MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Oxford CPR Onsite Year: 2011-2012 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 10/16/2012. Mandatory One-Year Compliance Date: 10/16/2013 Summary of Required Corrective Action Plans in this Report Criterion SE 7 SE 18A Criterion Title Transfer of parental rights at age of majority and student participation and consent at the age of majority IEP development and content SE 22 IEP implementation and availability SE 32 Parent advisory council for special education SE 34 Continuum of alternative services and placements SE 37 Procedures for approved and unapproved out-of-district placements Special education programs and services are evaluated Information to be translated into languages other than English Responsibilities of the school principal SE 56 CR 7 CR 18 CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Not Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 7 Transfer of parental rights at age of majority and student Partially Implemented participation and consent at the age of majority Department CPR Findings: A review of student records and interviews with staff members indicated the district does not consistently inform the student and the parent/guardian one year prior that the educational decision making rights will transfer from the parent/guardian to the student upon the student's 18th birthday. Further, it was evident that the school district does not implement procedures to obtain consent from the student upon reaching the age of 18 to continue the student´s special education program. Description of Corrective Action: 1. The district will develop and implement a form in triplicate to be used at the last IEP for a student before he/she turns 17 to inform parents/guardians and the student about the transfer of rights at the age of majority. This form will contain signatures obtained from the parent/guardian, Team members, and the student. A signed copy will be given to the parent/guardian and the student and one will be placed in the student's file. The signed copy will also be scanned into the student's electronic file. 2. The student's liaison will present the student with a district-created duplicate form that indicates the student's consent or refusal to continue special education services within the first 5 school working days after the student turns 18. The student will be given a copy of the form. This form will be scanned into the student's electronic record. 3. The district will tag the electronic records of each student at the time of the above meeting to ensure that the students' consent for and IEPs will go to them for signature instead of to their parents/guardians unless the district receives court papers indicating that the parent/guardian has retained rights. 4. The director will provide training to the appropriate Team Leader, liaisons, and central office staff on the new processes. This training will take place no later than January 31, 2013. The district will document the discussion in the "additional information" section of the IEP. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 05/31/2013 Evidence of Completion of the Corrective Action: 1,2,3: The progress report regarding the results of this review will be submitted to the DESE no later than May 15, 2013. The director will indicate the number of records containing the appropriate documentation. If any records that are reviewed do not contain the appropriate documentation, the director will determine the root cause and submit a report to the DESE. 4. The agenda and sign-in sheet for this training will be submitted to the DESE no later than February 6, 2013. Description of Internal Monitoring Procedures: 1, 2, and 3: The director will complete an internal monitoring process for each of the above. This internal audit will consist of a review of 6 randomly selected records for the above referenced students. This review will take place no later than May 1, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 2 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 7 Transfer of parental rights at age of Status Date: 12/17/2012 majority and student participation and consent at the age of majority Basis for Partial Approval or Disapproval: The district has provided a detailed description as to how it will implement with staff training and then monitor via administrative review its process and procedure to ensure that both parents and student receive notice one year prior to the student's turning age 18 in order to prepare for his/her decision making, responsibilities and role upon reaching the age of majority. The district, through a designated staff member responsible, will follow-up with monitoring the additional necessary component of then obtaining consent from the student upon reaching age 18 to continue the student's special education program should the student be the decision maker or share in the decision making process. Department Order of Corrective Action: Required Elements of Progress Report(s): Please provide supporting documentation of the above procedures on or before February 7, 2013. Please provide evidence of staff training on the above procedures, which will include, but not be limited to relevant memorandum, email correspondence, training/meeting agenda, signed attendance sheets and training materials on or before February 7, 2013. Subsequent to the completion of all training activities, submit the results of an administrative review of records for high school students for evidence that parents and students were sent appropriate notice one year prior to age 18 and for those students who have attained age of majority, documentation of consent in a timely fashion. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before May 31, 2013. Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names, grade level and age for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 3 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18A IEP development and content Partially Implemented Department CPR Findings: A review of student records and interviews with staff members demonstrated that whenever the IEP Team evaluation indicates that a student's disability affects social skills development, or when the student's disability makes him or her vulnerable to bullying, harassment, or teasing, the IEP Team does not address the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing when warranted. Additionally, for students identified with a disability on the autism spectrum, the IEP Team does not consider and specifically address the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing. Description of Corrective Action: 1. The district will develop and implement a duplicate form to document the Team discussion regarding the effect of the student's disability on his/her social skill development and on his/her vulnerability to bullying, harassment, or teasing. This form will be signed by the parent/guardian and Team members at the meeting and a copy will be given to the parent/guardian. A copy will be placed in the student's record and will also be scanned into his/her electronic record. 