MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Palmer Public Schools Corrective Action Plan Forms Program Area: Special Education Prepared by: Neil Metcalf 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 8, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 4 Required and optional Rating: Partially implemented assessments Department CPR Finding: : According to student record reviews and interviews, the assessment reports did not consistently summarize in writing the procedures employed, the results, and the diagnostic impression, nor did they always define in detail and in educationally relevant and common terms the student’s needs and offer explicit means of meeting them. Narrative Description of Corrective Action: All evaluators will be provided professional development regarding the forms and format to be utilized in the summary report for student evaluations. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Education Corrective Action Activity: Spring 2011 Evidence of Completion of the Corrective Action: Dated Agenda’s, Sign in sheets, sample formats. Record Review. Description of Internal Monitoring Procedures: Agendas from meetings and sample format. Record review. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 4 Required and optional assessments 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 March 1, 2011, submit evidence of professional development provided to evaluators on writing 1 appropriate summaries in assessment reports (agenda, sign-in sheets, materials). By May 31, 2011, conduct an administrative review of a sample of IEPs written since the training to determine if the assessment reports consistently summarize in writing the procedures employed, the results, and the diagnostic impression, and define in detail and in educationally relevant and common terms the student’s needs and offer explicit means of meeting them. Please submit: The number of student records reviewed; The number of student records in compliance; For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31, 2011 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: According to student record review and interviews, IEPs do not consistently address all elements of the most current IEP format provided by the DESE, such as the student’s educational strengths, interest areas, significant personal attributes, personal accomplishments and type of disability. Narrative Description of Corrective Action: All staff will be provided professional development regarding the forms and format to be utilized in the summary report for student evaluations. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Corrective Action Activity: Spring 2011 Implementation: All staff will be provided professional development regarding the requirement to include a description of the student’s educational strengths, interest areas, significant personal attributes, personal accomplishments and type of disability on page one if the IEP. Evidence of Completion of the Corrective Action: Dated Agendas, signature sheets, copies of forms/pages. Record review. Description of Internal Monitoring Procedures: Agendas from staff meetings. Record Review CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: : SE 18A IEP development and content Status of Corrective Action: Approved Partially Approved 2 Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011, submit evidence of professional development provided to staff on addressing all required elements when writing IEPs (agenda, sign-in sheets, materials). By May 31, 2011, conduct an administrative review of a sample of IEPs written since the training to determine if the IEPs consistently address all elements of the most current IEP format provided by the DESE, such as the student’s educational strengths, interest areas, significant personal attributes, personal accomplishments and type of disability. Please submit: The number of student records reviewed; The number of student records in compliance; For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 18B Determination of Rating: Partially Implemented placements; provision of IEP to parent Department CPR Finding: According to student record review and interviews, the district does not provide the parent with two copies of the proposed IEP and proposed placement, immediately following the development of the IEP. Narrative Description of Corrective Action: Office manager will receive a memo from the Director with a copy of this finding. All office staff will be informed of this requirement. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Education Corrective Action Activity: Spring 2011 Evidence of Completion of the Corrective Action: Copies of memo to office manager and staff informing of this requirement. Description of Internal Monitoring Procedures: Copy of memo. Record Review CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 18B Determination of placements; provision of IEP to parent Status of Corrective Action: Approved Partially Approved Basis for Partial Approval or Disapproval: 3 Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011, submit a copy of the memo regarding providing parents with two copies of the IEP (or a summary of decisions and agreements reached including a completed IEP service delivery grid describing the types and amounts of special education and /or related services proposed by the district and a statement of the major goal areas associated with these services-Memorandum on the Implementation of 603 CMR 28.05(7) Advisory 12/1/2006) and list of staff who received it. By May 31, 2011, conduct an internal review of IEPs written since the training to determine if the district provides parents with two copies of the proposed IEP and proposed placement, immediately following the development of the IEP(or a summary of decisions and agreements reached including a completed IEP service delivery grid describing the types and amounts of special education and /or related services proposed by the district and a statement of the major goal areas associated with these services-Memorandum on the I0mplementation of 603 CMR 28.05(7) Advisory 12/1/2006). Please submit: The number of student records reviewed; The number of student records in compliance; For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 20 Least restrictive program Rating: Partially implemented selected Department CPR Finding: According to student record review, the IEP Team did not consistently state why the removal of a student from the general classroom 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. Narrative Description of Corrective Action: Title/Role of Person(s) Responsible for Implementation: Director of Special Education Expected Date of Completion for Each Corrective Action Activity: Spring 2011 Evidence of Completion of the Corrective Action: Dated Agendas, signature sheets, copies of forms/pages. Record review. Description of Internal Monitoring Procedures: Agendas from staff training. Record Review 4 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 20 Least restrictive program selected Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not complete the narrative description of corrective action. Department Order of Corrective Action: The district will conduct training with appropriate staff on least restrictive program selected and then conduct an administrative review of a sample of student records to determine if the criterion is being met. Required Elements of Progress Report(s): By March 1, 2011, submit evidence of staff training on least restrictive program selected (agenda, signed attendance sheets, and materials used). By May 31, 2011, submit the results of an administrative review of a sampling of student records to determine that the IEP Team consistently stated why the removal of a student from the general classroom was 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. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31, 2011 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: According to interviews and document review, the high school has just two inclusion teachers for five grades. At the time of the Coordinated Program Review, one of the inclusion teachers was out on maternity leave and was replaced by a paraprofessional. Special education teachers and paraprofessionals are frequently removed from their duties to serve as substitute teachers in general education classrooms, particularly at the high school. Therefore, the school district does not always provide the mutually agreed upon services stated in the IEP without delay. Narrative Description of Corrective Action: Two paraprofessional instructional assistants are assigned to the inclusion teachers to assist in inclusion. Evaluation of services at the high school will be review with the principal and additional service/staff will be identified in preparation for the FY 12 budget. Procedures will be developed to ensure, to the degree possible, that substitutes are provided for all professional and paraprofessional positions as needed. Procedures will be developed with the principals of each building and shared with office staff whose responsibility it is to contact substitutes. 5 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: Fall 2011 Education/Principals Evidence of Completion of the Corrective Action: Procedure for substitutes. Substitute log/records. Summary of evaluation findings. Fy 12 Budget. Description of Internal Monitoring Procedures: Copies of procedure, sub log and pay slips. Fy 12 budget. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 22 IEP implementation and availability 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 March 1, 2011: Submit the names and qualifications of the inclusion teachers and paraprofessionals assigned to them at the high school Submit a description of procedures the district has developed to ensure that substitutes are provided for all professional positions and paraprofessional positions. Submit a description of procedures that the district has developed and shared with principals of each building regarding the responsibility to contact substitutes. By May 31, 2011 Submit the results of the evaluation of services at the high school and identify the additional services and staff that will be provided for in the Fiscal 2011-2012 budget. Describe how the high school will provide all services stated in the IEP without delay. Submit substitute logs and records compiled from the date when new procedures were developed. Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially implemented Criterion & Topic: SE 24 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE 6 Department CPR Finding: Student record reviews and interviews indicated that the district does not consistently address the six questions, as required by federal regulation, on the attachment to the Notice of School District Action (N1). Narrative Description of Corrective Action: Professional development will be provided to all staff/team leaders regarding the requirements of the N1 letter. Office manager will monitor NI letters being sent home to review completion and notify the team leader if incomplete. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: Spring 2011 Education/Office Manager Evidence of Completion of the Corrective Action: Copies of dated, agenda’s and sign in sheets. Record review. Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: : SE 24 Notice to parent Approved Partially Approved Disapproved regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011, submit evidence of professional development provided to staff and team leaders regarding the requirements of addressing all questions on the attachment to the N1 (agenda, sign-in sheets, and materials). By May 31, 2011, conduct an internal review of IEPs written since the training to determine if the district addresses all questions on the attachment to the NI. Please submit: The number of student records reviewed; The number of student records in compliance; For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31, 2011 7 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 27 Content of Team meeting Rating: Partially implemented notice to parents Department CPR Finding: Review of student records and interviews reveal that parent notices do not always include a list of the team members who would be in attendance at the meeting. Narrative Description of Corrective Action: The signature sheet will no longer be separated from the N1 copy in the file. A separate sheet will be used for attendance at team meeting and the file copy will be left in tact. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Education Corrective Action Activity: Winter 2010/11 Evidence of Completion of the Corrective Action: Copy of memo to office personnel. Description of Internal Monitoring Procedures: Record review and parent interviews. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 27 Content of Team meeting notice to parents 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 March 1, 2011, submit a copy of the memo sent to appropriate staff regarding including in the parent notice a list of team members who will be in attendance at IEP team meetings. By May 31, 2011, conduct an internal review of IEPs written since the memo was sent to appropriate staff to determine if parent notices include a list of the team members who will be in attendance at the IEP team meeting Please submit: The number of student records reviewed; The number of student records in compliance; For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31, 2011 8 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: According to student record review and interviews, communications with parents are not consistently provided in both English and the primary language of the home if such primary language is other than English. Narrative Description of Corrective Action: Coordination with ELE committee. Contact surrounding communities to identify existing translations for common notices and to identify a cost effective system for the translation of communications. The district currently uses Word 2010 and will utilize its translation capability for document translations. