of every year, the district will be required to provide the DOJ with a detailed annual report including but not limited to the following: student information, SEI and ESL schedules including number of hours of ESL instruction, ESL model (push-in, pull-out, co-teach), and qualifications of SEI and ESL teachers. ESL teachers’ rosters and student schedules will be reviewed in the fall. Description of Internal Monitoring Procedures: In accordance with the DOJ Settlement Agreement, on July 15 of every year, the district will provide the DOJ with a detailed annual report including but not limited to the following: student information, SEI and ESL schedules including number of hours of ESL instruction, and qualifications of SEI and ESL teachers. ESL teachers’ rosters and student schedules will be reviewed in the fall. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Program Placement and Structure Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): 1) Please provide a detailed plan that shows that the district is providing sufficient ESL instruction to all ELL students during the 2013-2014 school year based on the Department's Transitional Guidance on Identification, Assessment, Placement, and Reclassification of English Language Learners found at http://www.doe.mass.edu/ell/TransitionalGuidance.pdf 2) Please complete district information in the attached spreadsheet labeled ELL List by school for each ELL student in the district. Progress Report Due Date(s): May 22, 2014; October 24, 2014 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: Student records indicated that the district’s Parent Notification letter does not contain specific exit requirements and incorrectly requires that parents provide consent for ELE programming within five (5) day of receipt of the notice. Student records also indicated that the district provides families who are low-incidence language speakers with Spanish translated notification letters, rather than in the language of the home. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 74 Narrative Description of Corrective Action: The Parent Notification letter has been revised to contain specific exit requirements and to remove the request for parents to consent for ELE programming within five (5) days of receipt of the letter. See Attachment 1 for revised letter. Families who are low-incidence language speakers will receive notification letters translated in the language of their home as outlined in the district’s Department of Justice Settlement under Translation Services (Paragraph 32), Low-Incidence Translation Policy, and Standards of Practice for Interpreters. See attached Attachments 2, 3 and 4. The DOJ Settlement is expected to be finalized by Spring 2014. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of English Language Education The revised parent notification letters will be implemented by February 24, 2014. Notification letters for low-incidence languages will follow the protocol outlined in our Department of Justice Settlement Agreement’s Translation Services (Paragraph 32), LowIncidence Translation Policy, and Standards of Practice for Interpreters. The Settlement is expected to be finalized by Spring 2014. Evidence of Completion of the Corrective Action: Replacement of existing parent notification letters with revised letters. Copies of revised notification letters in LEP and LIP students’ records. Description of Internal Monitoring Procedures: Random student cumulative record review by designated school/district staff. Other monitoring as required by DOJ Settlement Agreement. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Parental Notification Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): The district will provide its revised procedures for providing parents with notification letters to document translation and interpretation needs, along with evidence of training of Parent Information Center staff and principals, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by May 22, 2014. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by May 22, 2014. Submit the results of an administrative review of 20 student records, representing each school level, for parent notification and translation and documentation of oral translations. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by October 24, 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 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 75 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): May 22, 2014; October 24, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal Access to Academic Programs and Services Rating: Partially Implemented Department CPR Finding: Student records and staff interviews indicated that translations of important school documents are not consistently provided to families who are not fluent in English. Staff interviews demonstrated that interpreters are not consistently provided for families in need of language support. Student files also indicated that ELLs do not receive the number of hours for English Language Development recommended by Department guidelines. Narrative Description of Corrective Action: Major language groups that comprise of 100 or more families within the District, and families who are low-incidence language speakers will receive “essential information” translated in the language of their home as outlined in the district’s Department of Justice Settlement Agreement under Translation Services (Paragraph 32), the Low-Incidence Translation Policy, and Standards of Practice for Interpreters. See attached Attachments 2, 3 and 4. The DOJ Settlement is expected to be finalized by Spring 2014. The district has been providing Level 1 and 2 students with the recommended hours of ELD, and for the past two years has been working to ensure that Level 3-5 students receive the recommended number of hours in ESL. We will continue to work towards this as outlined in our DOJ Settlement Agreement Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of ELE Corrective Action Activity: Upon final approval of DOJ Settlement (expected in Spring 2014), and on-going as outlined in Settlement. Evidence of Completion of the Corrective Action: Copies of letters/documents in students’ records and IEP records. Description of Internal Monitoring Procedures: Random student cumulative record review by designated school/district staff. Review of students’ schedules and other monitoring as required by DOJ Settlement. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 11 Equal Access to Academic Programs and Services Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): Please provide a narrative description and update on the implementation of the Department of Justice (DOJ) Settlement Agreement related to translation and interpretation for major languages and low incident languages, along with evidence of staff training, including principals, on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 76 before by May 22, 2014. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by May 22, 2014. Submit the results of an administrative review of 20 student records, representing all school levels, for translation and documentation of oral translations. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before by October 24, 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): May 22, 2014; October 24, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 12 Equal Access to Nonacademic and Extracurricular Programs Rating: Partially Implemented Department CPR Finding: Staff interviews and documentation indicated that the district provides students and families who are low-incidence language speakers with Spanish translated documents, rather than in the language of the home. Narrative Description of Corrective Action: Families who are low-incidence language speakers will receive “essential information” translated and/or interpreted in the language of their home as outlined in the district’s Department of Justice Settlement under Translation Services (Paragraph 32), LowIncidence Translation Policy, and Standards of Practice for Interpreters. See attached Attachments 2, 3 and 4. The DOJ Settlement Agreement is expected to be finalized by Spring 2014. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of ELE Corrective Action Activity: Upon final approval of DOJ Settlement (expected in Spring 2014), and on-going as stipulated in Settlement Agreement. Evidence of Completion of the Corrective Action: Copies of notices/documents, and logs of interpretation requests from schools and from “ Connections” (the HPS afterschool and summer school program). Description of Internal Monitoring Procedures: Periodic review of notices/documents/logs by designated school/district staff, and other monitoring as required by DOJ Settlement Agreement. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 12 Equal Access to Nonacademic and Extracurricular Programs Status of Corrective Action: Approved Partially Approved MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan Disapproved 77 Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): Provide a sample of translated essential documents that represent the district’s low incidence language speakers and the review logs of interpretation requests as designated by the district’s settlement agreement. Provide this information by May 22, 2014. Progress Report Due Date(s): May 22, 2014 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: Student records indicated that monitoring documentation is not consistently completed for students who have exited English learner education. Narrative Description of Corrective Action: Beginning in SY 2011/2012, the district developed a new comprehensive FLEP monitoring form, and revised the procedures for completion and review of the monitoring forms by school and district staff. The district will ensure that the monitoring mechanisms for completing, reviewing, and filing the monitoring forms are followed. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of ELE Corrective Action Activity: During the second annual monitoring period that occurs in May/June 2014, and bi-annually thereafter. Evidence of Completion of the Corrective Action: Proper completion of the monitoring forms/process during the second annual monitoring period in May/June 2014. Description of Internal Monitoring Procedures: Review of the monitoring forms by school and district staff, and random review of students’ records by school/district staff. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 13 Follow-up Support Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): Please provide a narrative description and update on the implementation of follow-up monitoring, along with evidence of staff training, including principals, on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by May 22, 2014. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by May 22, 2014. Submit the results of an administrative review of 10 student records for follow-up monitoring. Please ensure that the records are selected for students exited following the completion of all corrective MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 78 actions. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before October 24, 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): May 22, 2014; October 24, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 Records of ELL Students Rating: Partially Implemented Department CPR Finding: Student records indicate that the district does not provide families with English Language Development progress reports for their students. In addition, record review indicated that monitoring forms for students who exited English language education are not consistently completed. Narrative Description of Corrective Action: : ELD Progress Reports will be updated to reflect WIDA standards, and will be distributed with report cards and SpEd Progress Reports (3 times/year for K-5; 4 times/year for Gr. 6-12). WIDA CAN-DO Descriptors will be used by teachers to observe ELL progress in completing the ELD Progress Report. The ACCESS Parent Report will continue to be sent home annually. Beginning in SY 2011/2012, the district developed a new comprehensive FLEP monitoring form, and revised the procedures for completion and review of the monitoring forms by school and district staff. The district will ensure that the monitoring mechanisms for completing, reviewing, and filing the monitoring forms are followed. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of ELE Corrective Action Activity: September 2014 for ELD Progress Reports; for FLEP monitoring forms (students who exited English language education) completion during the second annual FLEP monitoring period that occurs in May/June 2014 , and bi-annually thereafter. Evidence of Completion of the Corrective Action: ELD Progress Report template will be revised and generated at the schools to be completed by ESL teachers, and to be distributed with report cards. WIDA CAN-DO Descriptors will be used by teachers to observe ELL progress in completing the ELD Progress Report. The ACCESS Parent Report will continue to be sent home annually. Beginning in SY 2011/2012, the district developed a new comprehensive FLEP monitoring, and revised the procedures for completion and review of the monitoring forms by school and district staff. The district will ensure that the monitoring mechanisms for completing, reviewing, and filing the monitoring forms are followed. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 79 Description of Internal Monitoring Procedures: ELD Progress Reports will be generated at schools to be completed by ESL teachers for ELLs, to be distributed with reports cards and SpEd Progress Reports (3 times/year for K-5; 4 times/year for 6-12). Random review of students’ records by school/district staff for completion of FLEP Monitoring forms and ELD Progress Reports. . CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 18 Records of ELL Students Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): Please provide procedures for direct language instruction progress reports and follow-up monitoring, along with evidence of staff training, including principals, on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by May 22, 2014. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by May 22, 2014. Submit the results of an administrative review of 20 student records from differing grade levels and proficiency levels for progress reports and follow-up monitoring. Indicate the number of records reviewed at each level, the number found to be compliant, 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. Please submit this to the Department on or before October 24, 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): May 22, 2014; October 24, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Holyoke CPR Corrective Action Plan 80