2. The district will develop and implement a separate duplicate form to document the Team discussion for students on the spectrum. This form will document what the district will do to specifically address the skills and proficiencies needed for this student in order to avoid and respond to bullying, harassment, or teasing if determined necessary by the Team. This form will be signed by the parent/guardian and Team members at the meeting and a copy will be given to the parent/guardian. A copy will be placed in the student's record and will also be scanned into his/her electronic record. 3. The director will provide a training for the Team Leaders and the district's Autism/Behavior Specialist on the use of the form and the discussions at the Team meetings no later than January 31, 2013. This discussion will be documented on the "additional information" section of the IEP. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 05/31/2013 Evidence of Completion of the Corrective Action: 1,2,3. The district will provide copies of the agenda, forms, and sign-in sheet to the DESE no later than February 6, 2013. The progress report regarding the results of the internal review for compliance for this SE will be submitted to the DESE no later than May 15, 2013. Description of Internal Monitoring Procedures: The director will complete an internal monitoring process for each of the above. This internal review will consist of a review of 6 randomly selected records for the above referenced students. The director will indicate the number of records containing the appropriate documentation. If any records that are reviewed do not contain the appropriate documentation, the director will determine the root cause and submit a report to the DESE. This internal review will take place no later than May 1, 2013. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 4 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18A IEP development and content Corrective Action Plan Status: Approved Status Date: 12/17/2012 Basis for Partial Approval or Disapproval: The district's proposed corrective action is accepted. Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of training for staff members regarding the documentation within the IEP of the risk of bullying for students whose disability affects social skills development or those who have a disability on the autism spectrum. Evidence may include, but not be limited to memorandums, training/meeting agendas, letters or email correspondence. Please submit this to the Department on or before February 7, 2012. Submit the results of an administrative review of student records. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before by May 31, 2012. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 5 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 22 IEP implementation and availability Partially Implemented Department CPR Findings: A review of district documentation and interviews with staff members indicated that the district does not have a procedure in place to consistently inform general education teachers of their specific responsibilities related to IEP implementation, resulting in some general education teachers not providing accommodations, modification and supports for special education students. A review of student records and interviews with staff members also demonstrated that in situations where there has been a lack of special education personnel, the district does not consistently inform parents in writing of any delayed services, reasons for delay, actions that the school district was taking to address the lack of personnel and did not offer alternative methods to meet the goals on the accepted IEP. Description of Corrective Action: 1. The district uses a web-based system to create and maintain special education records for each student. This system includes a communication system that allows all staff to receive messages on their students through a secure system. 2. A staff member from the Office of Student Services will use this system to notify each teacher of the availability of a student's plan, IEP meetings, etc. 3. All notification swill be sent to the appropriate staff prior to the start of the school year and notices will be sent each time a new IEP has been signed. 4. The district will provide on-line training for staff in the use of the system and the technology department will be available for individuals who need additional assistance. 5. The director will provide annual training for all staff on their specific responsibilities related to IEP implementation. 6. The district will develop and implement letters to inform parents of possible delays in service, the reasons for those delays, and the action that the district is taking, as well as the possibility of compensatory services. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 05/31/2013 Evidence of Completion of the Corrective Action: 1- 4: Copies of notices, agendas for trainings, and sign-in sheets. The first round will be complete no later than January 31, 2013. 5: Copies of the agenda, handouts, and sign-in sheets for training session. This will be completed no later than May 15, 2013 and will be completed every year prior to the end of September. 6. Copies of the letters that have been sent to be completed no later than May 15, 2013. Description of Internal Monitoring Procedures: 1-4: The director will review the web-based system FERPA Audit Trail prior to January 31, 2013 and prior to May 15, 2013 to determine compliance by individual teachers. 5. The director will create and follow a training timeline by building. 6. The director will review the records of all students who have missed services to ensure that letters have been sent. This internal review will be conducted no later than January 31, 2013 and May 15, 2013. The director will complete a report to the DESE on the results of the internal reviews and will investigate the root cause of any non-compliance. This report will be submitted to the MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 6 DESE no later than May 31, 2013. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 22 IEP implementation and Status Date: 12/17/2012 availability Basis for Partial Approval or Disapproval: The district has provided a detailed narrative description as to how it will implement with staff training general educators' review of IEP's for their students and then monitoring via administrative review its process and procedure to ensure that general education teachers will be informed in a timely fashion and with confidentiality in accordance with federal and state requirements their specific responsibilities related to IEP implementation. The district will also train staff and monitor compliance regarding its duties and responsibilities pertaining to circumstances regarding delay of implementation of services in a student's IEP if and when the situation may arise. Department Order of Corrective Action: Required Elements of Progress Report(s): Provide evidence of training for staff members regarding its procedures to ensure that general education teachers are reviewing the IEP to implement the accommodations, modifications, and support agreed upon by the Team in the IEP. Additionally, the district must ensure training regarding procedures related to parent notification and its proposed actions if there are circumstances that may warrant the inability to provide services in the IEP. Evidence may include, but not be limited to memorandums, training/meeting agendas, training materials, letters or email correspondence. Please submit this to the Department on or before February 7, 2012. Submit the results of an administrative review of student records. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before by May 31, 2012. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 7 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 32 Parent advisory council for special education Partially Implemented Department CPR Findings: Interviews with staff members and parents indicated that the parent advisory council (PAC) does not advise the district on matters that pertain to the education and safety of students with disabilities and does not meet regularly with school officials to participate in the planning, development, and evaluation of the school district´s special education programs. Description of Corrective Action: 1. The director will meet at least quarterly with the PAC president to plan presentations and other PAC activities. 2. The superintendent will meet with the PAC annually. 3. The director will meet with the PAC at least twice per year. 4. The district will create and implement parent surveys to determine issues related to the district's special education programs and Team process. The results of those surveys will be released to the PAC and the district will use those results to inform their decisions related to those programs. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 05/31/2013 Evidence of Completion of the Corrective Action: 1, 2,3: The district will submit copies of agendas for these meetings and copies of PAC notices regarding these meetings to the DESE no later than January 31, 2013. 4. The district will submit copies of the surveys and their results to the DESE no later than May 31, 2013. Description of Internal Monitoring Procedures: 1,2,3,4. The director will audit the Department calendar and the district website on a monthly basis to ensure that all of the above activities have occurred. 4. The director and the Team chairs will compile the result of the surveys. The director will write the reports and provide copies to the PAC and the superintendent. The director will determine the root cause of any non-compliance and submit a report to the DESE. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 32 Parent advisory council for special Status Date: 12/17/2012 education Basis for Partial Approval or Disapproval: The district has presented a detailed description of its plans to ensure that the PAC has opportunities to meet with school officials pertaining to the education and safety of students. The PAC will also participate in the planning, development and evaluation of the school district programs by meeting with school officials in a formalized manner, setting quarterly meeting dates with the Director of Student Services and PAC President, biannual meetings with the PAC members and Director of Student Services, and an annual meeting with the Superintendent. Department Order of Corrective Action: Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 8 Please submit a copy of the schedule and agenda of PAC meetings for the 2012-13 school year and indicate how the PAC will have opportunities to advise the school district on matters that pertain to the education and safety of students. Please submit this to the Department on or before February 7, 2013. Please submit copies of the annual survey, along with the summary of results and improvement plan, PAC and school official meeting dates, agenda, and outcomes on or before May 31, 2013. Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 9 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 34 Continuum of alternative services and placements Partially Implemented Department CPR Findings: A review of student records and interviews with staff members demonstrated that the district is currently operating a public day program, Project Coffee, which does not have current approval from the Department of Elementary and Secondary Education. The Project Coffee program is housed in a separate facility on the Oxford High School property and is staffed with a principal, special education teachers and vocational teachers. The program has an overall enrollment of 43 high school level students, of that enrolled group, records showed that 22 students have an IEP which calls for a public day or substantially separate placement, one student is on a 504 accommodation plan and 10 students are general education students. Approximately half the students enrolled in the Project Coffee program are students that are placed there from other school districts with an IEP that calls for a public day placement. Description of Corrective Action: The director will complete and submit the initial program application for approval for Project COFFEE to be classified as a "Separate Public Day School". Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 07/31/2013 Evidence of Completion of the Corrective Action: The completed application. Description of Internal Monitoring Procedures: The director will create a timeline to complete each section of the application and will document meetings with the appropriate administrators who will be involved in the submission. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 34 Continuum of alternative services Status Date: 12/17/2012 and placements Basis for Partial Approval or Disapproval: The district has submitted a description of its plan to work on and submit its application to ESE for approval of "Project Coffee", its district's operating public day program. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit to ESE on or before February 7, 2013 the district's timeline of projected application submittal. Please include as evidence with the timeline: scheduled administrative meeting dates, agenda, and attendance. On or before May 31, 2013 please submit the completed application to ESE for the operation of Project Coffee as a separate public day school. Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 37 Procedures for approved and unapproved out-of-district Partially Implemented placements Department CPR Findings: Review of student records indicated that the Oxford Public School District does not appropriately document the monitoring of the provision of services to and the programs of individual students placed in public and private out-of-district programs. Documentation of monitoring plans and all actual monitoring were not placed in the files of every eligible student who has been placed out-of-district. Additionally, it was noted that in instances when monitoring required site visits, such site visits were not documented and placed in the students´ files. Description of Corrective Action: 1. The district will develop and implement a triplicate form to document the site visit for monitoring purposes for each student placed in an out-of-district program. This form will be signed by the representative of the district and by a representative of the program upon the completion of the monitoring visit. A copy will be given to the parent/guardian and to the representative of the program. A copy will be placed in the student's record and will also be scanned into his/her electronic record. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 05/31/2013 Evidence of Completion of the Corrective Action: Copies of the completed forms form the records of 6 randomly selected students. Description of Internal Monitoring Procedures: The director will conduct an internal audit no later than May 15, 2013 and will review 6 randomly selected records for the above students. A report on the results of the internal review will be submitted to the DESE no later than May 31, 2013. The director will investigate and report on the root causes of any non-compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 37 Procedures for approved and Status Date: 12/17/2012 unapproved out-of-district placements Basis for Partial Approval or Disapproval: The district has submitted its plans to create and implement an out-of-district monitoring form to ensure its responsibilities of its required duties to monitor and document students placed in an out-of-district setting. The district has described its planned method of internal monitoring by administrative oversight and record review of OOD students to ensure compliance and investigate, upon any continued non-compliance, the root cause and address with corrective action accordingly. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit the district's newly developed OOD monitoring form that will be placed within the student's record along with evidence of staff training regarding implementation and use of the form. Evidence may also include email correspondence, staff training agenda, and signed attendance sheets. Submit this evidence on or before February 7, 2013 to ESE. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 11 Please submit the results of an administrative review of OOD student records. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before May 31, 2012. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 56 Special education programs and services are evaluated Not Implemented Department CPR Findings: A review of district documentation and interviews with staff members demonstrated that special education programs and services are not being regularly evaluated. Description of Corrective Action: 1. The district will create a cycle for the review of in-district programs so that all programs will be reviewed at least once in every three year period. 2. This review will cover the appropriateness of the program for the students who are placed in the program, the compliance of the program to the individual students' IEPs, the appropriateness of the materials and supplies, the appropriateness of the curriculum, and the appropriateness of the physical location of the programs for the needs of the students being served. 3. The director will use the results of these evaluations when meeting with building principals and Team Leaders on any needs to restructure programs. Title/Role(s) of responsible Persons: Expected Date of Completion: Patricia W. Susen, Director of Student Services 07/31/2013 Evidence of Completion of the Corrective Action: 1. Copy of the 3 year timeline 2. Copies of the reports 3. Copies of the agendas for these meetings and notes from these meetings on decisions made as a result of the evaluations. Description of Internal Monitoring Procedures: 1. The director will create and follow this timeline. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 56 Special education programs and services are evaluated Corrective Action Plan Status: Approved Status Date: 12/17/2012 Basis for Partial Approval or Disapproval: The district has proposed an annual process for reviewing special education programs and services, with a 3 year cycle of review, to allow for the ongoing and continuous regular evaluation of special education programs and services. Department Order of Corrective Action: Required Elements of Progress Report(s): Please provide a narrative of the district's plans to ensure the annual review of special education programs and services, the guidelines on selecting programs/services to evaluate, and the timeline(s) of projected review of special education programs and services on or before February 7, 2013 to ESE. Evidence may also include but not be limited to email correspondence, letters, and planned surveys. Please provide to ESE on or before May 31, 2013 the results of the district's annual evaluation of special education program(s)/service(s) with a narrative of outcomes and improvement plans as warranted, along with administrative meeting dates/notes for improvement implementation. Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 13 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7 Information to be translated into languages other than Partially Implemented English Department CPR Findings: A review of district documentation and interviews with staff members indicated that important information in documents, handbooks and codes of conduct being distributed to parents, is not being translated into the major languages spoken by parents/guardians with limited English skills; oral interpreters are not always attending parent conferences or translating report cards to assist parents with limited English skills, including low incidence languages. Description of Corrective Action: 1. The district will add a translation link to the website no later than January 31, 2013. 2. The district will create posters and cards in the languages (as determined by the home language surveys) of the district to be placed in the front offices of each building to inform parents/guardians of the availability of both written and oral translations (including American Sign Language) no later than January 31, 2013. 3. The district will create forms in the languages of the district for parents/guardians to use to request translators and/or written translations of documents no later than January 31, 2013. 4. The district will create forms for the buildings to use to request translations and/or a translator no later than January 31, 2013. 5. The services of a translator and or translated documents will be provided by the Office of Student Services. 6. The director will conduct trainings for office staff and others related to the use of the posters, cards, and home language surveys as well as methods to use to inform parents/guardians of the availability of these services no later than January 31, 2013. 7. Records of requests and actual translations and contracts with translators will be maintained by the Office of Student Services. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 05/31/2013 Evidence of Completion of the Corrective Action: 1, 2, 3, 4: Copies of forms. 5: Copies of contracts 6. Copy of agendas and sign in sheets All to be submitted to DESE no later than February 7, 2013. Description of Internal Monitoring Procedures: The director will conduct an internal review of all submitted forms and the results no later than May 15, 2013. The director will submit a report of the results of the internal review to the DESE no later than May 31, 2013 and will investigate and report on the root causes of any non-compliance at that time. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 7 Information to be translated into Status Date: 12/17/2012 languages other than English Basis for Partial Approval or Disapproval: The district has described its plans to ensure that important documents, handbooks and MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 14 codes of conduct will be translated in the major languages of the district and use of translators to assist parents with limited English skills will be provided when warranted at parent conferences and needed translation of student report cards. Department Order of Corrective Action: Required Elements of Progress Report(s): The district must provide evidence of training for staff members regarding that important information and documents being distributed to parents are consistently translated and the district has established a consistent system of oral interpretation to ensure assistance to parents/guardians with limited English skills. Evidence may include, but not be limited to memorandums, training/meeting agendas, training materials, forms, letters or email correspondence. Please submit this to the Department on or before February 7, 2013. Submit the results of an administrative review of ELE student records. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before May 31, 2012. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 02/07/2013 05/31/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 15 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 18 Responsibilities of the school principal Partially Implemented Department CPR Findings: A review of district documentation and interviews with staff members showed that the District Curriculum Accommodation Plan (DCAP) does not consistently provide general education teachers the support to meet the needs of diverse learners in the general education programs resulting in a lack of direct and systemic instruction in reading and gaps in provisions of services to address the needs of children whose behavior may interfere with learning. Description of Corrective Action: 1. The district will review and re-design the system of tiered interventions available in the district, based on the state MTSS model no later than May 31, 2013. 2. The district has purchased a web-based system to create, manage, and document all student plans, including DCAPs. The use of the system will be implemented in stages, beginning in February, 2013. 3. The district's director of curriculum and the district's director of student services will develop a new set of protocols and procedures for the development and implementation of DCAPs no later than August 15, 2013. 4. The district will provide additional trainings for regular education teachers in direct and systematic instruction in reading - on going. 5. The district will investigate the need to hire additional staff to assist with the behavioral needs of all students no later than March 31, 2013. 6. The directors will provide training to the appropriate district staff on the creation and monitoring of a DCAP no later than September 30, 2013. Title/Role(s) of responsible Persons: Expected Date of Patricia W. Susen, Director of Student Services Completion: 09/30/2013 Evidence of Completion of the Corrective Action: 1. A copy of the district's new system 2. A sample of the new plan 3. A copy of the new protocols and procedures 4. Copies of agendas and sign-in sheets for teacher trainings. 5. Report on the results of the investigation and next steps regarding additional staff. 6. Agendas and sign-in sheets for trainings. Description of Internal Monitoring Procedures: The director of student services will collect documentation and will follow the timeline as created. A report will be submitted to the DESE no later than October 10, 2013. The director will investigate and report on the root causes of any non-compliance at that time. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 18 Responsibilities of the school Status Date: 12/17/2012 principal Basis for Partial Approval or Disapproval: The district has presented a description of its detailed overall plans to address and support the needs of general education teachers regarding the education of diverse learners including students with concerns in reading and those students who may display behavioral concerns. Differentiated instruction via tiered intervention models with student MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 16 success plans will be implemented, along with increased support staff to improve student success and outcomes. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit on or before May 31, 2013 to ESE evidence of the district's newly revised DCAP as described, which will include, but not be limited to relevant memorandum, email correspondence, training/meeting agenda, signed attendance sheets and materials. Subsequent to the completion of the continued phase of training activities, submit the results of an administrative review of records of students with reading concerns and additionally, those with behavioral interventions. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before September 9, 2013. Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names, grade level and age for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and their signature(s). Progress Report Due Date(s): 05/31/2013 09/09/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 17 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW District: Oxford Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Patricia W. Susen, Director of Student Services 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: August 21, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 Program Placement and Rating: Partially Implemented Structure Department CPR Finding: Documentation reviewed indicated that the district did not develop an ESL curriculum. In this regard, the district should note that the Department has new regulations in place which may affect its corrective action plan (CAP). Please refer to: http://www.doe.mass.edu/rettell/ for more information. Concerning hours of ESL services, English language learners (ELLs) are provided with limited instructional time; each student gets one hour, regardless of the students level of English proficiency. The students MEPA (Massachusetts English Proficiency Assessment) levels seem to be level 1 and/or 2. According to Department guidance, beginner ELLs at MEPA levels 1 and 2 should receive 2.5 hrs ESL instruction daily or 12.5 hours a week. (Please refer to http://www.doe.mass.edu/mcas/mepa/guidance.html - p. 5 Please see ELE 15 for comments on Professional Development Requirements. The Department concluded that the district does not have a fully implemented SEI Program as required by Chapter 71A. The district has not developed an ESL curriculum, the hours of ESL instruction provided to ELLs are not consistent with Department guidance, and content area teachers instructing ELLs have not completed all of the required SEI Category Trainings. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 18 Narrative Description of Corrective Action: 1. SEI-trained teachers: The district has received the 2015-2016 cohort status for the RETELL. The district will comply with the guidance provided by the DESE for training teachers for the RETELL. 2. ESL Curriculum: By 8/21/2014, the district will develop an ESL curriculum that is aligned with the WIDA standards. 3. Hours of ESL Instruction: The director of Student Services and the district’s ESL teacher met on 8/29/13 and 9/12/13 to discuss the regulations re: instructional hours as outlined in the DESE guidance from 9/2009. -By 9/30/13, the director and the ESL teacher will have cross-walked the proficiency categories using the Spring WIDA scores to determine the appropriate number of instructional hours for each ELL student in the district. -By 10/9/13, all ESL students in the district will be placed in the appropriate grouping to meet their individual needs and their proficiency levels. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen, Director of Corrective Action Activity: Student Services 1. Dependent of DESE activities/guidance. 2. Proficiency Levels 1 & 2: Feb 1, 2014; Proficiency levels 3 & 4: May 1, 2014; Proficiency Levels 5 & 6: August 21/2014 3. 10/09/13 Evidence of Completion of the Corrective Action: 1. List of trained teachers 2. Written curriculum 3. Individual student schedules/proficiency categories Description of Internal Monitoring Procedures: The director will review student records quarterly to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Program Placement and Structure Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department accepts the district’s plan to ensure that all core academic teachers with ELLs and administrators that supervise core academic teachers of ELLs are endorsed. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): 1) Please provide a detailed plan that shows that the district is providing sufficient ESL instruction to all ELL students during the 2013-2014 school year based on the Department's Transitional Guidance on Identification, Assessment, Placement, and Reclassification of English Language Learners found at http://www.doe.mass.edu/ell/TransitionalGuidance.pdf 2) Please complete district information in the attached spreadsheet labeled ELL List by school for each ELL student in the district. 3) Submit a plan that includes information about a process for reviewing or developing ESL curriculum that integrates WIDA ELD standards. Progress Report Due Date(s): January 13, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 19 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 8 Declining Entry to a Program Rating: Not Implemented Department CPR Finding: Interviews indicated that the district does not have a mechanism in place to provide English language support to students whose parents have declined entry to the sheltered English immersion program. Narrative Description of Corrective Action: The district will implement a monitoring form to be used by classroom teachers in order to indicate the student’s progress. These forms will be submitted to the Office of Student Services at least quarterly and will be used by the director and the ESL teacher to determine possible need for intervention. If it is determined that a student requires interventions, a meeting will be called for the parent/guardian, building administrator, teachers, guidance, and ESL staff to discuss this need with the parent/guardian. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen, Director of Corrective Action Activity: June, 2014 Student Services Evidence of Completion of the Corrective Action: Copies of monitoring form, meeting notices, meeting notes Description of Internal Monitoring Procedures: The director will review student records quarterly to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: : ELE 8 Declining Entry to a Program Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district also needs to address those “opt out” students who will still be reported as “ELL” on the SIMS data. Additionally, the annual ACCESS assessment will be administered as long as the student’s proficiency level in English identifies her/him as “ELL”. Parent notification is also required on an annual basis as long as those students are identified as English language learners. Department Order of Corrective Action: Develop a procedure for the district regarding “opt out” students and train relevant staff, e.g. ELL Director, Principals and ELL teachers, on the procedure. Conduct an administrative review of “opt out” student records to determine whether the procedure is followed and appropriate documentation is found in the student record for ELLs. Required Elements of Progress Report(s): Please provide the “opt out” procedures and evidence of training including, but not limited to agenda, memorandums, training materials and sign-in attendance sheet by January 13, 2014. Subsequent to implementation of training of new procedures, conduct an administrative review of “opt out” student records and document whether compliant with the procedure. Report the number of records reviewed, the number compliant and any steps the district will take to address any continuing identified non-compliance after a root cause analysis by May 15, 2014. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of the person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): January 13, 2014 & May 15, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 20 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: The district did not specify if ELLs are grouped to receive ESL services, and if so, the criteria used to form the groups. Narrative Description of Corrective Action: The director of Student Services and the district’s ESL teacher met on 8/29/13 and 9/12/13 to discuss the regulations re: instructional hours as outlined in the DESE guidance from 9/2009. -By 9/30/13, the director and the ESL teacher will have cross-walked the proficiency categories using the Spring WIDA scores to determine the appropriate number of instructional hours for each ELL student in the district. -By 10/9/13, all ESL students in the district will be placed in the appropriate grouping to meet their individual needs and their proficiency levels. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen, Director of Corrective Action Activity: 9/30/13, 10/9/13 Student Services Evidence of Completion of the Corrective Action: Copies of student records, copies of student placements/schedules Description of Internal Monitoring Procedures: The director will review individual student records quarterly to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 9 Instructional Grouping Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): Provide a copy of the most recent ESL teacher schedules for all grade levels district wide. All schedules should include the following for each block of time: 1. Names of the ELL students 2. Grade level for each student 3. English proficiency level for each student. Progress Report Due Date(s): January 13, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 10 Parental Notification Rating: Partially Implemented MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 21 Department CPR Finding: A review of student records demonstrated that the district does not, upon initial identification of the student as LEP (n.k.a.ELL), nor annually thereafter, provide notice to the student’s parent/guardian that specifies the reasons for identification of the student as LEP (n.k.a.ELL); the child’s level of English proficiency; program placement and/or the method of instruction used in the program; and the parents’ right to apply for a waiver or to decline to enroll their child in the program. Narrative Description of Corrective Action: The district uses an electronic data base to maintain student records for a variety of populations. The district has just instituted that system for the purpose of maintaining ELL records, as well. That system contains a variety of notifications, including notices for all of the above. Students who are currently receiving services, or who have been identified as needing services, are being enrolled in that data base and the appropriate notifications are being generated and sent through that system. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen Corrective Action Activity: Ongoing, as students are identified. Evidence of Completion of the Corrective Action: Copies of the letters sent (including translations) Description of Internal Monitoring Procedures: The director will review student records in the data base quarterly to ensure that the appropriate notices have been sent out. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Parental Notification Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Provide a copy of the Parent Notification letter and the translations for the district as well as the schedule for sending this letter for identified ELL students. Required Elements of Progress Report(s): It is recommended that the district use the Parent Notification letter on the Department’s ELE web site, http://www.doe.mass.edu/ell/resources.html. Please use this letter or include all of the required elements, e.g. reason for identification, level of English proficiency, method of instruction used in the program and parents’ right to apply for a waiver or decline to enroll the student in the program. Attach a translation for each of the major languages in the district. Please submit to ESE by January 13, 2014. Subsequent to implementation of new procedures, conduct an administrative review of a sample of student records across all levels to determine if the Parent Notification letter was sent for the 20132014 school year and report the number of records reviewed, the number of records in compliance and the steps the district will take to address any identified noncompliance found. Please submit the results of the administrative record review by May 15, 2014. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of the person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): January 13, 2014 & May 15, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 22 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Rating: Partially Implemented Development Requirement Department CPR Finding: The district did not develop a multi-year Sheltered English Immersion (SEI) Professional Development Plan. However, onsite interviews indicated that some teachers had completed SEI Category I Training, but no additional SEI training categories. Documentation also indicated that in middle school Category 1 and 2 had been completed by one teacher each. The district should note that the Department’s regulations concerning SEI professional development requirements have changed. Please refer to: http://www.doe.mass.edu/retell/ for more information. Narrative Description of Corrective Action: The district has been placed in the 2015-2016 cohort for the RETELL. Based on this designation, the district will be providing training as determined by the DESE. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen, Director of Corrective Action Activity: On-going as Student Services determined by the DESE Evidence of Completion of the Corrective Action: Lists of trained teachers. Description of Internal Monitoring Procedures: The director will conduct twice-annual reviews of staff trainings to ensure that the district teachers are being appropriately trained. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 15 Professional Development Requirement Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See ELE 5. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): None required. Progress Report Due Date(s): N/A COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 17 Program Evaluation Rating: Not Implemented Department CPR Finding: A review of district documentation and interviews with staff members indicated that the district does not conduct periodic evaluations of the effectiveness of their ELE program. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 23 Narrative Description of Corrective Action: Through the assistance of the DSAC, the district has formed a district-level data team and is currently forming building-based data teams. Part of the responsibilities of these teams is to review data from the various assessments that the district uses. As the district develops an ELL curriculum based on the WIDA standards, assessments will be developed for that as well. The director and the ESL teacher will review the results of individual ELL student assessments, including the MAPS, DIBELS, district-created common assessments, MCAS, and WIDA testing in October, February, and June of each year to determine the effectiveness of the ELL program. The district will use this data to inform the instruction for each ELL student. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen, Director of Corrective Action Activity: October 31, 2013; Student Services February 15, 2014; June 2, 2014 Evidence of Completion of the Corrective Action: Results of assessments for each ELL student Description of Internal Monitoring Procedures: The director will conduct an internal review in November, February, and June of each year to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: : ELE 17 Program Evaluation Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Note: Optional program evaluation form is available @ http://www.doe.mass.edu/ell/resources.html. Required Elements of Progress Report(s): Provide the report to ESE from the data committee for ELL students by May 15, 2014. Progress Report Due Date(s): May 15, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 Records of ELL Students Rating: Partially Implemented Department CPR Finding: A review of student records showed that the files did not contain information about students’ previous school experiences; copies of parent notification letters, progress reports and report cards; evidence of follow-up monitoring; documentation of a parent’s consent to “opt-out” of English learner education, if applicable; waiver documentation, if applicable; and Individual Student Success Plans for students who have failed MCAS, if the district is required to complete plans for non-LEP(ELL) students. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 24 Narrative Description of Corrective Action: The district uses an electronic data base to maintain student records for a variety of populations. The district has just instituted that system for the purpose of maintaining ELL records, as well. Through this system, the district will scan the records of all ELL students into their appropriate files, including the various notifications as required by ELE 10. The district has a centralized registration system and the home language survey is now provided to the Office of Student Services by the registrar. In addition, copies of the student records will be provided to the office by the guidance department of each school when received by that school. When required records are not provided by the sending school, or if previous services are not identified, the Office of Student Services will contact the sending schools to ensure that the appropriate records are provided. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Patricia W. Susen, Director of Corrective Action Activity: On-going Student Services Evidence of Completion of the Corrective Action: Student records files Description of Internal Monitoring Procedures: The director will conduct quarterly record reviews to ensure compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 18 Records of ELL Students Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): Conduct an administrative review of ELL student records for ELL students from each level (elementary, middle and secondary) and a variety of proficiency levels, as well as any students on monitoring now known as “FELL” and any “opt out” students. Report the number of records reviewed, the number in compliance with required documents (home language survey, results of identification tests, ACCESS results, MCAS results, previous school experience, parent notification letters, progress reports, report cards, follow-up monitoring, opt-out documented by parent and any waiver documentation). For students whose parents require documentation in their native language the student record must contain evidence of translations. The district must also report the number of records in compliance and any steps it will take to correct any areas of noncompliance by May 15, 2014. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of the person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): May 15, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Oxford CPR Corrective Action Plan 25