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: Fall 2011 Education/ELE committee Evidence of Completion of the Corrective Action: Copies of translated documents. Record review, and parent interviews. Description of Internal Monitoring Procedures: ELE committee agendas and minutes. Copies of translated documents. Record review. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 29 Communications are Status of Corrective Action: in English and primary language of Approved Partially Approved home Basis for Partial Approval or Disapproval: Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011, submit a: Description of procedures the district uses to determine if the primary language of a student’s home is other than English and, if so, how the district provides translation/interpretation in that language. List of communities the district contacted about existing translations and copies of documents identified as available to the district. List of primary home languages that are spoken in the district if the primary language is other than English By May 31, 2011, conduct an internal review of the records of students whose primary home language is other than English to determine if communications with parents are provided in both English and the primary language of the home and submit: The number of student records reviewed; The number of student records in compliance (communications were provided in both English and the primary language of the home if such primary language is other than English); For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance 9 *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011; May 31 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: Review of student records and documents, and interviews indicated that the district does not have a program for students with behavioral problems, although there are a number of students who have a need for such a program. There is one behaviorist on staff who serves the entire district Narrative Description of Corrective Action: Since the audit in the spring of 2010, the district has established an alternative program at Palmer High School. This program is staffed by a certified special needs teacher, certified school adjustment counselor/behaviorist and a paraprofessional instructional assistant. Classes are taught by appropriate licensed high schools staff. The elementary schools are in the process of developing program options for students with behavioral problems. At all levels it is required that these students be educated in the least restrictive setting. The Middle School continues its alternative education program. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Corrective Action Activity: Fall 2011 Education/Principals Evidence of Completion of the Corrective Action: Program descriptions, intake and exit criteria. Description of Internal Monitoring Procedures: Review of program participations. Program visitation and observation. Staff evaluations. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 34 Continuum of alternative services and placements 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 March 1, 2011, submit a Detailed description of the alternative program for students with behavior problems at Palmer High School, including intake and exit criteria. List of the alternative program staff, including certifications Description of program options the district has developed for students with behavior problems at the elementary level By May 31, 2011, submit a 10 Review of the alternative program for students with behavior problems at Palmer High School, including number of students served, successes, challenges and possible changes for the next school year. Provide an update on the program options the district has chosen for students with behavior problems at the elementary level. Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 36 Implementation, accountability and financial responsibility Department CPR Finding: See SE 22 Rating: Partially implemented Narrative Description of Corrective Action: Two paraprofessional instructional assistants are assigned to the inclusion teachers to assist in inclusion. Evaluation of services at the high school will be review with the principal and additional service/staff will be identified in preparation for the FY 12 budget. Procedures will be developed to ensure, to the degree possible, that substitutes are provided for all professional and paraprofessional positions as needed. Procedures will be developed with the principals of each building and shared with office staff whose responsibility it is to contact substitutes. Since the audit in the spring of 2010, the district has established an alternative program at Palmer High School. This program is staffed by a certified special needs teacher, certified school adjustment counselor/behaviorist and a paraprofessional instructional assistant. Classes are taught by appropriate licensed high schools staff. The elementary schools are in the process of developing program options for students with behavioral problems. At all levels it is required that these students be educated in the least restrictive setting. The Middle School continues its alternative education program. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Education Corrective Action Activity: Spring 2011 Evidence of Completion of the Corrective Action: Procedure for substitutes. Substitute log/records. Summary of evaluation findings. Fy 12 Budget. Program descriptions, intake and exit criteria. Description of Internal Monitoring Procedures: Copies of procedure, sub log and pay slips. FY 12 budget. Review of program participations. Program visitation and observation. Staff evaluations. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 36 Implementation, Status of Corrective Action: accountability and financial Approved Partially Approved responsibility Basis for Partial Approval or Disapproval: Department Order of Corrective Action: 11 Disapproved Required Elements of Progress Report(s): By March 1, 2011: submit the names and qualifications of the inclusion teachers and paraprofessionals assigned to them at the high school Submit procedures the district has developed to ensure that substitutes are provided for all professional and paraprofessional positions. Submit procedures that the district has developed and shared with principals of each building regarding the responsibility to contact substitutes. By May 31, 2011 Submit the results of the evaluation of services at the high school and identify the additional services and staff will be provided for in the Fiscal 2011-2012 budget. Describe how the high school will provide all services stated in the IEP without delay. Submit substitute logs and records compiled from the date when new procedures were developed Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: SE 54 Professional Development Rating: Partially implemented Department CPR Finding: According to interviews and document review, the district does not provide training opportunities