MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Northampton Public School District Corrective Action Plan Forms Program Area: Special Education Prepared by: Nathan Ziegler/Rose Carr 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: November 22, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 1 Assessments are appropriately Rating: Partially Implemented selected and interpreted for students referred for evaluation Department CPR Finding: A review of documents, student records and interviews indicate that assessments are not tailored to assess specific areas of educational or related developmental need. In addition, the district does not have tests and other evaluation materials that are provided and administered in the language and form most likely to yield accurate information on what the student knows and can do academically, developmentally, and functionally for limited English proficient students that are referred for evaluations. Interviews and parent surveys indicate that in interpreting evaluation data and making decisions, the district does not ensure that the placement decision conforms with placement in the least restrictive environment. See SE 20. 1 Narrative Description of Corrective Action: The district offers various assessments to assess specific areas of educational or related developmental need, as evidenced by the Permission for Evaluation Forms sent to parents. The district will provide training and a list of assessments to ETLs, Special Education Teachers, and Related service providers. The district continues to contract with bilingual evaluators for LEP students. The district will ensure that all assessment materials and techniques are in the language that will yield the most accurate information regarding student functioning. Procedures to determine who receives bilingual testing will be developed as well as a request form for bilingual assessments that will be sent to the special education office. The procedures and forms will be reviewed with special education staff. Placement decisions will be made with consideration of providing a Free and Appropriate Public Education (FAPE) in the least restrictive environment. IEP teams will explore the most inclusive placement options, and proceed to review sequentially, if necessary, up to the less restrictive options. Program descriptions will be developed and disseminated to special education staff. Review of the schools’ Curriculum Accommodation Plans will be conducted and provided to special education staff. If the team makes a decision to have the student removed from the regular classroom for services, then a discussion will take place regarding the justification for removal. Title/Role of Person(s) Expected Date of Completion for Each Corrective Action Activity: May 21, 2010 Responsible for Implementation: Director of Special Education Evidence of Completion of the Corrective Action: Staff training agendas and attendance sign in sheet. List of assessments.Procedures for the determination of bilingual testing and a request for bilingual testing form will be reviewed at a staff training. Training agendas and attendance sign in sheets will be provided.Development and review of program descriptions and school curriculum accommodation plans at a staff training. With agenda and attendance sheet. Internal monitoring: Quarterly review of request for assessment for students whose primary language is other than English and/or whose parents are identified as having a language other than English. The primary language of a student and/or parent is already listed on the referral form or the IEP. Rate of compliance will be reported to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 1 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit the following documentation: A list of assessments used to assess specific areas of education or related 2 developmental need. Procedures for the evaluation of students who do not speak English. Documentation (sign-in sheets, agendas and training materials) evidencing that training was conducted for all identified staff district-wide on the evaluation procedures of students who do not speak English. Documentation (sign-in sheets, agendas and training materials) evidencing that training was conducted for all identified staff district-wide on exploring and placing eligible students in the least restrictive environment. See also SE 20. By June 30, 2010, the district will conduct an internal review at all levels. Report on the number of limited English proficient student records reviewed which required evaluations, including at the preschool level, the number of those student records in which assessments were conducted in a language and form most likely to yield accurate information on what the student knows and can do academically, developmentally, and functionally and specific corrective action taken if needed, to ensure that all student files are in compliance. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 2 Required and optional Rating: Partially Implemented assessments Department CPR Finding: Interviews and parent surveys indicate that particularly at the elementary and high school levels, students are not assessed in all areas of suspected disability. In addition, it is a common practice of the district to remove related services from service delivery grids after elementary school without students’ achieving their goals or further conducting comprehensive assessments in areas of disability. Narrative Description of Corrective Action: See SE1 regarding students’ assessments. Entrance and exit criteria will be established for related services. Review of the criteria at a staff training. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: May 21, 2010 Education Evidence of Completion of the Corrective Action: Training agenda and attendance sign in sheet will be submitted to the DESE. Description of Internal Monitoring Procedures: 10 IEPs for students transitioning from elementary to middle school and 10 IEPs for students transitioning from middle school to high school whose related services have been discontinued from the service delivery grid, will be reviewed to indicate that assessments have been completed or the student has reached their goals and benchmarks. Rate of compliance will be reported to the DESE 3 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 2 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, submit the procedures for staff to follow in order to ensure that related services are not removed from service delivery grids after elementary school without indicating that the student achieved the goals in the IEP or without further assessments being conducted. Also submit evidence of staff training regarding this criterion. By June 30, 2010, the district will conduct an internal review at the elementary level. Report on the number of students who have been exited from related services, the number of student records in compliance with this criterion, and specific corrective action taken, if needed, to ensure that all student files are in compliance. See also SE 1 regarding assessments in the area of suspected disability. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 4 Reports of assessment Rating: Partially Implemented results Department CPR Finding: Interviews and parent surveys indicate that summaries of assessments are not completed prior to discussion by the Team and are not made available to parents at least two days in advance of the Team meeting when requested by parents. Narrative Description of Corrective Action: The district, upon request, will make assessment reports available to parents at least two days prior to the Team meeting. Assessment reports must be given to the ETL or special ed office two days before the Team Meeting. Staff will be trained in this area and sent a Memo. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Corrective Action Activity: May 21, 2010 Director/Team Leaders Evidence of Completion of the Corrective Action: Training agenda, attendance sign in sheet and Memo will be submitted to DESE. 4 Description of Internal Monitoring Procedures: Team Leaders in each school will track dates of report availability for the team meeting. This information will be sent to the special education office quarterly for analysis. Rate of compliance will be sent to the DESE CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 4 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence of training (attendance sheets, agendas, training materials) to ensure that upon request by the parent, staff make summaries of assessments available two days prior to Team meetings. By June 30, 2010, the district will conduct an internal review. Report on the number of parents who requested summaries of assessments prior to Team meetings, the number of parents who received summaries of assessments two days prior to Team meetings and any corrective action taken to ensure that all student files are in full compliance. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 8 IEP Team composition Rating: Partially Implemented and attendance Department CPR Finding: Interviews at all levels indicate that while the district has designated educational Team liaisons, they do not have the authority to commit the resources of the district and frequently reschedule Team meetings and seek approval from the administrator of special education regarding services, programs and placements. Interviews also found that individuals who are qualified to interpret the instructional implications of evaluation results are not always in attendance at Team meetings. Lastly, a review of documents, student records and interviews indicate that the district does not have procedures in place and staff are unfamiliar with the requirement that parents must agree and consent in writing to excusing a required Team member’s attendance at a Team meeting. 5 Narrative Description of Corrective Action: The district will provide training for ETLs and special education teachers as to their authority in committing resources and if additional information needs to be gathered for services, programs or placements recommendations, a follow up Team meeting will be scheduled for presentation of new information and consideration for recommendations. Principals will be notified via memo regarding their authority to commit resources at the Team meeting. The district will provide training on the requirements of the Team composition; personnel familiar with student performance and personnel who can interpret assessment results. Principals will be notified via memo of Team meeting requirements Procedures will be developed and training for special education staff will be provided regarding parent agreement and consent in writing to excuse a required Team member’s attendance at a Team meeting. Principals will be notified of this requirement via memo. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director Corrective Action Activity: May 21, 2010 Evidence of Completion of the Corrective Action: Procedures for parent consent in writing to excuse a required Team member’ attendance at a Tea meeting. Training agenda, attendance sign in sheet , and memo to principals will be submitted to the DESE. Description of Internal Monitoring Procedures: 10 IEP Team meeting attendance sign in pages from each school will be reviewed quarterly for attendance by someone who has authority to commit resources, someone who is familiar with the student’s performance, and someone who is qualified to interpret assessment results when assessments are being discussed. The attendance sign in and excuse form will also be reviewed for parent consent in writing that a required Team member is not present at the Team. Rate of compliance of the review will be sent to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 8 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence of training (attendance sheets, agendas, training materials) on the requirements of the Team composition, and procedures for the parental excusal of required Team members. By June 30, 2010, the district will conduct two internal reviews for each building: Report the number of records reviewed, the number that evidenced all required Team members in attendance, and any corrective actions taken to ensure that all student files are in full compliance. The district will conduct a second internal review in which records indicated that Team members were absent from Team meetings. Report the number of student records reviewed, the number that documented parent excusals of required Team members in writing and any corrective actions taken to ensure that all student files are 6 in full compliance. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 9 Timeline for Rating: Partially Implemented determination of eligibility and provision of documentation to parent Department CPR Finding: A review of student records, interviews and parent surveys indicate that across all levels, the district does not meet timeline requirements for determination of eligibility. Narrative Description of Corrective Action: The district is in the process of hiring a part time psychologist to meet eligibility timelines. The district will provide training to Special Education staff regarding timelines for determination of eligibility. The district will advise staff to use a DRAFT IEP for annual review meetings and Summary of Team Meeting form for initial and re-evaluation meetings indicating general student services, times of services, and placement of services and present this document as a proposed IEP to parents or a copy of the Summary of the Team Meeting form listing agreed upon services. The Summary of the Team Meeting will be signed by the parent and given to the parent at the end of the team meeting. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: October 8, Education, ETL, special education staff 2010 Evidence of Completion of the Corrective Action: Training agenda and attendance sign in sheet will be submitted to the DESE. Newspaper advertisement for a part time Psychologist. Summary of Team Meeting form will be submitted to DESE Internal Monitoring: Quarterly analysis of 10 records from each school listing student name, grade, assigned ETL and all required due dates for completion of assessments, invitation to Team meeting, Team meeting, meeting summary form, issuance of IEP or recommendation of no eligibility or dismissal and parent response. Rate of compliance will be submitted to the DESE 7 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 9 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence of training (materials, agendas, signed attendance sheets) for all special education staff on the timeline requirements for determination of eligibility. By June 30, 2010, the district will conduct an internal review at all buildings. Report the number of students that were referred for evaluations (initial and reevaluations), the number of files in compliance with the required timelines for eligibility determination, and any specific corrective action taken to ensure full compliance with this criterion. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 9A Elements of the Rating: Partially Implemented eligibility determination; general education accommodations and services for ineligible students Department CPR Finding: A review of student records, staff and parent interviews indicate that the district has a practice of identifying limited English proficient (LEP) students as eligible for special education services and does not always determine if an LEP student’s lack of progress is the result of a disability or limited English proficiency. In addition, staff and parent interviews indicate that students are identified as eligible for special education services due to a lack of instruction in reading or mathematics. 8 Narrative Description of Corrective Action: The district has been administering the MEPA assessment with Spring 2009 scores listed on the DESE portal. The district will provide training to the special education staff and Building Base Assistance Team chairs in the examination of ELL testing information including MEPA results and levels, LAS and BSM scores prior to making a referral for a special education evaluation. If a student has a bilingual background or parents who speak a different language at home and this student has not be tested for ELL, a referral to ELL for testing should be made prior to any referral for a special education evaluation. An ELL teacher should be present at the Building Base Team meeting when a child who is or could be ELL is discussed. Training will be conducted for special education staff regarding eligibility determination for learning disabilities. In addition training in the use of the SLD determination form that is required by the state which will document the team’s determination that the students’ disability is not due to lack of instruction. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director, Corrective Action Activity: October 8, Principals 2010 Evidence of Completion of the Corrective Action: Training agenda and training attendance sheet Description of Internal Monitoring: The district will review Quarterly 25 district wide referrals for evaluation for students who have a bilingual background or parents who speak a different language at home and the accompanying Building Base Meeting attendance sheet for ELL teacher involvement. Rate of compliance will be submitted to the DESE An ongoing review will be conducted of initial and/or re-evaluations that have SLD as the eligibility determination to determine that the necessary documentation for SLD has been completed and team signatures attesting to the determination that the identify disability is not due to the lack of instruction. Rate of compliance between May 1 and June 30 will be submitted to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 9A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence of training (materials, agendas, signed attendance sheets) for all special education staff regarding eligibility determination procedures for limited English proficient students. Training will also include ensuring that students are not found eligible due to lack of instruction in reading or mathematics. By June 30, 2010, the district will conduct a district-wide internal review of referrals for the evaluation of students who are identified as LEP. Report the number of LEP students referred by level (elementary, middle, high school), the number of student records which indicate that a 9 decision has been made with regard to limited English proficiency or disability status, and indicate any corrective action taken to remedy noncompliance found. By June 30, 2010, conduct a second review of student records. Indicate the number of records reviewed, the number in which students were identified as eligible for special education services due to a lack of instruction in reading or mathematics and any corrective action taken to remedy noncompliance found. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 12 Frequency of reRating: Partially Implemented evaluation Department CPR Finding: A review of student records, and staff and parent interviews indicate that the district does not always conduct a re-evaluation every three years. Narrative Description of Corrective Action: The district will provide training to ETLs regarding evaluations and timelines for three year re-evaluations. ETLs will be sent a monthly listing beginning February, 2010 for the remainder of school year, and a complete year listing beginning September 2010 of all students due for a re-valuation. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: Education and ETLs October 8, 2010 Evidence of Completion of the Corrective Action: Training agenda and attendance sign in sheet. Description of Internal Monitoring Procedures: See SE 9 internal monitoring. The internal monitoring process listed for SE9 will be used for re-evaluations and compliance data will be sent to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 12 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence of staff training (agendas, signed attendance sheets, training materials) on the district’s procedures and requirements for conducting re-evaluations. By June 30, 2010, the district will submit the internal monitoring results from each school. 10 Report on the number of students that required re-evaluations since the training and the number of re-evaluations that were conducted within appropriate timeframes. Indicate specific corrective action taken for any non-compliance found. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 13 Progress Reports and Rating: Partially Implemented content Department CPR Finding: A review of student records, parent interviews and surveys indicate that progress reports do not always report on the student’s progress towards reaching the goals set forth in the IEP. The district does not routinely conduct Team meetings and review and revise IEPs when progress reports indicate that the student is not learning as expected, particularly at the elementary and high school levels. Narrative Description of Corrective Action: The district will provide training to special education staff on writing progress reports that reflect the student’s progress toward meeting IEP goals and holding Team meetings when progress reports indicate that the student is not learning Principals will be notified of this requirement via a Memo. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director Special Education, Corrective Action Activity: May 14, 2010 Principals Evidence of Completion of the Corrective Action: Training agenda and participant attendance sign in sheet and Memo to principals will be sent to the DESE. Description of Internal Monitoring Procedures:Quarterly analysis of the content of 10 progress reports from each building indicating student progress toward the IEP goal. Rate of compliance will be submitted to the DESE Procedures will be developed to ensure that IEP liaisons will write progress reports, review the reports with classroom teachers, and call a Team meeting if the student is not succeeding and make adjustments to the IEP if needed. The liaisons will attest that the progress reports have been reviewed with appropriate classroom teachers by signing a form indicating the students name, grade, and the teacher’s name and grade, and subject area. If the student is not making progress toward reaching the goals set forth in the IEP, a Team meeting will be held to review and revise, if appropriate the IEP. The form will be submitted to the Special Education Office quarterly with copies of the progress reports. 11 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 13 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit documentation of staff training (agendas, signed attendance sheets, training materials) on the district's procedures for progress report submission and content, as well as reconvening the Team when progress reports indicate that the student is not learning as expected. By June 30, 2010, the district will conduct two internal reviews at each building: Report on the number of student files reviewed for progress reports developed after the training, and the number of progress reports that included the student's progress towards the goals set forth in the IEP, and specific corrective action taken to remedy any non-compliance found. The district will also report on the number of students in each building whose progress reports indicated a lack of progress, and the number of these students who had Teams reconvened. Report any corrective action taken if non-compliance is identified to ensure that all student files reviewed are in full compliance. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 14 Review and revision of Rating: Partially Implemented IEPs Department CPR Finding: A review of student records, staff and parent interviews indicate that the district has a practice of not conducting annual review meetings and developing IEPs prior to the expiration of the former IEP. Narrative of Corrective Action: The district will provide training to staff who conduct annual review meetings regarding annual team meetings timelines.The special education staff will also be trained that update meetings are not annual reviews. Title/Role of Person(s) Responsible for Implementation: Special Education Director, ETLs, Special Education Teachers, and Principals Expected Date of Completion for Each Corrective Action Activity: October 8, 2010. 12 Evidence of Completion of the Corrective Action: Same as SE 9 Timeline Description of Internal Monitoring: A review of the district’s computerized listing of students’ annual review dates to ensure all students have a current IEP by the start of school. Rate of compliance will be sent to the DESE. Also See SE 22 monitoring CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 14 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence of training (agendas, signed attendance sheets, training materials) on the required IEP annual review timelines. By June 30, 2010, the district will conduct an internal review at each building. Report on the number of student files that had annual review meetings since the training, the number of student files that had proposed IEPs developed prior to the expiration date of the former IEP and any corrective action taken to ensure full compliance. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 18A IEP development and Rating: Partially Implemented content Department CPR Finding: A review of student records, staff and parent interviews indicate that the Team recommendations and proposed IEPs are changed at a higher administrative level within the district. Narrative Description of Corrective Action: A training session will be conducted for ETLs and special education teachers to assist with facilitating meeting, synthesizing information, dealing with different perspectives and clarifying IEP recommendations at the conclusion of the meeting. The district will develop a Summary of Team Meeting form that list recommended programs and services as well as placement. The parents will sign that they received their summary of the meeting and will be given a copy at the conclusion of the Team meeting Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: 0ctober 8, Education, special education providers, ETLs 2010 13 Evidence of Completion of the Corrective Action: Training agenda and attendance sheet Summary of Team Meeting form Description of Internal Monitoring Procedures: Review of 10 IEPs from each building to compare the service delivery grids with the Summary Team Meeting form information. Rate of compliance will be submitted to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 18A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s proposed internal review does not address the findings in this criterion. Department Order of Corrective Action: See Required Elements of Progress Reports. Required Elements of Progress Report(s): By April 15, 2010, the district will submit a signed statement of assurance from all ETLS and staff who serve as Team chairpersons, indicating that they have the authority to commit fiscal resources of the district. In addition, the district will submit evidence (agenda, signed attendance sheets) that all staff who chair Team meetings received training and are familiar with the responsibilities of the Team Chairperson role. Progress Report Due Date(s): April 15, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 18B Determination of Rating: Partially Implemented placement; provision of IEP to parent Department CPR Finding: A review of documentation, staff and parent interviews indicate that the district does not provide the parent with two copies of the proposed IEP and proposed placement along with the required notice immediately following the development of the IEP. Narrative Description of Corrective Action: The district has met this requirement. Two copies of the proposed IEP and Proposed placement and required notice is sent out to parents from the Special Education office following the development of the IEP and documented on the cover sheet sent to parents. A copy of that notice is placed in the student’s file. Additionally, the student’s file cover receives a sticker with the date the IEPS are sent. The district will also develop a Summary of Team meeting form that lists recommended programs and services, as well as placement for these services. Parents will sign that they received a copy of the summary. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director Corrective Action Activity: January 20, 2010 Evidence of Completion of the Corrective Action: An enclosure statement listing 2 IEPS is written on the cover sheet sent to parents with the IEPs. The dates parents are sent IEPs are put in the computer system and logged in the student folder with a sticker and date. 14 Description of Internal Monitoring Procedures: A quarterly review of 25 student files to ensure that the IEPs cover letters sent to parents indicate that two copies of the proposed IEP and proposed placement and required notices were sent to parents. Rate of compliance will be sent to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 18B Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): On January 22, 2010, the district submitted the revised N1 template letter to inform parents that two copies of the IEP have been enclosed. By April 15, 2010, submit documentation of staff training (agendas, signed attendance sheets, training materials) on requirements for determination of placement. Also submit the new Summary of Team Meeting form that lists recommended programs and services. By June 30, 2010, the district will conduct an internal review. Report the number of student files reviewed that had Team meetings held since the training, the number of files that included documentation that the parent received two copies of the proposed IEP and proposed placement along with the required notice immediately following the development of the IEP, and any specific corrective action taken to remedy non-compliance found. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 20 Least restrictive Rating: Partially Implemented program selected 15 Department CPR Finding: A review of student records, interviews and parent surveys indicate that the program selected is not the least restrictive environment for students, with consideration given to any potential harmful effect on the student or on the quality of services that he or she needs. The district has minimal academic supports for students in reading, as well as in content area classes. Non-Participation Justification Statements in the IEPs do not explain why the removal is considered critical to the student’s program and the basis for its conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. Staff report that placement decisions are determined by the administrator of special education and are based on the availability of placements, programs, services, and supports, not evaluation data and individual student needs. Narrative Description of Corrective Action: The district will continue to provide inclusion support with the use of resource room teachers and paraprofessionals when the team determines this is the least restrictive environment. Three reading interventionist and Title I math tutors have been hired. In addition to the reading and math support, the district continues to employ 104 paraprofessionals to aide support in content classes. See SE 1 Non –Participation Justification Statement-Training on discussion of why removal is considered critical to the student’s program and the basis for its conclusion that education of the student in a less restrictive environment. See SE 34, 43 and CR 34,18 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: October 8, Education 2010 Evidence of Completion of the Corrective Action: Training agenda and attendance sign in sheets Hiring notices of Reading Interventionist and Math Tutors Description of Internal Monitoring Procedures: An analysis of district wide special education staff and paraprofessionals schedules to determine inclusion support for content subject areas. Report to DESE percentage of content classes with support. See SE1 Placement decisions and least restrictive environment CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 20 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not address the issue that students are often not placed in the least restrictive environment and that consideration is not given to the quality of services that he or she needs as the district has minimal academic supports for students in reading, as well as in content area classes. Department Order of Corrective Action: Develop procedures for ensuring that students are placed in the least restrictive environment. Required Elements of Progress Report(s): By April 15, 2010, submit documentation of staff training (agendas, signed attendance sheets, training materials) on the least restrictive 16 environment and on writing IEP non-participation justification statements. Submit the procedures for staff to follow to ensure that students are placed in the least restrictive environment. Also submit evidence of the hiring of reading interventionists and math tutors. By June 30, 2010, submit the report of an internal review of student records for completion of non-participation justification statements. Include in the report the number of records reviewed in which IEPs were developed since the training, the number of records in compliance with this criterion and specific corrective action taken to remedy any non-compliance found. See also CR 18. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 22 IEP implementation and Rating: Partially Implemented availability Department CPR Finding: A review of student records, and staff and parent interviews indicate that the school district does not always provide the mutually agreed upon services without delay upon acceptance of the IEP by the parent, and the district does not have an IEP in effect at the beginning of the school year for each eligible student within its jurisdiction. Interviews indicate that not all teachers and providers described in the IEP are informed of their specific responsibilities related to the implementation of the student’s IEP and the specific accommodations, modifications, and supports that must be provided for the student under it. Interviews and parent surveys indicate that when related services are interrupted for extended periods of time the school district does not inform parents in writing of any delayed services, reasons for delay, actions that the school district is taking to address the lack of space or personnel or offer alternative methods to meet the goals on the accepted IEP. Nor does the district, upon agreement of the parents, implement alternative methods immediately until the lack of space or personnel issues are resolved. 17 Narrative Description of Corrective Action: The district will conduct training for special education staff and notify principals via Memo regarding the regulation in this section. Please see SE9 Please see SE 18B Development of Summary of Team Meeting to be given to parents. When the district has Rejected, partially rejected or unsigned IEPs over the summer months of school, the Bureau of Special Ed appeals will be notified and mediation requested when appropriate. Special Education staff will review with teachers and providers their specific responsibilities, student goals and accommodations. Teachers and providers will sign a form indicating that they were informed of the students’ needs and their specific responsibilities. This information will be sent to the Special Education office by September 30, 2010. This process is ongoing when new IEPs are accepted by parents. This citation has been met. The Associate Special Education Director sent a letter to inform parents of a delay in services, reasons for the delay, the actions the school district is taking to remedy the situation, and alternative methods that can be implemented until the lack of personnel can be resolved. This process will continue if related services are interrupted in the future. Documentation will be forward to the DESE Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special education director, Corrective Action Activity: October 8, Special Education staff, Principals 2010 Evidence of Completion of the Corrective Action: Training agenda and participant sign in for attendance. Summary of Team Meeting Form Copies of letters sent to parents from the Bureau of Special Education Appeals. Form for verification that teachers and providers were informed of their responsibilities and the students’ needs. Copy of Letter sent to parents regarding delay in services. Description of Internal Monitoring Procedures: Quarterly review of 10 IEPs from each building to review Non-Participation Justification Statement and its basis for conclusion that the student is in the least restrictive environment. Rate of compliance will be sent to the DESE. An analysis of unsigned IEPs prior to the beginning of the school year will be conducted. A letter will be sent to the parents indicating that the student has an unsigned IEP and requesting that the IEP be signed by August 1 so that the new IEP can be implemented at the beginning of the school year. By August 15 all unsigned IEPs will be treated as rejected IEPs and sent to the BSEA. Number of unsigned IEPs by September 10, will be reported to the DESE. The special education office will maintain a list of all in- district special education students and the service providers working with the students. Service providers will sign off that they reviewed and understood their responsibilities regarding the student’s IEP. 18 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 22 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): On January 22, 2010, the district submitted sample notices sent to parents informing them that speech services had been interrupted. These notices informed parents of the delay in services, the reasons for delay, actions that the school district is taking to address the lack of personnel and offered alternative methods to meet the goals on the accepted IEP. By April 15, 2010, submit a copy of the district protocol/procedures staff will implement when the district does not have an IEP in effect at the beginning of the school year for each eligible student within its jurisdiction and district protocol/procedures for principals and ETLs to follow when services have been interrupted. Submit evidence (agendas, signed attendance sheets) that training has been conducted on these procedures. By October 1, 2010, the district will conduct an internal review by building. Report the number of teachers by building that have students on IEPs, the number of teachers who signed the district form indicating that they were informed of their specific responsibilities related to the implementation of the student’s IEP and corrective action taken to remedy any noncompliance found. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 24 Notice to parent Rating: Partially Implemented regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Department CPR Finding: A review of student records indicates that across all levels the district’s Notices of Proposed School District Action (N1) are not comprehensive and do not meet all of the content requirements set forth in M.G.L. c.71B, §3, and in federal law. Narrative Description of Corrective Action: The district will provide training to special education providers on how to write comprehensive Notices of Proposed District Action (N1) that meet all of the regulatory content requirements. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: May 21, 2010 Education 19 Evidence of Completion of the Corrective Action: Training agenda and attendance sign in Description of Internal Monitoring Procedures: An analysis will be conducted of 10 IEPs from each school between the dates of March 15 and May 1, 2010 to ensure that a N1 is included with the IEP and the N1 meets the regulatory requirements. Rate of compliance will be submitted to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 24 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit evidence (agendas, signed attendance, training materials) that training has been provided to special education staff on how to write comprehensive Notices of Proposed District Action (N1) forms that meet all of the regulatory content requirements. By June 30, 2010, the district will conduct an internal review and report on the number of student records reviewed by building, the number of that contained comprehensive N1 notices that meet all of the regulatory content requirements and any specific corrective action taken to remedy any non-compliance found. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 29 Communications are in Rating: Partially Implemented English and primary language of home Department CPR Finding: A review of documentation, student records and interviews indicate that limited communications are translated into Spanish only, and not any other languages spoken in the district. The district also uses interpreters who are not always familiar with special education procedures, programs and services. If the district provides notices orally or in some other mode of communication that is not written language, the district does not consistently document (1) that it has provided such notice in an alternate manner, (2) of the content of the notice, and (3) the steps taken to ensure that the parent understands the content of the notice. 20 Narrative Description of Corrective Action: The district provides interpreters for Spanish which is a major language in the school district. The district contracts with agencies, and utilizes the language departments of several area colleges for translations in non-major languages. The district will develop a list of available interpreters for languages other than Spanish. Interpreters will be asked to review the special education regulations, procedures, and programs and services, prior to their involvement in a Team Meeting., Upon contracting, interpreters will acknowledge in writing that the special education regulations, procedures and programs and services have been reviewed. The district will send a memo to school principals, health coordinator, 504 coordinator, and the early childhood regarding the need for documentation when notices are provided orally or in some other mode of communication that is not written language. The documentation will include what notice was provided in an alternative manner, content of notice and the steps taken to ensure the parent understands the content of the notice. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director, Corrective Action Activity: May 21, 2010 Principals, Coordinators Evidence of Completion of the Corrective Action: List of available interpreters for languages other than SpanishVerification form that interpreter has reviewed the special education regulations, procedures, and programs and services prior to translating for the district.Memo to principals and coordinators Description of Internal Monitoring Procedures: Quarterly review of 10 district wide contracts for interpreters with attached verification form that the interpreter has review the special education regulations, procedures, and programs and services. Rate of compliance submitted to the DESE On a monthly basis the building principals will send to the special ed office documentation of notices provided in an alternative manner, listing that provided such notice in an alternate manner, the content of the notice, and the steps taken to ensure that parents understood the content of the notice. A listing by building, of the notices provided to parents will be sent to the DESE CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 29 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, submit the list of interpreters for languages other than Spanish. By June 30, 2010, submit the results of an internal review that includes the number of parents who have requested information be translated, the number of parents who received translated information, and corrective action taken to remedy any non-compliance found. 21 The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 34 Continuum of alternative Rating: Partially Implemented services and placements Department CPR Finding: A review of documentation, student records, staff and parent interviews and parent surveys indicate that there are several gaps in the continuum that prevent the district from providing supports and services to special needs students. The district lacks co-teaching, inclusion and resource room support options at all levels. The district is also in need of reading and behavioral therapeutic supports for special education students at all levels. In addition, Teams do not routinely consider or discuss students’ vocational needs, services or vocational opportunities at the high school level when developing IEPs because the district does not have vocational services or vocational opportunities for students who have been denied admission into the local vocational school. Narrative Description of Corrective Action: Please see SE 20 Reading and Math, SE 43 Behavior The district does provide a continuum of alternative services and placements by contracting with agencies and district staff who provide job internships, work study and life skills programs. The school district has career days at the high school and some students are attending community college classes. The district will provide training to high school special education staff regarding the development of transition plans and what vocational opportunities are available to meet post secondary educational goals. The high school special education staff will be notified that a statement in the additional information portion of the IEP must indicate that vocational opportunities were discussed. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: October 8, Education 2010 Evidence of Completion of the Corrective Action: Training agenda and sign in , List of contracted agencies that provide a continuum of alternative services and placements Description of Internal Monitoring Procedures: Review quarterly 10 high school IEPs for documentation in additional information that vocational opportunities were discussed. Rate of compliance will be reported to the DESE 22 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 34 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: While the district indicated that it does have a continuum of alternative services and placements, the district did not provide evidence supporting this claim. This finding specifically includes inclusion, co-teaching and resource room supports, as well as behavioral therapeutic supports. Department Order of Corrective Action: Develop a continuum that includes co-teaching, inclusion and resource room supports, as well as behavioral therapeutic supports. Required Elements of Progress Report(s): By April 15, 2010, indicate the steps to be taken by the district to ensure that a continuum of supports is available that includes co-teaching, resource room, inclusion and behavioral therapeutic supports. Submit evidence of staff training at the high school on ensuring that Teams routinely consider or discuss students’ vocational needs, services or vocational opportunities when developing IEPs, as well as the vocational services or vocational opportunities provided to students who have been denied admission into the local vocational school. By June 30, 2010, submit the results of an internal review conducted at the high school. Indicate the number of records reviewed, the number that indicated that the Teams considered or discussed the student’s vocational needs, and steps taken to remedy any non-compliance found. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review, with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 43 Behavioral Interventions Rating: Partially Implemented Department CPR Finding: A review of student records indicates that IEP Teams do not routinely identify and include behavioral supports or services in IEPs when developing IEPs for students whose behaviors impede their learning or the learning of others. Teachers and parents report that students who have ongoing behavioral needs do not have positive behavioral interventions and the district does not conduct functional behavioral assessments within appropriate timeframes. 23 Narrative Description of Corrective Action: The district does identify and include behavioral supports or services in the IEP for students whose behaviors impede their learning or the learning of others, however, not consistently. Few behavioral plans are written for these students. The district contracts with behavioral specialist and has school psychologist on staff. The district will provide training on positive behavioral interventions and writing behavior plans. Behavior Plans will be required for all students entering or who are in behavior programs. The district will conduct training as to FBA timeframes. The district will require that the Special Education office be notified when an FBA is requested. The district employs a computerized IEP system that tracks permission for evaluations. See SE9 and SE12 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special education Corrective Action Activity: director,ETL, special education teachers October 8, 2010 Evidence of Completion of the Corrective Action: Training agenda and participant attendance Description of Internal Monitoring Procedures: The district will conduct an analysis from September 15-October 15 of goals and benchmarks listed in IEPs regarding behavioral supports. Data from the review will be submitted to the DESE The district will be notified when an FBA is requested and will track permission for evaluation, Parent consent and the FBA review date for compliance of appropriate timelines. Quarterly review of timelines for all district FBA will be conducted. Rate of compliance will be sent to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 43 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, the district will submit procedures for conducting FBAs. By April 15, 2010, submit documentation of staff training (agendas, signed attendance sheets, training materials) on positive behavioral interventions, writing behavior plans and conducting FBAs. By June 30, 2010, conduct an internal review and report on the number of students at each building who have been identified with social, emotional and behavioral needs, the number of students with appropriate behavioral supports identified, as needed, on the IEP and specific corrective action taken to remedy any non-compliance found. Maintain the following documentation and make it available to the Department upon request: 24 list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 53 Use of Rating: Partially Implemented paraprofessionals Department CPR Finding: Staff interviews indicate that paraprofessionals are not supervised by an appropriately certified or licensed professional who is proximate and readily available to provide such supervision in all schools. Narrative Description of Corrective Action: The district has a list, by building, of the names of all the paraprofessionals and the supervising professional for each paraprofessional. The list will be given to the building principals and the principals will be responsible for informing the paraprofessionals and the supervising professional staff members and the principals will also inform the supervising professionals of their duties associated with this responsibility. Documentation that both the paraprofessional and supervising professional were informed will be provided by the school principal and will be sent to the Special Education Office. The list will be kept in both the Special Education Office and with the building principals. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special education director Corrective Action Activity: May 13, 2010 and building principals Evidence of Completion of the Corrective Action: Memo to principals. List of building paraprofessionals and supervising professional. Verification (initials, signatures) of those who were informed. Memo and verification will be sent to DESE with compliance rate. Description of Internal Monitoring Procedures: By September 30 each building principal will have informed paraprofessional and supervising professional staff as to there assignments. Both the paraprofessional and supervising professional will indicate they were informed by signing or initialing their name. The information will be sent to the special education office for a compliance review. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 53 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: 25 Required Elements of Progress Report(s): By April 15, 2010, the district will conduct an internal review for this criterion. Report on the number of special education paraprofessionals in each building identifying the supervising certified teacher responsible for their daily supervision, and report the number of the supervising teachers who hold current certifications/ licenses or waivers for their current grade level for which they are working. Report any specific corrective action taken to remedy any non-compliance found. Progress Report Due Date(s): April 15, 2010 26 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Northampton Public School District Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Nathan Ziegler/Rose Carr 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: November 22, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7 Information to be Rating: Partially Implemented translated into languages other than English Department CPR Finding: A review of documentation and interviews indicate that the district has a limited amount of important information and documents, e.g. handbooks and codes of conduct, translated into Spanish but not other major languages spoken by parents or guardians with limited English skills. Narrative Description of Corrective Action: The district provides most important documents in Spanish but not all. Extra curricular activities and weekly parent newsletters are not translated often. There is no other major language in the district. However, the district contracts with an agency or arranges with area college language departments to provide translations and/or translators when other languages need to be translated. The district will translate newsletters, notices for extracurricular activities, other school notices and documents in other non-major languages used in the district when needed.See SE 29 Memos to Principals, Coordinators List of translators Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: October 8, Education, Principals, Coordinators. 