MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Marblehead CPR Onsite Year: 2011-2012 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 09/12/2012. Mandatory One-Year Compliance Date: 09/11/2013 Summary of Required Corrective Action Plans in this Report Criterion SE 9 SE 14 Criterion Title Timeline for determination of eligibility and provision of documentation to parent Review and revision of IEPs SE 18A IEP development and content SE 18B Determination of placement; provision of IEP to parent SE 24 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 Assistive technology: specialized materials and equipment SE 35 CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 48 CR 3 CR 7 CR 7B CR 9 Criterion Title FAPE (Free, appropriate, public education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education Access to a full range of education programs Information to be translated into languages other than English Structured learning time CR 10A Hiring and employment practices of prospective employers of students Student handbooks and codes of conduct CR 11A Designation of coordinator(s); grievance procedures CR 12A Annual and continuous notification concerning nondiscrimination and coordinators 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 Institutional self-evaluation CR 16 CR 17A CR 25 CPR Rating 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 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: A review of student records indicated that evaluations are not always conducted within 30 school working days after the receipt of parental consent. Description of Corrective Action: The Director will use Special Education Leadership meetings, which take place every other Friday, to review this requirement and to develop a plan to streamline the handling of parental consent so that no time is lost prior to the beginning of the evaluation process. Including principals in this training and awareness will also improve compliance. This will allow us to fully implement this requirement. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Special Education Chairpersons, Completion: Building Principals 04/30/2013 Evidence of Completion of the Corrective Action: Evidence of our Special Education Leadership meeting agenda showing discussion and materials used to improve compliance with this criterion. Description of Internal Monitoring Procedures: Director will randomly pull a sampling of initial and reevaluation files at each level to selfassess improvement and compliance with this regulation. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 9 Timeline for determination of Status Date: 11/19/2012 eligibility and provision of documentation to parent Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action. It will develop a process to streamline the handling of parental consents to ensure compliance with required timelines, as well as provide training to appropriate staff on the revised protocol. The district will then conduct a follow-up administrative record review to ensure 100% compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, the district will submit its plan to streamline and track the receipt of parental consents for evaluations, as well as evidence (agenda, signed attendance sheets, training materials) of training for principals and required special education staff on the revised process. By April 12, 2013, after the district has implemented all corrective actions, the district will conduct an internal record review to ensure that evaluations are conducted within 30 school working days after the receipt of parental consent. Report the number of evaluation consents received, the number of evaluations that were conducted in 30 school working days, and if any non-compliance is identified, report the steps taken to remedy each individual file. The district will also identify the root cause of the ongoing noncompliance and a plan of action to ensure ongoing compliance. MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 3 *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 01/11/2013 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: A review of student records and staff interviews indicated that IEP Team meetings are not always held prior to the expiration date of the IEP. Description of Corrective Action: MPS believed that if both parent and district agreed in writing to hold the IEP Team meeting after the expiration date of the IEP, that this was allowed practice. With this citing, MPS will be increasing our efforts to schedule these meetings with enough advance time so as not to go beyond the IEP expiration date. This will not be a major difficulty now that we are aware of the "no exceptions, even if parent and district agree" opinion. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services and Special Education Chairpersons Completion: 04/30/2013 Evidence of Completion of the Corrective Action: Evidence will be that from a random sampling of each chairperson's scheduled IEP Team meetings, there will be 100% compliance. Description of Internal Monitoring Procedures: The Director will request all special education chairpersons to identify those situations where scheduling seems to be problematic and to schedule those meetings well in advance of the expiration date. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Approved Status Date: 11/19/2012 Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action for this criterion. It will develop a tracking process to ensure that annual reviews will be conducted and IEPs will be developed prior to the expiration date of the previous IEP. The district will provide training to appropriate staff on the tracking process and conduct a follow-up administrative tracking review to ensure 100% compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, the district will submit a description of its tracking procedures to ensure that annual review Team meetings are conducted and that IEPs are developed prior to the expiration date of the previous IEP. Submit evidence (agenda, signed attendance sheets, training materials) of training for principals and required special education staff on the revised procedures. By April 12, 2013, after the district has implemented all corrective actions, the district will conduct an internal review of the tracking data at all levels (elementary, middle school, high school) to ensure that annual reviews are conducted and IEPs are developed prior to the expiration date of the previous IEP. Report the number of annual review Team meetings conducted at each level and the number of annual reviews that had IEPs proposed prior to the expiration date of the previous IEP. If any non-compliance is identified, report the steps taken to remedy each individual file and identify and report the root cause of the ongoing non-compliance with a plan of action to ensure ongoing MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 5 compliance. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 01/11/2013 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18A IEP development and content Partially Implemented Department CPR Findings: A review of student records indicated that IEP Teams do not reference the specific skills and proficiencies in IEPs that are needed to avoid and respond to bullying, harassment, or teasing for those students whose disability affects their social skills development or are on the autism spectrum. Description of Corrective Action: After providing a basic training to all special education chairpersons through our Special Education Leadership meetings, Chairpersons will provide information and training at their monthly department meetings to special education teachers at all levels. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Special Education Chairpersons, Completion: special education teachers 04/30/2013 Evidence of Completion of the Corrective Action: Chairpersons, who chair all special education meetings, will verify through the use of our Team meeting summary sheet, that IEP meetings have discussed this issue and made provisions, where necessary, to avoid and respond to bullying, harassment or teasing students whose disability effects their social development or for those students with an ASD diagnosis. Description of Internal Monitoring Procedures: Chairpersons will report back to the Director regarding the provision of training to the teachers, complete with agenda and training materials to insure that all teachers understand this requirement. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18A IEP development and content Corrective Action Plan Status: Approved Status Date: 11/19/2012 Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action for this criterion. The district will train required staff on how to reference the specific skills and proficiencies in IEPs that are needed to avoid and respond to bullying, harassment, or teasing, and will conduct an administrative review of student records to ensure 100% compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, the district will submit evidence of staff training (agenda, signed attendance sheets, training materials etc.) that training for special education staff was conducted on how to reference the specific skills and proficiencies in IEPs that are needed to avoid and respond to bullying, harassment, or teasing for those students whose disability affects their social skills development or are on the autism spectrum. For those students whose names were provided to the district as being out of compliance during the record review, submit updated copies of these students' IEPs. By April 12, 2013, following the district's implementation of all corrective actions, please select a sample of records of students who are on the autism spectrum or whose disability affects their social skills development at each level to verify that the records contain documentation that IEP Teams have considered and specifically addressed the MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 7 skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing. Report the number of records reviewed at each level and the number of records in compliance. For any records not in compliance with this criterion, provide the results of a root cause analysis of the non-compliance and the specific actions taken by the district to remedy any identified noncompliance. *Please note that when monitoring, the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 01/11/2013 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18B Determination of placement; provision of IEP to parent Partially Implemented Department CPR Findings: A review of student records indicated that at all school levels and for students in out-ofdistrict placements, parents are not always provided with the proposed IEP and placement immediately following the development of the IEP. Description of Corrective Action: The Director, in collaboration with Special Education Chairpersons, at monthly Special Education department meetings at all levels, will provide training to special education teachers, related service providers and any other person responsible for a component of the IEP document regarding the need to provide the IEP to parents as soon after the development as possible but no later than 10 days after the IEP development meeting. MPS will continue to give parents a TEAM summary sheet at the end of the meeting so that parents understand what services/changes were being proposed at the IEP meeting and [new] include an expected date that parent(s) can expect to receive the IEP proposal. Principals will also be included in the trainings to stress the importance of their signing the proposed IEPs in a timely manner so that they can be delivered to parents. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Special Education Chairpersons, Completion: Principals 06/30/2013 Evidence of Completion of the Corrective Action: It will be evident that our efforts to meet this requirement will be complete when training has been conducted at all levels and that we are in 100% compliance with parents receiving the proposed IEP immediately but no more than 10 days after the IEP meeting date. Description of Internal Monitoring Procedures: Through a random sampling comparison between Team summary sheets, with date IEP is expected to be delivered, and actual delivery date, the Director and Special Education Chairpersons will monitor progress towards completion. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 18B Determination of placement; Status Date: 11/19/2012 provision of IEP to parent Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action for this criterion. The district will develop a tracking process to ensure that proposed IEPs and placements for all out-of-district students are provided to parents immediately following the development of the IEP. The district will provide training to appropriate staff on the tracking process and will conduct a follow-up administrative record review to ensure 100% compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, the district will submit evidence (agenda, signed attendance sheets, training materials etc.) that training for special education staff was conducted on the provision of IEPs to parent. By April 12, 2013, following the district's implementation of all corrective actions, conduct MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 9 an internal review of the tracking data for students in out-of-district placements at each level (elementary, MS, & HS). Report the number of IEP Team meetings held (annual reviews & re-evals) requiring the development of IEPs, and the number of parents who received proposed IEPs and placements immediately following the Team meeting. For any records not in compliance, report the root cause analysis of the ongoing non-compliance, the district's plan to remedy the noncompliance and the specific corrective actions taken by the district to remedy any identified noncompliance in specific student records. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 01/11/2013 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 10 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: A review of student records indicated that at the preschool, elementary, and high school levels the district's Notices of Proposed Action (N1) did not always include the following four required elements: 1. An explanation of why the agency proposed or refused to take the action. 2. A description of any other options that the agency considered and the reasons why those options were rejected. 3. A description of each evaluation procedure, test, record, or report the agency used as a basis for the proposed or refused action. 4. A description of any other factors relevant to the agency's proposal or refusal. In addition, the district does not always provide parents with notice documenting the district's actions when proposing home/ hospital services; conducting manifestation determination meetings or IEP team meetings regarding a change of placement. Description of Corrective Action: At the preschool, elementary and high school levels, the District will fully comply with this requirement, through additional training of Special Education Chairpersons, who are primarily responsible for the completion of N1's This training will take place at one or more Special Education Leadership meetings which take place two times per month during the school year. Title/Role(s) of responsible Persons: Expected Date of Special Education Chairpersons with review by Director of Completion: Student Services 06/30/2013 Evidence of Completion of the Corrective Action: We will know that we are in full compliance with this criterion when 100% of the situations requiring an N1 are completed, answering all of the required questions. Random samples of N1's will be utilized and reported on. Description of Internal Monitoring Procedures: As Director, I have also made the decision to require the use of the question format (through our web-based IEP program) rather than the paragraph, to assist in guiding Chairs to improve their N1 writing. The Special Education Chairs and I will use individual meeting times to monitor compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 24 Notice to parent regarding Status Date: 11/19/2012 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: The district proposed a comprehensive plan of corrective action for this criterion. The district will conduct training on the requirements of N1 notices; procedures for notifying and documenting the district's actions when proposing home/hospital services to parents; and procedures for conducting manifestation determination meetings or IEP Team meetings regarding a change of placement. The district will also conduct a follow-up MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 11 administrative record review to ensure 100% compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, the district will submit evidence (agenda, signed attendance sheets, training materials, etc.)that training was conducted for special education staff on the requirements for writing comprehensive Notices of Proposed School District Action (N1) forms. By April 12, 2013, following the district's implementation of all corrective actions, conduct an internal record review at each level (elementary, MS, & HS). Report the number of records reviewed and the number that contained comprehensive N1 forms that addressed all required elements: 1. An explanation of why the agency proposed or refused to take the action. 2. A description of any other options that the agency considered and the reasons why those options were rejected. 3. A description of each evaluation procedure, test, record, or report the agency used as a basis for the proposed or refused action. 4. A description of any other factors relevant to the agency's proposal or refusal. For any records not in compliance, report the root cause analysis of the ongoing non-compliance, the district's plan to remedy the non-compliance and the specific corrective actions taken by the district to remedy any identified noncompliance in specific student records. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 01/11/2013 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 35 Assistive technology: specialized materials and equipment Partially Implemented Department CPR Findings: Staff interviews and parent surveys indicated that the district is unable to consistently implement the specific assistive technology requirements on accepted IEPs. Different schools and in some instances, different classrooms within the schools, have outdated computers that delay the downloading of specific programs needed by students. Teachers cannot run needed software, or the computer specifications are not compatible with the assistive technology software needed to implement IEPs. Description of Corrective Action: While Marblehead is providing compliance with the consideration of assistive technology assessments and student assistive technology needs through the IEP process, Marblehead's infrastructure and need for more updated computers and other technological devices has been accurately reflected.The District, through our new Supervisor of Technology and Technology Director ,will develop both a long and short term plan to correct the inadequacies of the district in keeping pace with the assistive technology infrastructure issues needed to support the requirements currently in students' IEPs. Through a needs assessment and the data compiled by our Assistive Technology consultant, we will address the immediate needs reflected in this finding. Title/Role(s) of responsible Persons: Expected Date of Director of Student Svces, Director of Technology, Sp.Ed/ Completion: Chairpersons, Asst. Tech Consultant 06/30/2012 Evidence of Completion of the Corrective Action: Evidence of compliance will be the end of the year results, where we will have 100% compliance with the assistive tech needs of the students, where the computers and infrastructure, limited to designated work areas at first, will be in place to meet student IEP needs. Description of Internal Monitoring Procedures: At all levels we will first compile, through a report completed by the Supervisor of Technology, a list of the areas that need to be brought up to standards to meet the assistive technology needs of the district, which will then be used as a checklist of needed improvements that have been completed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 35 Assistive technology: specialized Status Date: 11/19/2012 materials and equipment Basis for Partial Approval or Disapproval: The district will develop and submit its long and short term plans to ensure that it will have the in-house capacity to implement the assistive technologies identified in IEPs. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, following the Supervisor of Technology's needs assessment, the district will submit its long and short term plans to ensure that the district will have the in-house capacity to implement the assistive technologies identified in IEPs. By April 12, 2013, conduct an internal review of records of students, subsequent to implementation of the corrective actions, and indicate the number of records reviewed, MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 13 the number of records in compliance and for any records not in compliance, indicate the specific steps taken to remedy the non-compliance. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 01/11/2013 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 14 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: Staff interviews indicated that students with disabilities in grades 6-8 do not have opportunities to participate in a foreign language if they need specialized reading supports. Description of Corrective Action: Due to the way the schedule is set up at both the Village and Veterans School (covering Grades 4-8), some students who require additional reading supports or those who are in special education programs requiring additional tutorial blocks, may not have time available in their schedules to choose a foreign language, thus depriving them of the opportunity and/or choice to elect this foreign language option. Title/Role(s) of responsible Persons: Expected Date of Student Services Director, Village and Veterans School Completion: Principals, Sp. Ed. Chairpersons 09/03/2013 Evidence of Completion of the Corrective Action: Evidence of 100% completion of this criterion will be a schedule that takes into account all of the students in the building and offers or limits opportunities for everyone equally, providing FAPE. Description of Internal Monitoring Procedures: Meetings throughout the 2012-2013 school year regarding how this requirement can be met, with input from parents and teachers regarding the fair implementation of foreign language introduction to all students with the product being a schedule at each of these schols that supports this criterion. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 48 FAPE (Free, appropriate, public Status Date: 11/19/2012 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: The district will develop and submit a proposed plan of action that will ensure that eligible students in grades 6-8 will have opportunities to participate in a foreign language if they need specialized reading supports by the start of the 2014 school year. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, submit a proposed plan of action that will ensure that students with disabilities in grades 6-8 will have opportunities to participate in a foreign language if they need specialized reading supports. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 15 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 16 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 3 Access to a full range of education programs Partially Implemented Department CPR Findings: See SE 48. Description of Corrective Action: Due to the way the schedules are set up at both the Village and Veterans Schools (covering Grades 4-8), some students who require additional reading or other academic supports or those who are in special education programs requiring additional tutorial blocks, may not have time available in their schedules to choose a certain general education offerings (including foreign language), thus depriving them of the opportunity and/or choice to elect these general education offerings. Title/Role(s) of responsible Persons: Expected Date of Assistant Supt,Director of Human Resources, Director of Student Completion: Services, Principals 09/03/2013 Evidence of Completion of the Corrective Action: Evidence of 100% completion of this criterion will be school schedules that take into account all of the students in the building and offer or limit opportunities equally for all students. Description of Internal Monitoring Procedures: Administrative meetings throughout the 2012-2013 school year regarding how this requirement can be met regarding the implementation of a schedule that does not discriminate between students in offering equal access to school offerings. Progress will be measured throughout the year to see steady progress in implementing the changes needed to meet this requirement. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 3 Access to a full range of education Status Date: 11/19/2012 programs Basis for Partial Approval or Disapproval: See SE 48 Department Order of Corrective Action: Required Elements of Progress Report(s): See SE 48. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 17 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: A review of documentation and interviews indicated that the district does not have or distribute translated important information and documents ( e.g. handbooks and codes of conduct) for those parents or guardians with limited English skills, nor does the district have an established system of oral interpretation. Description of Corrective Action: The District will first identify what documents it considers important, such as but not limited to, handbooks and codes of conduct. Then,through our student data collection system, identify students who have a first language other than English or whose language spoken in the home is other than English, and provide these important documents to parents who would benefit from these translated materials. Title/Role(s) of responsible Persons: Expected Date of Assistant. Superintendent/ELL Director, Director of Human Completion: Resources 09/03/2012 Evidence of Completion of the Corrective Action: Evidence of completion of this corrective action will be the evidence of a system that identifies important information and documents and uses established lists of students whose parents either speak languages other than English and/or would find it useful and helpful to receive this info or documents translated into their language. Description of Internal Monitoring Procedures: Internal monitoring will consist of regularly checking in with building and central data personnel to ensure that this important information is getting translated and into the hands of those parents and/or guardians who need it. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 7 Information to be translated into Status Date: 11/19/2012 languages other than English Basis for Partial Approval or Disapproval: The district will submit a list of documents to be translated, a proposed plan (with implementation dates, persons responsible) to ensure that the district will meet the translation needs of its LEP population and the district will conduct an internal review regarding this criterion. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, submit copies of translated documents (handbooks, codes of conduct). Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 18 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7B Structured learning time Partially Implemented Department CPR Findings: The document review and staff interviews indicated that the district does not offer physical education in all grades at the high school level. Description of Corrective Action: The High School Principal and Assistant Principals will meet with the Athletic Director to discuss options to be in compliance with state law regarding the need for each grade level at the HS to offer physical education. Title/Role(s) of responsible Persons: Expected Date of High School Principal, HS Assistant Principals, Athletic Director Completion: 06/30/2013 Evidence of Completion of the Corrective Action: The evidence will consist of a schedule and/or program of studies that lists physical education as an offering in each of the HS grades, 9-12. Description of Internal Monitoring Procedures: This will be monitored by documentation provided by the HS Principal to Central Administrators showing that the HS offers a physical education option in each HS grade. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 7B Structured learning time Corrective Action Plan Status: Approved Status Date: 11/19/2012 Basis for Partial Approval or Disapproval: The district will submit a plan and a revised course of studies to ensure that all students in grades 9-12 will receive physical education to ensure 100% compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, submit the district's plan (schedule, course of studies, etc.) to ensure that all students in grades 9-12 will receive the mandated physical education. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 19 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: A review of documents indicated that the district's signed statement procured from prospective employers of students does not specifically include the following protected categories: race, color, national origin, sex, handicap, religion and sexual orientation. Description of Corrective Action: Signed statement procured from prospective employers of students that includes the following protected categories; race, color, national origin, gender identity, sex, handicap, religion and sexual orientation. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services Completion: 11/30/2012 Evidence of Completion of the Corrective Action: A corrected statement uploaded for review by the Coordinated Program Review Team. Description of Internal Monitoring Procedures: The corrected form will be distributed at an Administration Council meeting for use in all buildings where prospective employers of students may be present. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 9 Hiring and employment practices of Status Date: 11/19/2012 prospective employers of students Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action for this criterion. On November 6, 2012, the district submitted a revised letter for prospective employers of students that includes all protected categories. Department Order of Corrective Action: Required Elements of Progress Report(s): Progress Report Due Date(s): MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 20 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 10A Student handbooks and codes of conduct Partially Implemented Department CPR Findings: A review of documentation indicated that the district has handbooks for all schools. The high school and middle school student handbooks omit procedures for the reporting, investigation and resolution of complaints involving discrimination and the discipline procedures for students not yet eligible for special education. Elementary school handbooks omit grievance procedures for harassment. Staff interviews indicated that the district has a paperless electronic distribution system for student handbooks and report cards. While the district is able to track who does not log onto the district's system, the district does not automatically send out hard copies of student handbooks to those parents who have not logged onto the system. While the district reports that it would translate handbooks and code of conduct into languages other than English if requested, the district does not formally track parent requests. Description of Corrective Action: Specifically the Middle and High School Handbook will be corrected to include procedures for the reporting, investigation and resolution of complaints involving discrimination and the discipline procedures for students not yet eligible for special education. Elementary handbooks will be corrected to include grievance procedures for harassment. The district will require parents to read, understand and return a sign-off regarding the handbook contents, either electronically or through a hard copy return. Title/Role(s) of responsible Persons: Expected Date of All principals, Director of Student Services, Director of Human Completion: Resources 09/03/2013 Evidence of Completion of the Corrective Action: Handbook corrections can be submitted by November 30, 2012. The process for handbooks being translated and all parents receiving handbooks, either digitally or in hard copy format will be completed by the start of the new school year, as noted in the Expected Date of Completion. Schools should show 100% participation and/or its strong effort to engage 100% of the parents and guardians of students in the district. Description of Internal Monitoring Procedures: Monitoring will be that all handbooks will show the changes by the expected date of completion and moving forward. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 10A Student handbooks and codes of Status Date: 11/16/2012 conduct Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action for this criterion. The district will revise the handbooks to ensure 100% compliance and will track receipts to ensure that all parents received them. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, submit the revised student handbook pages and indicate how this information was provided to parents. Progress Report Due Date(s): MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 21 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 22 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 11A Designation of coordinator(s); grievance procedures Partially Implemented Department CPR Findings: A review of documents indicated that the district has not designated a person to serve as Title IX coordinator. High school and middle school handbooks omit grievance procedures for the reporting, investigation and resolution of complaints involving discrimination. Description of Corrective Action: The district has already completed the designation of a person to serve as Title IX coordinator and it was distributed to all staff at our beginning of the year (1st month) mandatory training. The HS and MS handbooks will be corrected to include grievance procedures for the reporting, investigation and resolution of complaints involving discrimination. Title/Role(s) of responsible Persons: Expected Date of Director of Human Resources, Director of Student Services, Completion: Principals 09/03/2013 Evidence of Completion of the Corrective Action: Uploaded document as part of that training showing who the Title IX Coordinator is and giving contact information for that person. The handbook corrections will also be submitted no later than the date of completion given. Description of Internal Monitoring Procedures: These corrections will be monitored by insuring that the corrections get made and that the designation of a Title IX Coordinator is stated in all necessary documents and at annual mandatory trainings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 11A Designation of coordinator(s); Status Date: 11/19/2012 grievance procedures Basis for Partial Approval or Disapproval: See CR 10A. Department Order of Corrective Action: Required Elements of Progress Report(s): See CR 10A. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 23 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: A review of documents indicated that the district's student handbooks omit the name(s), office address(es), and phone number(s) of the person(s) designated as the Title IX coordinator. Description of Corrective Action: All district student handbooks will be corrected to include the name(s), office address(es)of the person(s) designated as the Title IX coordinator. Title/Role(s) of responsible Persons: Expected Date of All Principals, Director of Human Resources, Director of Student Completion: Services 09/03/2013 Evidence of Completion of the Corrective Action: A corrected handbook or excerpt from the handbooks showing that the corrections have been made. Description of Internal Monitoring Procedures: During the year, but especially in the spring when new handbooks are submitted, making sure that the Title IX coordinator information is clearly articulated in the handbooks being proposed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 12A Annual and continuous Status Date: 11/19/2012 notification concerning nondiscrimination and coordinators Basis for Partial Approval or Disapproval: See CR 10A. Department Order of Corrective Action: Required Elements of Progress Report(s): See CR 10A. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 24 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: A review of documents indicated that the district's notice to students 16 or over leaving school does not contain all the required information. The notice omits that a parent/guardian may request a meeting extension of not longer than fourteen days, omits the purpose of the meeting (to discuss the reasons why student is leaving school and to inform them of alternative educational or other placements) and does not inform the recipient of the availability of publicly funded post-high school academic support programs or encourage them to participate in those programs. Description of Corrective Action: The district's notice to students 16 or over, leaving school w/o a high school diploma, certificate of attainment, or certificate of completion must be corrected to include all required information as noted in the CPR finding above. Title/Role(s) of responsible Persons: Expected Date of HS Principal and Asst. Principals, Director of Human Resources Completion: 06/30/2013 Evidence of Completion of the Corrective Action: A corrected document uploaded and reviewed and approved by the CPR team. Description of Internal Monitoring Procedures: This will be monitored by making sure that the corrected document is distributed to all relevant employees such as HS guidance counselors who would use the letter for any students who meet the criteria for this item. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 16 Notice to students 16 or over Status Date: 11/19/2012 leaving school without a high school diploma, certificate of attainment, or certificate of completion Basis for Partial Approval or Disapproval: The district will submit a revised notice to students 16 or over leaving school and will inform applicable staff (principals, guidance, etc) on the revised letters to ensure 100%. compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, submit a copy of the revised notice sent to students 16 or over leaving school without a high school diploma, certificate of attainment or certificate of completion. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 25 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: A review of documentation and interviews indicated that the district did not conduct staff training on the use of physical restraint consistent with regulatory requirements within the first month of each school year and for employees hired after the school year begins, within a month of their employment. Description of Corrective Action: The district has already completed this item by completing our staff training on the use of physical restraint consistent with regulatory requirements within the first month of the school year and will continue to offer the training to any new employees hired after the start of the school year, within a month of their employment. Title/Role(s) of responsible Persons: Expected Date of Director of Student Services, Student Services Liaison, Director Completion: of HR. 11/30/2012 Evidence of Completion of the Corrective Action: Evidence of the training that took place within the first month of the 2012-2013 school year. Description of Internal Monitoring Procedures: This was monitored by the scheduling of this mandatory training on the teachers first or second full day of school (depending on the school) for the 2012-2013 school year. In addition, the HR department has been alerted that any new employees starting after the beginning of the new school year must receive the training within one month of their hiring. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 17A Use of physical restraint on any Status Date: 11/19/2012 student enrolled in a publicly-funded education program Basis for Partial Approval or Disapproval: The district will submit documentation that training was conducted on the requirements of physical restraint. Department Order of Corrective Action: Required Elements of Progress Report(s): By January 11, 2013, submit documentation (agenda, signed attendance sheets) from each school indicating that training on the use of physical restraint consistent with regulatory requirements was conducted within the first month of the 2013 school year. The district will also conduct an internal review of its tracking procedures and report the number of new staff hired after the start of the school year, the number that received training within a month of their employment and if noncompliance is identified, submit the root cause of the ongoing non-compliance and a plan to remedy it. Progress Report Due Date(s): 01/11/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 26 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 27 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: A review of documents and interviews indicated that the district has not conducted an annual self-evaluation of its K-12 program. Description of Corrective Action: The Marblehead Public Schools must conduct an annual self-evaluation of its K-12 program. Title/Role(s) of responsible Persons: Expected Date of Superintendent of Schools, Asst. Superintendent, Director of HR, Completion: Principals 09/03/2013 Evidence of Completion of the Corrective Action: Evidence of completion of this corrective action will be the production of a self-evaluation summary of all K-12 programming. Description of Internal Monitoring Procedures: Monitoring of this activity in the future will be the role of our HR Director, with principals collecting information as directed by the Superintendent. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Approved Status Date: 11/19/2012 Basis for Partial Approval or Disapproval: The district will submit an institutional self-evaluation summary of all K-12 programming. Department Order of Corrective Action: Required Elements of Progress Report(s): By April 4, 2013, the district will submit a copy of the institutional self-evaluation. Progress Report Due Date(s): 04/12/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Marblehead CPR Corrective Action Plan 28