for paraprofessional staff, nor does it provide training in state and federal special education requirements and related local special education policies and procedures; analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate diverse learning styles of all students in the regular classroom. According to a review of documents, the district does not provide in-service training for all locally hired and contracted transportation providers, before they begin transporting any special education student receiving special transportation, on his or her needs and appropriate methods of meeting those needs; nor does it provide for any such student written information on the nature of any needs or problems that may cause difficulties, along with information on appropriate emergency measures. Narrative Description of Corrective Action: Paraprofessional Instructional Assistance, by contract, are allowed $275 per. For professional to offset costs of courses. Staff will be reminded of this availability In the fall, within the first two weeks of school, all staff are required to participate In, annual, on line training of civil rights, restraint, 504 etc. training. Specialized training is provided as necessary or required by individual student needs. These training include but are not limited to; restraint training, discrete trial methods, physical transfer and health needs, seizure intervention procedures etc.. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Administrative Council/PD Corrective Action Activity: Spring 2011 Committee 12 Evidence of Completion of the Corrective Action: Copies of attendance sheets from district provided professional development. Copies of PD request and completion forms. Copy of paraprofessional contract. Copies of specific instruction participation by provider. Description of Internal Monitoring Procedures: Quarterly review of budget and staff requests. Training verification by providers. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: SE 54 Professional Development Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not address the specific professional development needs identified in the CPR Department Order of Corrective Action: The district must ensure that all staff, including both special education and general education staff, are trained on: state and federal special education requirements and related local special education policies and procedures; analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate diverse learning styles of all students in the regular classroom. The district must provide in-service training for all locally hired and contracted transportation providers, before they begin transporting any special education student receiving special transportation, on his or her needs and appropriate methods of meeting those needs; and provide for any such student written information on the nature of any needs or problems that may cause difficulties, along with information on appropriate emergency measures. Required Elements of Progress Report(s): By March 1, 2011, submit a plan (including proposed agenda, tentative dates, and materials to be used) to provide training to all staff, including both special education and general education staff on: state and federal special education requirements and related local special education policies and procedures; analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate diverse learning styles of all students in the regular classroom. A plan (including proposed agenda, dates, and materials to be used) to provide in-service training for all locally hired and contracted transportation providers, before they begin transporting any special education student receiving special transportation, on his or her needs and appropriate methods of meeting those needs; and to provide for any such student written information on the nature of any needs or problems that may cause difficulties, along with information on appropriate emergency measures By May 31, 2011, submit 13 Evidence of training provided to all staff, including agenda, sign-in sheets and materials, on: state and federal special education requirements and related local special education policies and procedures; analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate diverse learning styles of all students in the regular classroom. Evidence of training, including agenda, sign-in sheets and materials, provided to all locally hired and contracted transportation providers, before they begin transporting any special education student receiving special transportation, on his or her needs and appropriate methods of meeting those needs; and to provide for any such student written information on the nature of any needs or problems that may cause difficulties, along with information on appropriate emergency measures. Progress Report Due Date(s): March 1, 2011; May 31, 2011 14 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Palmer Public Schools Corrective Action Plan Forms Program Area: Civil Rights Prepared by: Palmer Public Schools 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 8, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7 Information to be translated Rating: Partially implemented into languages other than English Department CPR Finding: According to interviews, review of student records, and documentation, the district does not consistently translate important information into the major languages spoken by parents or guardians with limited English skills. The district did not provide evidence of a system of oral interpretation to assist parents/guardians with limited English skills, including those who speak low-incidence languages. Narrative Description of Corrective Action: Coordination with ELE committee. Contact surrounding communities to identify existing translations for common notices and to identify a cost effective system for the translation of communications. The district currently uses Word 2010 and will utilize its translation capability for document translations. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELE Committee Corrective Action Activity: Fall 2011 Evidence of Completion of the Corrective Action: Copies of translated documents. Record review, and parent interviews. Description of Internal Monitoring Procedures: ELE committee agendas and minutes. Copies of translated documents. Record review. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7 Information to be translated into languages other than English Status of Corrective Action: Approved Partially Approved 15 Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): See SE 29 By March 1, 2011, submit a: Description of procedures the district uses to determine if the primary language of a student’s home is other than English and, if so, how the district provides translation/interpretation in that language. List of communities the district contacted about existing translations and copies of documents identified as available to the district. List of primary home languages that are spoken in the district if the primary language is other than English By May 31, 2011, conduct an internal review of the records of students whose primary home language is other than English to determine if communications with parents are provided in both English and the primary language of the home and submit: The number of student records reviewed; The number of student records in compliance (communications were provided in both English and the primary language of the home if such primary language is other than English); For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy the non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): March 1, 2011, May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 7B Structured learning time Rating: Partially implemented Department CPR Finding: According to a review of documents and interview, the district does not have documented policies and practices related to directed study, independent study, or technologyassisted learning, presentations by persons other than teachers, and school to work programs, or a procedure for the verification of hours spent by students in independent study or school-to-work programs. Narrative Description of Corrective Action: The district will develop a procedure for monitoring and documenting hours spent in all activities outside the traditional classroom. These activities will include but not be limited to independent study, on line learning, and school to work programs. Include these procedures in the student handbook and the course of study handbook. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: School to work Corrective Action Activity: Fall 2011 coordinator/principal and administrative council. 16 Evidence of Completion of the Corrective Action: Updated school handbook, record review. Description of Internal Monitoring Procedures: Drafts of proposed wording for handbook. Updated handbook. Record review. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 7B Structured learning time 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 March 1, 2011, submit a description of newly developed procedures for monitoring and documenting hours spent in all activities outside the traditional classroom. By May 31, 2011, submit a copy of the portion of the student handbook outlining the newly developed procedures for monitoring and documenting hours spent in all activities outside the traditional classroom, including, but not limited to, independent study, on line learning, and school to work programs. Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 9 Hiring and employment Rating: Partially implemented practices of prospective employers of students Department CPR Finding: The district submitted a form that employers recruiting at the school are required to sign that includes a statement that the employer complies with applicable federal and state laws prohibiting discrimination in hiring or employment practices, but did not submit signed copies of forms from those prospective employers. Narrative Description of Corrective Action: The school to work coordinator and guidance office will maintain a file of signed copies of employer statements of non discrimination. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal/school to work Corrective Action Activity: Spring 2011 coordinator. Evidence of Completion of the Corrective Action: Copies of signed forms. Description of Internal Monitoring Procedures: Copies of signed forms CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 9 Hiring and Status of Corrective Action: employment practices of prospective Approved Partially Approved employers of students Basis for Partial Approval or Disapproval: 17 Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By May 31, 2011, submit signed copies of forms that prospective employers signed during the 20102011 school year stating that the employer complies with applicable federal and state laws prohibiting discrimination in hiring or employment practices Progress Report Due Date(s): May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 10A Student handbooks and Rating: Partially implemented codes of conduct Department CPR Finding: The district did not submit a code of conduct for Old Mill Pond school. Document reviews and interviews indicate that no district handbooks contain appropriate procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans. The district handbooks contained non-discrimination and harassment policies, but they did not reference M.G. L. c.76, s.5. Handbooks did not contain procedures for accepting, investigating and resolving complaints for harassment. Narrative Description of Corrective Action: Meet with administrative council to discuss wording for student handbooks. Include final wording in 2011-12 handbooks Development of state required 2011 anti-bullying policy and procedures. Expected Date of Completion for Each Title/Role of Person(s) Responsible for Implementation: Superintendent/Building Corrective Action Activity : Fall 2011 Principals Evidence of Completion of the Corrective Action: 2011-12 Student Handbooks Description of Internal Monitoring Procedures: Draft of handbook wording CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 10A Student handbooks and codes of conduct 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 May 31, 2011 Submit a draft of the code of conduct for Old Mill Pond School that will be included in the 2011-2012 school year handbooks. Submit a draft of procedures for disciplining students with special needs and students with 504 accommodation plans that will be included in the 2011-2012 school year handbooks. Submit a draft of procedures for investigating and resolving complaints for harassment Progress Report Due Date(s): May 31, 2011 18 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 12A Annual and continuous Rating: Partially implemented notification concerning nondiscrimination and coordinators Department CPR Finding: According to the review of documentation, with the exception of the website homepage, district documents such as employment applications, job announcements, and school newspapers, do not contain notice that the district does not discriminate on the basis of race, color, national origin, sex, disability, religion, or sexual orientation. Narrative Description of Corrective Action: Through the administrative council, all administrators will be made aware of this finding. All documents generated by the central office or at the individual school level, including but not limited to job announcements, applications and school newspapers shall include the notice “The Palmer Public School District does not discriminate on the basis of race, color, national origin, sex, disability, religion, or sexual orientation” on all such documents. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Superintendent Corrective Action Activity: Winter 2010-11 Evidence of Completion of the Corrective Action: Dissemination of this corrective action plan item. Description of Internal Monitoring Procedures: Copy of memo. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 12A Annual and Status of Corrective Action: continuous notification concerning Approved Partially Approved nondiscrimination and coordinators Basis for Partial Approval or Disapproval: Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011, submit a copy of the memo sent to administrators regarding the requirement for annual and continuous notification concerning nondiscrimination and coordinators. By May 31, submit copies of district documents such as employment applications, job announcements, and school newspapers that contain notice that the district does not discriminate on the basis of race, color, national origin, sex, disability, religion, or sexual orientation. Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 14 Counseling and counseling materials free from bias and stereotypes 19 Rating: Partially implemented Department CPR Finding: A review of documentation and interviews indicate the district does not have a process in place to ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, religion, national origin, sexual orientation, disability, and homelessness. The district did not submit evidence that it: communicates effectively with limited-English-proficient and disabled students and facilitates their access to all programs and services offered by the district; provides limited-English-proficient students with the opportunity to receive guidance and counseling in a language they understand Narrative Description of Corrective Action: Coordination with ELE committee. For counseling, translators will be provided to students and guidance staff to assist in communication in the language of the student. Principals will be provided with phone number and contact information for Language Bridge Inc. of Springfield. The primary provider of translation services for the Palmer School District. Outreach to surrounding communities for possible additional resources and service providers. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Principal/ELE coordinator Corrective Action Activity: Spring 2011 Evidence of Completion of the Corrective Action: Documentation of service bills and contracts for services. Description of Internal Monitoring Procedures: Log of requests and copies of invoices for services. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 14 Counseling and Status of Corrective Action: counseling materials free from bias and Approved Partially Approved stereotypes Basis for Partial Approval or Disapproval: Disapproved Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011 submit a copy of the newly developed procedures to ensure that counseling and counseling materials are free from bias and stereotypes. By May 31, 2011, submit a log of requests and copies of invoices for services for language translation and interpretation services that were provided since procedures were developed. Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion 20 Rating: Partially implemented Department CPR Finding: According to a review of documentation and interviews: the district does not provide written notice to students age 16 or over and their parents or guardians within ten days from the student’s fifteenth consecutive unexcused absence. The notice must be in English and the family’s native language stating that the student and the parent or guardian may meet with a representative of the district within ten days from the date the notice was sent. At the request of the parent or guardian, the district may consent to an extension of the time for the meeting of not longer than fourteen days. the district does not send annual written notice to former students who have not yet earned their competency determination and who have not transferred to another school to inform them of the availability of publicly funded post-high school academic support programs and to encourage them to participate in those programs., the district does not send annual written notice by first class mail to the last known address of each such student who attended a high school in the district within the past two years. Narrative Description of Corrective Action: The High School Principal and guidance department will develop the following notice/; 1. Written notice to students age 16 or over and their parents or guardians within ten days from the student’s fifteenth consecutive unexcused absence. The notice must be in English and the family’s native language stating that the student and the parent or guardian may meet with a representative of the district within ten days from the date the notice was sent. At the request of the parent or guardian, the district may consent to an extension of the time for the meeting of not longer than fourteen days. 2. Written notice to former students who have not yet earned their competency determination and who have not transferred to another school to inform them of the availability of publicly funded post-high school academic support programs and to encourage them to participate in those programs. The High School Principal is in the process of applying for a grant for the “Gateway to College” program. A program designed to help high school dropouts and students on the verge of dropping out, to earn a high school diploma while also earning college credits. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: High School Principal/Guidance Corrective Action Activity: Spring 2011 Director. Evidence of Completion of the Corrective Action: Copies of Written Notices . Grant application. Description of Internal Monitoring Procedures: Copies of completed notices and record reviews. Notice of grant status. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion Status of Corrective Action: Approved Partially Approved 21 Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By March 1, 2011, submit copies of the written notices the district developed to send to: students age 16 or over and their parents or guardians within 10 days of the student’s fifteenth consecutive unexcused absence former students who have not yet earned their competency determination and who have not transferred to another school By May 31, 2011, submit copies of all of the written notices that the district has sent out to students since they were developed. By May 31, 2011, submit a copy of the “Gateway to College” grant proposal. Progress Report Due Date(s): March 1, 2011; May 31, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 18 Responsibilities of school Rating: Partially implemented principal Department CPR Finding: According to a review of documentation and interview, the district does not have procedures in place to ensure the provision of home or hospital programs. Narrative Description of Corrective Action: Title/Role of Person(s) Responsible for Implementation: Expected Date of Completion for Each Corrective Action Activity: Evidence of Completion of the Corrective Action: Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 18 Responsibilities of school principal Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not respond to this criterion. Department Order of Corrective Action: Submit a description of the procedures the principal of each school in the district has developed for ensuring the provision of home or hospital programs and services to students who require them, along with the detailed list of such students. 