2010 Evidence of Completion of the Corrective Action: List of interpreters See SE 29, Memo to Principals and Coordinators, 27 Description of Internal Monitoring Procedures: The building principals and coordinators will be sent a memo to forward all translated notices to the special education office on a monthly basis when translations are provided in a non-major language. A quarterly review of all contracts for translations /translators for non-major languages will be conducted. The number, name of the language, and listing of the documents/notices translated in other nonmajor languages will be submitted to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7 Information to be Status of Corrective Action: Approved Partially Approved Disapproved translated into languages other than English Basis for Partial Approval or Disapproval: The district did not indicate how it will inform parents that information can be translated upon request. Department Order of Corrective Action: Develop a plan of action detailing how the district will inform parents of their right to have information translated. Required Elements of Progress Report(s): By April 15, 2010, the district will submit a plan of action detailing how it will inform parents of their right to have information translated. The district will also submit a list of interpreters and translators for the top three high-frequency languages within the district. By October 1, 2010, submit copies of documents (handbooks and codes of conduct), as well as other information and notifications (weekly parent newsletters, extracurricular activities) that have been translated for parents. Submit this information in English and in translation. Progress Report Due Date(s): April 15, 2010 & October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7A School year Rating: Partially Implemented schedules Department CPR Finding: A review of documentation indicates that the Bridge Street Elementary School is not scheduled for 900 hours of structured learning time each school year. Narrative Description of Corrective Action: This criterion has been met. The school day has been adjusted to meet the 900 hours of structured learning time for the 2009-2010 school year as evidenced in the school calendar.. Documentation will be submitted for this criterion January 20, 2010 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal Corrective Action Activity: September 5, 2009 Evidence of Completion of the Corrective Action: School calendars and school notices Description of Internal Monitoring Procedures: N/A 28 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): On January 22, 2010, the district submitted the following documentation: copies of letters sent to parents and a copy of the revised Bridge Street Elementary School schedule for 2009-2010, evidencing that the school meets the required 900 hours of structured learning time. Progress Report Due Date(s): No further progress reports are required COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7C Early release of high Rating: Partially Implemented school seniors Department CPR Finding: A review of documentation indicates that the seniors’ graduation is more than 12 school days before the regular scheduled closing date of the school. Narrative Description of Corrective Action: This criterion has been met. The high school graduation date has been changed with the new school year. Documentation to meet this criterion will be submitted to the DESE January 20, 2010 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: High School Principal Corrective Action Activity: September 5, 2009 Evidence of Completion of the Corrective Action: School calendar and notices Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7C Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): On January 22, 2010, the district submitted a revised school calendar for the 2009-2010 school year evidencing that graduation is less than 12 school days before the regular scheduled closing date of school. Progress Report Due Date(s): No further progress reports are required 29 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 9 Hiring and Rating: Partially Implemented employment practices of prospective employers of students Department CPR Finding: A review of documentation and staff interviews indicate that the district does not procure signed statements from employers of job internships, work study and life skills programs in the community ensuring that they comply with applicable federal and state laws prohibiting discrimination in hiring and employment practices. Narrative Description of Corrective Action: The district will provide a statement that compliance with federal and state laws prohibiting discrimination in hiring and employment practices to the district’s contracts or agreements with employers of job internships, work study and life skills program with an understanding that the employers signed contract verifies that federal and state laws are followed. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director Corrective Action Activity: May 21, 2010 Evidence of Completion of the Corrective Action: Copy of contract with statement Description of Internal Monitoring Procedures: Quarterly review of 10 district-wide contracts to ensure compliance of language regarding federal and state laws prohibiting discrimination in hiring and employment practices verified by contractor/ employers signature. Rate of compliance will be submitted to the DESE CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 9 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, submit the revised statement that prospective employers of students will sign. By June 30, 2010, the district will conduct an internal review. Report on the number of employers of students, the number of statements that have been signed by the employers and any corrective action taken to ensure full compliance with this criterion. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 10A Student handbooks Rating: Partially Implemented and codes of conduct 30 Department CPR Finding: A review of documentation and interviews indicate that all student handbooks omit discipline procedures for students on Section 504 Accommodation Plans and discipline procedures for students not yet determined eligible for special education. Codes of conduct, suspension, expulsion and due process procedures are not translated into any high frequency languages other than Spanish. Narrative Description of Corrective Action: Discipline procedures for students on Section 504 Accommodation Plan, and discipline procedures for students not yet determined eligible for special education will be added to all student handbooks. Other findings have been accepted as Implemented by the DESE Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director, Corrective Action Activity: January 20, 504 Coordinator 2010 Evidence of Completion of the Corrective Action: Copies of the procedures Description of Internal Monitoring Procedures: Each building principals will submit the school handbook to the Special Education Director for review of the discipline procedures for students on a 504 Accommodation Plan and procedures for students not yet determined eligible for special education. Compliance rate will be submitted to the DESE with copy of procedures. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 10A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not propose a plan of action to ensure that codes of conduct, suspension, expulsion and due process procedures are translated into languages other than Spanish and English. Department Order of Corrective Action: See CR 7 with regard to the translation of codes of conduct, suspension, expulsion and due process procedures. Ensure that translations are provided in languages other than Spanish. Required Elements of Progress Report(s): By April 15, 2010, submit copies of the procedures to be included in the student handbooks with regard to the discipline of students on Section 504 Accommodation Plans and the disciplinary procedures for students not yet determined eligible for special education. By October 1, 2010, submit copies of the 2010-2011 student handbooks and the code of conduct (in English and in translation). Progress Report Due Date(s): April 15, 2010 & October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 13 Availability of Rating: Partially Implemented information and academic counseling on general curricular and occupational/vocational 31 opportunities Department CPR Finding: A review of documentation indicates that the district has information and academic counseling on general curricular opportunities available in English only, which limits the availability of this information to limited English proficient students. Narrative Description of Corrective Action: The district will translate academic counseling for general curricular opportunities in Spanish and when needed in other non-major languages. See SE 29 and CR 7. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: Education, Principals, Coordinators October 8, 2010 Evidence of Completion of the Corrective Action: Memo to principals and coordinators, list of translated material from the school Description of Internal Monitoring Procedures: See CR 7 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 13 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit copies of the translated academic counseling information for general curricular opportunities. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 14 Counseling and Rating: Partially Implemented counseling materials free from bias and stereotypes Department CPR Finding: A review of documentation indicates that the district has counseling materials, such as the Mental Health Resource Guide, available in English only. Limited English proficient students are not provided with the opportunity to receive guidance and counseling services or materials in a language they understand. Narrative Description of Corrective Action: The district does provide a Mental Health Resource Guide in Spanish. This will be submitted to the DESE January 20, 2010 The district will provide guidance and counseling materials in Spanish and when needed in other non-major languages. The district will instruct the schools’ guidance departments and school psychologist in documenting counseling sessions that are in languages other than English. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director, Corrective Action Activity: May 21, 2010 Principals 32 Evidence of Completion of the Corrective Action: Meeting agenda for guidance department and school psychologist and sign in. Memos to all principals, and school guidance and psychologists Description of Internal Monitoring Procedures: On a quarterly basis, the school guidance and psychologist will forward to the special education office a list of students by SAAID # that received counseling in a language other than English, and what language was used in the counseling session. The list will be submitted to the DESE for compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 14 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By June 30, 2010, the district will submit a list of guidance/counselor service providers it could access if needed in order to provide guidance and counseling services to limited English proficient students. In addition, the district will submit the number of students that receive guidance and counseling services in languages other than English, including the language used in the counseling session(s). Progress Report Due Date(s): June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 17A Use of physical Rating: Partially Implemented restraint on any student enrolled in a publiclyfunded education program Department CPR Finding: A review of documentation and staff interviews indicate that the district does not consistently implement staff training on the use of physical restraint for employees hired after the school year begins, within a month of their employment. In addition, at the alternative program, staff are not trained on the use of physical restraint and are unable to identify staff who have completed the in–depth training. Narrative Description of Corrective Action: The district will continue to provide training to all staff who were hired after the school year begins, within a month of their employment. All staff at the alternative program will be trained in physical restraint. Principals will keep a list of all staff who received in-depth training and will disseminate this information to school personnel. The district is investigating a Train a Trainer program so some staff member would be certified restraint trainers. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director, Corrective Action Activity: October 8, Principals 2009 Evidence of Completion of the Corrective Action: Training agenda and attendance sign in 33 Description of Internal Monitoring Procedures: On a quarterly basis a review of a list of all new staff members and new staff of alternative programs, with dates of employment will be conducted to determine if physical restraint training has occurred within the first month of employment. Rate of compliance will be submitted to the DESE CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 17A Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By June 30, 2010, submit evidence that restraint training has been conducted for all employees hired after the start of the school year and evidence that staff at the alternative program have also received training on the use of physical restraint. Progress Report Due Date(s): June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 18 Responsibilities of the Rating: Partially Implemented school principal Department CPR Finding: A review of documents and interviews indicate that due to limited resources principals have been unable to implement the curriculum accommodation plan developed by the district’s general education program to ensure that all efforts have been made to meet the needs of diverse learners in the general education program. Instructional supports, including remedial reading instruction at the elementary levels, consultative services for teachers, and appropriate services for linguistic minority students, are very limited and are unavailable in most schools in the district. The district submitted documentation indicating that professional development was provided in the areas of differentiated instruction and response to intervention. However, interviews indicate that regular classroom teachers do not analyze and accommodate the diverse learning styles of all children in the regular classroom and cannot provide appropriate services and supports within the general education program including, but not limited to, direct and systematic instruction in reading and provision of services to address the needs of children whose behaviors may interfere with learning. Teacher mentoring and collaboration opportunities are severely limited. Lastly, when students are referred for an evaluation to determine eligibility for special education, the principals do not ensure that documentation on the use of instructional support services for the student is provided as part of the evaluation information reviewed by the Team when determining eligibility. 34 Narrative Description of Corrective Action: The district will provide training regarding Building Base Assistance Team procedures that include appropriate documentation of interventions and use of the District Curriculum Accommodation Plan by the general education program before a student is referred for special education services. Continued staff training in Differentiated Instruction See SE 20 Reading Interventionist and Math Tutors See SE 34 Behavior Interventions Principals will review Building Base Team procedures regarding documentation on the use of instructional support services for the student when determining eligibility. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Special Education Director, Corrective Action Activity: Principals, November 19, 2010 Evidence of Completion of the Corrective Action: Training agenda and sign in sheets , procedures Description of Internal Monitoring Procedures: A quarterly review of 10 referrals for special education from each school with accompanying Building Base Team forms indicating a consideration was given to the District Curriculum Accommodation Plan and general education services before the referral was made. Rate of compliance will be submitted to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 18 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By April 15, 2010, submit evidence (materials, agendas, signed attendance sheets) that principals received training in the following areas: the district’s curriculum accommodation plan, their responsibilities to ensure that all efforts have been made to meet the needs of diverse learners in the general education program, and how to document these efforts. In addition, principals will submit a description of their teacher mentoring and collaboration opportunities in their buildings. By June 30, 2010, submit the results of an internal review that has been conducted at each building. Report on the number of referrals for special education from each school, and the number of those referrals that contained documented Building Based Team supports and services to ensure that all efforts have been made to provide instructional supports, including remedial reading instruction and consultative services, and report on any corrective action taken to remedy the non-compliance found. Progress Report Due Date(s): April 15, 2010 & June 30, 2010 35 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Northampton Public School District Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Jack Kelley 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: November 22, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 3 Initial Identification Rating: Partially Implemented Department CPR Finding: A review of documents, student records and interviews indicate that the district does not identify students in a timely manner. Assessments for initial identification may be delayed as the district conducts screening prior to assessments. Narrative Description of Corrective Action: The district has procedures to ensure that suspected ELL students are tested in a timely manner as well the tests that should be used to make the determination. The testing procedures were inconsistently followed at the high school level. The procedures were followed at the elementary and middle school level but documentation was not kept. Training and informational meetings have already occurred with the ELL staff and with the building principals as to the tests the districts requires and the timelines that are acceptable. All schools now have the correct testing materials or those materials have been ordered. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: May 21, 2010 Designee, Building Principals 36 Evidence of Completion of the Corrective Action: Testing and timeline data will be collected and sent to the DESE. The district has a computerized data sheet which allows for a variety of information about ELL students to be recorded. It needs to be updated to include new areas or changes that have occurred in the regulations. That process has already started. The data has been inconsistently entered. The data documenting a 3 month period starting February 1, 2010 to May 1, 2010 of students who have been suspected of needing ELL services and were tested will be collected. The date they entered the district, the date they were tested and the results of that testing will be collected and recorded on a data sheet and will be submitted to the Office of Pupil Services. The information will then be entered into the data base. The data sheet will be printed out and sent to the DESE by May 21, 2010. A list of tests used by the district to determine eligibility and level of need will be submitted to DESE by May 21. Internal Monitoring: The date of entrance of possible ELL students and the date they were tested will be submitted to the Office of Pupil Services and entered into the data base. Each March 1st and October 1st the data will be reviewed by the Director to ensure timelines are being followed. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 3 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By June 30, 2010, the district will submit the procedures for the timely assessment and identification of LEP students and evidence (materials, agendas, signed attendance sheets) of training on these procedures. The district will also submit a list of tests used for identifying students as LEP. By October 1, 2010, the district will conduct an internal review of the identification timelines and tracking data. Report the date of entrance of possible ELL students and the date they were tested. If non-compliance is found, indicate the corrective action taken with regard to each student. Progress Report Due Date(s): June 30, 2010, October 1, 2010 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 37 Department CPR Finding: Sheltered English immersion (SEI) is a program model for limited English proficient (LEP) students composed of two parts—English as a second language (ESL) and sheltered content instruction. ESL is explicit, direct instruction about the English language, delivered to LEP students only and designed to promote the English language development of LEP students. Sheltered content instruction is an approach for teaching content to LEP students in strategic ways that make the subject matter concepts comprehensible while promoting the LEP students’ English language development. The Northampton Public Schools serves English Language Learners (ELL) through a Sheltered English Immersion (SEI) model. Based on documentation submitted, direct ESL instruction in these programs does not meet the recommended number of hours as outlined in the Department’s guidance document on this topic issued in June 2005. It appears as though only the high school meets the recommended hours for Beginner and Early Intermediate ELLs, but not for Intermediate ELLs who appear to get no direct ESL instruction. The district indicated that ESL instruction is based on the English Language Proficiency Benchmarks and Outcomes (ELPBO) at the middle school, but also indicated that it does not have an ESL curriculum. Programs at the various grade levels (elementary, middle and high school) appear to differ substantially as indicated by the district’s documentation. Narrative Description of Corrective Action: Response to ELE 5 Issue # 1: The district has already collected the number of hours of service being provided to each ELL student in the entire district and the classification given to each student. Because the DESE has gone to a new “Level System” some of our ELL students still have a designation of “Beginner, Intermediate, etc.” The students who took the MEPA last Spring have the new Level designations. The level information is important because it dictates the number of hours of service that must be given to a student. The data that has been collected but still needs to be analyzed. All students must be given a level classification Issue #2: The English Language Proficiency Benchmarks and Outcomes have been used at the elementary and middle school levels but not at the high school. The district is aware of the ESL curriculum requirement and is working toward implementing it. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: October 8, the Superintendent’s Designee & Building 2010 Principals Evidence of Completion of the Corrective Action: Issue # 1: The district will submit a data sheet which will provide the statistical information the DESE is requesting for the district to meet this standard. Issue 2: The district will conduct an evaluation of the ESL instruction that is being offered at each level (elementary, middle school, and high school) to determine whether instruction is based on ELPBO and / or ESL requirements and to determine if the instruction offered meets the requirements of this standard and is consistent and coordinated at each level. The evaluation report will be submitted to DESE along with an analysis of the report and the actions taken by the district. 38 Description of Internal Monitoring Procedures: Internal Monitoring # 1: The district data base statistical information will be reviewed each year by the Director of Pupil Services or the Superintendent’s Designee and the building principal by September 30 of each school year to ensure that ELL students are receiving the amount of direct instruction as required by regulation. The statistical information will include each student’s name, level and actual number of hours of direct ELL service. .Internal Monitoring #2: The Director of Pupil Services or Superintendent’s Designee will receive a written report by September 30 of each school year from each ELL teacher (which has been approved and signed by their building principal) which assures that this standard is being met. Training records will be kept and reviewed yearly. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 5 Approved X Partially Approved Disapproved Basis for Partial Approval or Disapproval: Even though the level system for MEPA classification has changed, in terms of ESL instruction, this has only affected the formerly transitioning students, now Levels 4 and 5, who now need 2.5 hours per week of direct ESL instruction. This should not impede the district’s ability to plan and deliver the recommended hours of ESL instruction. Department Order of Corrective Action: The district must furnish to ESE a spreadsheet listing every ELL student outlining each ELL by grade and proficiency level and the number of hours of direct ESL instruction. This spreadsheet should demonstrate that all ELLs receive the recommended number of hours of direct ESL. The district must demonstrate that it has made substantial progress towards the production and implementation of a district-wide curriculum for its ELLs. Required Elements of Progress Report(s): By October 1, 2010, submit the spreadsheet referenced above. Please also submit both a district-wide ESL Curriculum (in draft form if necessary) based on the ELPBO along with curriculum maps from each grade span outlined in the ELPBO demonstrating the implementation of the district’s ESL curriculum. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 6 Program Exit and Rating: Partially Implemented Readiness Department CPR Finding: Instead of submitting the required Exiting and Redesignation policy, the district submitted a description of how it identifies new and incoming ELLs. Narrative Description of Corrective Action: The district will review and revise its’ Exiting and Redesignation procedures / policy and submit it to the DESE with evidence of staff training regarding the implementation. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: May 21, 2010 the Superintendent’s Designee 39 Evidence of Completion of the Corrective Action: Exiting and Redesignation criteria will be developed and put in writing. A policy and procedures will be developed by the district to meet this standard. The policy and procedures will be distributed to ELL staff and to building principals. Training will be provided to staff. The procedures and training agendas will be submitted to the DESE. Description of Internal Monitoring Procedures: Exiting and Redesignation of students in the ELL program will be tracked and reviewed by the Director of Pupil Services or Superintendent’s Designee and the building principals. ** The Director or Designee will develop Exiting and Redesignation procedures and arrange for staff to be trained. Policy and procedures and training agendas will be submitted to the DESE by May 21, 2010. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 6 Status of Corrective Action: X Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit appropriate policies for redesignating students from LEP to FLEP to DESE. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 7 Parent Involvement Rating: Partially Implemented Department CPR Finding: A review of documentation and interviews indicate that the district has not developed ways to include parents or guardians of LEP students in matters pertaining to their children’s education. Narrative Description of Corrective Action: The staff has used a variety of methods to involve parents of ELL students in their children’s education. They have examples of parent involvement, but no documentation. The district will develop a list of actions and activities that involved parents of ELE students. Data will also be included which will record the attempts which were made to involve parents. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Building Principals Corrective Action Activity: May 21, 2010 Evidence of Completion of the Corrective Action: Collect data of activities involving ELL parents and also the attempts made to involve parents for a 3 month period starting February 1, 2010 to May 1, 2010 and submit that data to the DESE by May 21, 2010. 40 Description of Internal Monitoring Procedures: Building principals will require ELL staff to document efforts to include parents in the school environment and activities and will review those efforts twice a year. The principals have been asked to have a folder in which all examples of the efforts made to contact ELL parents either in writing or by phone about activities and the number of parents who then actually attended the events. ** Building principals will be responsible for collecting this data and submitting it to the Director of Pupil Services or SD prior to May 21, 2010. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 7 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By June 30, 2010, the district will submit documentation from building principals evidencing activities and ways to include parents or guardians of LEP students in matters pertaining to their children’s education. Submit copies of translated notices sent to parents inviting them to meetings, such as school-based council meetings and parent-teacher meetings. Progress Report Due Date(s): June 30, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 8 Declining Entry to a Rating: Partially Implemented Program Department CPR Finding: A review of documents and interviews indicate that the district does not provide English language support to students whose parents have declined entry to a sheltered English immersion program. Narrative Description of Corrective Action: The district will compose a list of students whose parents have declined entry into the SEI program for the 2009 – 2010 school year and the support that has been provided to those students will be documented. The procedures for providing the support to these students and a listing of the types of support that should be offered will be developed. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: Superintendent’s Designee October 8, 2010 Evidence of Completion of the Corrective Action: The data collected which will include the names of students whose parents have declined entry into the SEI program, grade level, school, date services were declined and the support services which were then implemented will be sent to the DESE. The procedures which the ELL staff will follow in such circumstances will be submitted to the DESE along with documentation of training provided to the ELL staff. 41 Description of Internal Monitoring Procedures: A list of students whose parents have declined services will be kept by the building principals and the services provided to those students will be indicated. The list will be sent to the Office of Pupil Services every June 1st. ** Building Principals will collect required data. **Director of Pupil Services or the Superintendent’s Designee will develop the form and will arrange staff training. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 8 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit district procedures, evidence of training, and a list/description of supports provided to those students whose parents have declined entry into the ELL program. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 9 Instructional Grouping Rating: Partially Implemented Department CPR Finding: Documentation indicates that students are not receiving effective content instruction and in the required amounts (see ELE 5 and ELE 15). Only at the middle school is instruction based on the ELPBO, and the district currently has no ESL curriculum (see ELE 5). Narrative Description of Corrective Action: The district will document the type of instruction being provided to ELL students, the name(s) of the staff providing that instruction and the training levels of the staff. An ESL curriculum will be developed and implemented and the curriculum will be submitted to the DESE. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: Superintendent’s Designee, Building Principals November 19, 2010 Evidence of Completion of the Corrective Action: The ESL curriculum used by the district will be submitted. A list of staff providing instruction to ELL students and the qualifications of the staff will be submitted to the DESE. Inservice training agendas will be sent to the DESE as part of this documentation. Description of Internal Monitoring Procedures: A list of staff providing services to the ELL students will be compiled along with past training and needed training. A training plan will be developed and will be reviewed by building principals and the director to determine progress. The building principals will ensure that ELL students are placed with teachers who are trained or who are presently enrolled in a training program. 42 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 9 Status of Corrective Action: X Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit both a district-wide ESL Curriculum (in draft form if necessary) based on the ELPBO along with curriculum maps from each grade span outlined in the ELPBO demonstrating the implementation of the district’s ESL curriculum. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 10 Parental Notification Department CPR Finding: A review of documents and interviews indicate that the district does not have a parental notification letter. Narrative Description of Corrective Action: The district does have a parent notification letter. However, it has not been used consistently by all ELL staff. The letter will be reviewed and may need to be revised. Training will be provided to the ELL staff. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: Designee May 21, 2010 Evidence of Completion of the Corrective Action: A copy of the district’s parental notification letter will be provided to the DESE along with copies that have been sent to parents. Submit all documentation for this standard by May 21, 2010 including the district’s letter and copies of the letters sent to parents this school year. Description of Internal Monitoring Procedures: Parental notification letters will be sent to parents from the service providing school. The district will send the yearly notification letters along with the Spring MEPA scores (which are sent to district’s by the DESE in September) to parents in September of each year. Many district’s use this same approach as the MEPA report card is a reminder that the notification letter also needs to be sent. A copy of each letter sent and the student MEPA reports will be submitted to the Office of Pupil Services. All ELL student files will be kept at the Office of Pupil Services. The records will be reviewed once a year to ensure that all forms and requirements are being met. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 10 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By June 30, 2010, the district will submit a parent 43 notification letter template in both English and Spanish that contains all required information. By October 1, 2010, submit the results of an internal review indicating the number of ELL records reviewed, the number which indicate that the parent notification letter has been sent out annually and any corrective action for non-compliance found. Progress Report Due Date(s): June 30, 2010, October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal Access to Rating: Partially Implemented Academic Programs and Services Department CPR Finding: The district did not submit its own documentation for this criterion; the documentation submitted refers to another school district. A review of documents and interviews indicate that the district does not ensure that LEP students have the opportunity to receive support services, such as guidance and counseling, in a language that the student understands. The district does not ensure that LEP students are taught to the same academic standards and curriculum as all students, and does not provide the same opportunities to master such standards as other students, including the opportunity to enter academically advanced classes, and have access to the full range of programs. The district does not use grade appropriate content objectives for LEP students that are based on the district curricula in English language arts, history and social science, mathematics, and science and technology/engineering, taught by qualified staff members. Narrative Description of Corrective Action: At the K – 8 level the district does ensure that ELL students are taught to the same academic standards as all other students. This will need to be documented and that documentation submitted to the DESE. At the high school level the participation of ELL students in advanced courses needs to be examined. The district has found it difficult to find therapists who speak some of the ELL students home language. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity Designee Building Principals October 8, 2010. Evidence of Completion of the Corrective Action: The district will compile a list of all ELL students, their grade and school, and the programs and support services that they are presently receiving and what should be available to them. Description of Internal Monitoring Procedures: The building principal and director will examine the data collected for this standard and determine if ELL students have access to a full range of programs offered by the district. Their review of this data will be summarized in writing and sent to the DESE by October 15, 2010. 44 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 11 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, the district will submit the results of the building principals’ review/self-assessment of the requirements of this criterion and a proposed corrective action plan with dates to improve areas that are identified as problematic. Please ensure that the report addresses the following areas of concern: Do LEP students receive support services, such as guidance and counseling, in a language that the student understands? Are LEP students taught to the same academic standards and curriculum as all students? Are LEP students provided with the same opportunities to master such standards as other students, including the opportunity to enter academically advanced classes, and access to the full range of programs? Are teachers using grade appropriate content objectives for LEP students that are based on the district curricula in English language arts, history and social science, mathematics, and science and technology/engineering? See also ELE 15 regarding professional development. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 12 Equal Access to Rating: Partially Implemented Nonacademic and Extracurricular Programs Department CPR Finding: A review of documentation indicates that the district does not provide information about extracurricular activities and school events to LEP students in a language they understand. Narrative Description of Corrective Action: The district does have information about extracurricular activities and school events that are produced in Spanish. Sufficient documentation was not submitted. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Building Principals and Director of Pupil May 21, 2010 Services or the Superintendent’s Designee Evidence of Completion of the Corrective Action: Collect data (notices and information given to LEP students regarding extracurricular activities and school events) for a 3 month period starting February 1, 2010 to May 1, 2010 and submit that data to the DESE by May 21, 2010 45 Description of Internal Monitoring Procedures: Building principals will have copies of notices provided to LEP students given to them and will maintain a folder which will be reviewed by June 30th each school year by the building principal. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 12 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By June 30, 2010, submit copies of notices/communications (in English and translation) that have been sent to students regarding non-academic and extracurricular programs. Progress Report Due Date(s): June 30, 2010 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: A review of student records and interviews indicate that follow-up monitoring is not consistently conducted across all grade levels. Narrative Description of Corrective Action: Each school will keep a list of Level 5 and former ELL students and will record monitoring of each student’s progress. A monitoring form will be created. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Building Principals will be Corrective Action Activity: responsible for ensuring monitoring May 21, 2010 Director will create a monitoring form and review them yearly Evidence of Completion of the Corrective Action: Collect evidence of monitoring of Level 5 and former ELL students for a 3 month period starting The data will be submitted on the newly created data form which will include methods of monitoring that should be followed. February 1, 2010 to May 1, 2010 and submit that data to the DESE by May 21, 2010. Description of Internal Monitoring: Copies of monitoring forms will be sent to the Office of Pupil Services for review by June 1st of each school year. The Director or Superintendent’s Designee will review the data to ensure that monitoring is in place and meets the standard. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 13 Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: 46 Required Elements of Progress Report(s): By June 30, 2010, the district will submit monitoring procedures, the newly developed monitoring form, and evidence of training (agenda, signed attendance sheets). By October 1, 2010, the district will conduct an internal review at each level. Report the number of FLEP student files reviewed at each level, the number of files that contained required monitoring documentation and any specific corrective action taken if needed. Progress Report Due Date(s): June 30, 2010, October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 14 Licensure Requirements Rating: Partially Implemented Department CPR Finding: Documentation submitted indicates that at the middle school level, eleven teachers are assigned to teach ESL, while only one of them is appropriately licensed. The district did not submit an appropriate written Literacy and Fluency policy statement. Narrative Description of Corrective Action: The district makes an effort to place ELL students with trained staff. The district’s three ELL teachers are listed in the DESE data base as appropriately licensed. More general education teachers need to be trained to meet the requirements of this criterion. The training in the past has been voluntary and this needs to be changed if the district is going to have trained general education teachers available at each grade level and in each subject area. The district will submit written Literacy and Fluency policy statements. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Submit Director of Pupil Services or Superintendent’s documentation of staff training and Literacy Designee & Fluency policies by November 19, 2010 Evidence of Completion of the Corrective Action: The district surveyed all teaching staff during the period of January 7 – 12, 2010 (at the three ELL schools) as to their level of training to teach ELL students. That extensive data needs to be put into a useable format and analyzed. This is in process. The data will then be analyzed and a training plan will be developed and submitted to the DESE. A literacy & Fluency policy will be developed. Staff training will be provided. The policy and agendas of training will be provided to the DESE. Description of Internal Monitoring Procedures: Staff qualifications will be monitored by building principals and the director or Superintendent’s Designee by September 30th of each school year. The Literacy and Fluency policies will be reviewed by September 30th of each school year by the director or designee. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 14 Status of Corrective Action: X Approved Partially Approved 47 Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit either copies of licensure and/or license numbers for verification by DESE staff. Submit an approved Literacy and Fluency policy for the district. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Rating: Partially Implemented Development Requirements Department CPR Finding: The district has demonstrated that SEI professional development has taken place for staff during the past three years; however, district-wide, the training has thus far concentrated primarily on Category I with Categories II and III planned, but no definite dates given. A few teachers at the elementary level have individually completed Category II training. At the middle school, more teachers have completed Category training, with the district indicating that some staff have completed Categories I, II and IV. However, no teachers in the district meet the definition of “qualified” to provide sheltered content for ELLs. The district did not provide a well-defined plan for addressing its SEI PD needs during the upcoming school years. Narrative Description of Corrective Action: The district has provided staff with the opportunities for ELL training in all categories. The district has used the Hampshire Educational Collaborative for this training. The district is in the process of developing a list of teachers who have had category training, the categories included in their training and /or the training they are presently receiving and / or the training they are enrolled in but have not started. The district will identify staff at each grade level (at the middle school and high school for both grade level and subject area) who receive ELL and ESL students. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Building principal – Staff Corrective Action Activity: training levels and assigning students. November 19, 2010 Director or Designee – Training plan for staff Evidence of Completion of the Corrective Action: The principal of each school in which ELL services are provided will develop a list of staff who instruct ELL students and their level of training. The procedures which include the manner in which new ELL students and participating ELL students are assigned trained teachers for their content area subjects will be developed and submitted to the DESE along with the district’s professional development plan as it pertains to ELL. Description of Internal Monitoring Procedures: The building principals will track ELL training and ensure that they have a trained general education teacher at each grade level and for each subject area in the three participating schools. 48 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 15 Status of Corrective Action: X Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit a spreadsheet to DESE outlining each teacher in the district, Category trainings completed and an anticipated date for completion of remaining Category trainings. DESE expects that at a very minimum, districts will complete at least one Category training per year for all staff within the district and will have completed Category training for all staff within a four year period. Progress Report Due Date: October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 17 Program Evaluation Rating: Partially Implemented Department CPR Finding: A review of documentation indicated that the district had an outside consultant conduct an ELE program evaluation; however, at the time of the review the evaluation report was not completed. Narrative Description of Corrective Action: The district has not found the report that the audit team referenced above. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Corrective Action Activity: Director of Pupil Service or Designee October 8, 2010 Evidence of Completion of the Corrective Action: The district will contract with an outside vendor to complete an evaluation of the ELL program but will request that the evaluation concentrate on the areas listed in this audit report. The district would like this evaluation to take place in May, 2010 with a report due by mid June, 2010. This will allow the district to get data regarding its’ efforts to address the audit findings that are being addressed prior to the evaluation date and to get an update on the issues which are still being addressed. A copy of the evaluation report will be sent to the DESE. Description of Internal Monitoring Procedures: The evaluator will be asked to examine the district’s internal monitoring of each criterion to determine if the steps recommended in this document will ensure future compliance and if not how that can be attained. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 17 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By October 1, 2010, submit the program 49 evaluation. Please note that the program evaluation should consist of using the English language proficiency test data of the district’s ELE students individually and in the aggregate to determine the effectiveness of its ELE program model. Progress Report Due Date(s): October 1, 2010 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 18 Records of LEP Students Department CPR Finding: A review of student records indicates that records of ELE students did not consistently contain home language surveys; results of identification and proficiency tests and evaluations, including MEPA results; information about students’ previous school experiences; copies of parent notification letters, progress reports and report cards (in the native language, if necessary); evidence of follow-up monitoring; documentation of a parent’s consent to “opt-out” of English learner education, if applicable. Narrative Description of Corrective Action: The district has already made a decision to keep all ELL records in the Office of Pupil Services. The high school has already examined the cumulative files of the ELL students and retrieved any forms that could be found. The high school staff has made a separate file for each ELL student and those files will be transferred to the Office of Pupil Services. All ELL files will need to be examines to determine what specific information has and has not been collected. Incomplete files need to be addressed. A copy of each ELL students MEPA report from the Spring of 2009 have been received at the Office of Pupil Services for the high school and elementary school. The middle school is presently copy that data to send to the Office of Pupil Services. Parent notification letters will be sent out shortly. Some did go out earlier in the school year but may not have been the official district notification letter and this was done inconsistently. Copies will be kept on file. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Pupil Services or Corrective Action Activity: Designee May 21, 2010 Evidence of Completion of the Corrective Action: An internal record audit will be conducted to determine if the procedures which are being developed and have been put in place and are being followed. The results of the record audit will be sent to the DESE by May 21, 2010. Description of Internal Monitoring Procedures: Record review yearly of 25% of the records. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: ELE 18 Records of Approved Partially Approved Disapproved LEP Students Basis for Partial Approval or Disapproval: The district did not provide training to required staff on the requirements of student records. Department Order of Corrective Action: Provide training on the requirements of student records. 50 Required Elements of Progress Report(s): By June 30, 2010, submit evidence of training (agenda, signed attendance sheets) on the requirements of student records. By October 1, 2010, the district will conduct an internal review of student records. Report the number of LEP records reviewed at each level, and the number of records that contained: Home language surveys; Results of identification and proficiency tests and evaluations, including MEPA results; Information about students’ previous school experiences; Copies of parent notification letters, progress reports and report cards (in the native language, if necessary); Evidence of follow-up monitoring; Documentation of a parent’s consent to “opt-out” of English learner education, if applicable. Identify any specific corrective action taken if needed to ensure full compliance. Progress Report Due Date(s): June 30, 2010, October 1, 2010 51