22 Required Elements of Progress Report(s): By March 1, 2011, Submit a description of the procedures the principal of each school in the district has developed for ensuring the provision of home or hospital programs and services to students who require them. By May 31, 2011, submit a list for the 2010-2011 school year, by school, of all students who have required provision of home and hospital services, including the services each student received, the amount of time the student made use of such services, and the name and role of the service provider responsible. Progress Report Due Date(s): March 1, 2011; May 1, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: CR 18A School district Rating: Partially implemented employment practices Department CPR Finding: According to the review of documentation, the district does not have employment policies and procedures in place, or a description of recruitment practices. Narrative Description of Corrective Action: Provide copies of School Committee Policies GCE and GCF Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Director of Special Education Corrective Action Activity: Dec. 2010 Evidence of Completion of the Corrective Action: Copies of policy GCE and GCF Description of Internal Monitoring Procedures: CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: CR 18A School district employment practices 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 March 1, 2011, submit copies of the district’s employment policies and a description of recruitment practices. Progress Report Due Date(s): March 1, 2011 23 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Charter School or District: Palmer Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Dr. Susan Farrell 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 8, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 Program Placement and Structure 24 Rating: Partially implemented 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. A review of district documents shows that the district does not currently have an ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes. Students in the Palmer Public School District do not receive direct ESL instruction by a licensed ESL teacher as required. Documentation indicates that while parts of a program of language support seem to be in place, that the number of hours of support are not consistent with recommended hours as outlined in the Department’s September 2009 guidance document: “Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students.” It is not clear as to how many LEP students there are currently in the Palmer Public School District due to conflicting documentation. Content instruction is based on the appropriate Massachusetts Curriculum Framework; however, it is clear that LEP students do not receive sheltered content instruction as no teachers have completed all of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, described in the Commissioner’s Memorandum of June 2004 (see findings ELE 15). Conflicting documentation was submitted in regards to how many teachers have completed the SEI Category workshops. It appears in one document that one teacher has taken Categories 1 and 2 and no other teachers have taken any of the workshop, while another document states, “Teachers of ELL students have all been trained in the use of MELA-O…” Narrative Description of Corrective Action: Palmer School District will develop an ELL committee. This committee will develop a curriculum based on the ELPBO. The committee will assure all students with ESL needs will be correctly identified. Once identified, students will receive the correct amount of services based on MEPA results. The district will contract services with a licensed ESL teacher for students who need direct services. The district will provide training to in house staff for SEI and maintain documentation to reflect participation in and completion of category trainings. The district will maintain documentation that accurately reflects the number of students identified as ELL and the services provided to each eligible student. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: Committee developed by February 2011, all other items by November 2011 Evidence of Completion of the Corrective Action: Minutes of ELL meetings, Curriculum documents, Documentation of testing, services and trainings. Description of Internal Monitoring Procedures: ELL committee will monitor progress monthly. 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 district is a low incidence district. The Department’s SIMS database shows 18 English language 25 learners (ELLs) enrolled in the 2010-2011 school year. Over the last two years Palmer’s enrollment of ELLs has more than doubled. For the development of the ESL curriculum, the district will assemble an ELL committee which will be in place by February, 2011. Such Committee will be responsible for most of the activities described in the Corrective Action Plan (CAP). However, the district did not indicate who would be heading and taking responsibility for the committee’s progress and flow of work, so that the ESL curriculum for all grade levels can be completed by the district’s established November, 2011 deadline. With regard to the number of ESL instruction hours for ELLs, the district’s plan is to first identify ELLs who need ESL services and then offer appropriate ESL hours of instruction. However, the hours entailed were not specified. “The Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students” recommends the followings hours of ESL instruction for ELLs: 2.5 hours per day (or 12.5 hours a week) to a full day for levels 1 and level 2; 1-2 per day (or 5-10 hours a week) for level 3, and 2.5 hours per week for level 4 and level 5. See ELE 14 concerning licensing requirements. See ELE 15 concerning content instruction and SEI category Training. Department Order of Corrective Action: Provide an ESL curriculum that is based on the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO). Provide intermediate steps for the district to follow toward curriculum development (for example, identify grade placement of ELLs and English proficiency levels and then work first on parts of the curriculum that would meet the needs of those ELLs.) Provide a schedule of all ELLs that indicates grade placement, English proficiency level, and ESL hours of instruction they receive. Provide a summary report on the district’s internal monitoring findings. Required Elements of Progress Report(s): By May 18, 2011, submit any parts of the ESL curriculum that have been completed. By September 15, 2011, submit a full ESL curriculum for all grades. By May 18, 2011, submit a schedule of all ELLs that indicates grade level placement, English proficiency levels and ESL instruction hours (e.g., a spreadsheet containing students’ name, grade level placement, proficiency levels, and hours of ESL instruction). Submit an update by September 15, 2011 By May 18, 2011, submit a summary report on the district’s findings of internal monitoring. Include names of staff responsible, results of internal monitoring, and actions taken to remedy any areas of non-compliance by May 18, 2011. Submit an update by September 15, 2011. Progress Report Due Date(s): May 18, 2011; September 15, 2011 26 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 6 Program Exit and Readiness Rating: Partially implemented Department CPR Finding: Documentation indicates that although the district developed a policy for re-designation of LEP students from LEP to FLEP, the policy does not provide specific exiting criteria. The district did not indicate an understanding of how to effectively use MEPA results as an important part of the re-designation process, and documentation did not clearly indicate that FLEP students would be monitored for two years after being re-designated. Narrative Description of Corrective Action: The district will develop procedures that clearly define exiting criteria using the MEPA results. The procedures will include guidelines for the ongoing monitoring of FLEP students for two years following redesignation. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Procedure documentation. Monitoring documentation. Description of Internal Monitoring Procedures: Monthly review by ELL committee by June, 2011. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 6 Program Exit and Readiness 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): Provide procedures documenting exit criteria using MEPA results along with guidelines for the ongoing monitoring of FLEP students for two years following re-designation by May 18, 2011. Submit evidence that administrative and other school district staff was informed of exit criteria procedures mentioned above by May 18, 2011. Progress Report Due Date: May 18, 2011 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: Document review and interviews indicate that the district has not yet developed ways to include parents or guardians of LEP students in matters pertaining to their children’s education. 27 Narrative Description of Corrective Action: The district will develop procedures to increase parent involvement. The district will maintain documentation of attempts to include parents or guardians of LEP students in matters pertaining to their child’s education. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Documents of notices and invitations to parents, minutes of parent meetings Description of Internal Monitoring Procedures: ELL Committee will monitor quarterly CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 7 Parent Involvement 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 May 18, 2011, submit a description of the different strategies the district plans to use to increase participation of ELE parents or guardians in matters pertaining to their children’s education. By September 15, 2011, submit evidence of outreach to ELE parents/guardians, including copies of notices, invitations to meetings or activities, attendance sheets, meeting minutes, agendas, phone call lists. Progress Report Due Date(s): May 18, 2011; September 15, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 8 Declining Entry to a Program Rating: Partially implemented Department CPR Finding: Document review and interviews indicate that the district did not provide English language support to students whose parents have declined entry to a sheltered English immersion, two-way bilingual or other ELE program Narrative Description of Corrective Action: The district will provide parents who decline services with a full description, in a language they can understand, of all educational opportunities available to the student. Students will be provided with English language support as required by Mass DESE, state and federal laws. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Building Principal Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Documentation review and interviews Description of Internal Monitoring Procedures: Review by ELL committee quarterly 28 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 Department Order of Corrective Action: Required Elements of Progress Report(s): By May 18, 2011, submit a description of all English language supports available to ELE students, whose parents have declined entry to a SEI, two-way bilingual or other ELE program, which the district will provide to parents, in a language they can understand. By September 15, 2011, submit a list of ELE students whose parents have declined entry to a SEI, two-way bilingual or other ELE program and the different language supports they have had provided to them from the date that the description of such supports was provided to the Department. Progress Report Due Date(s): May 18, 2011; September 15, 2011 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: A review of district documents shows that the district does not currently have an ESL curriculum based on the Massachusetts English Language Proficiency Benchmarks and Outcomes (ELPBO); therefore, ESL/ELD instruction is not based on the ELPBO at all grade levels as required. The district did not indicate how students are grouped for any grade level, however the documentation indicated that at times the push-in model is used at the Elementary level. Narrative Description of Corrective Action: The district will develop an ESL curriculum based on the ELPBO. The district will provide guidelines on how to group students. The district will maintain documentation of student groupings. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Documentation of curriculum and groupings Description of Internal Monitoring Procedures: Monthly monitoring by ELL committee 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: See also ELE 5 concerning ESL curriculum. The district proposed developing guidelines on grouping students as a teaching strategy to provide ESL instruction. ELL groups can be mixed by proficiency level and/or grade levels as long as no more than 2-3 grade levels are considered and ELL proficiency levels are the same. Other factors that must be 29 taken into consideration in grouping ELLs are: maturity, literacy level, cultural considerations and the students’ personalities. Department Order of Corrective Action: See ELE 5 concerning the curriculum. Provide guidelines on how the district will group students for ESL instructional purposes. Inform administrative and other school district staff of procedures to be followed when grouping ELLs for ESL instruction. Required Elements of Progress Report(s): By May 18, 2011, submit guidelines on grouping of ELLs for ESL instructional purposes. By May 18, 2011, submit evidence that administrative and other school district staff was informed of procedures to be followed when grouping ELLs for ESL instruction purposes. Progress Report Due Date(s): May 18, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 10 Parent Notification Rating: Partially implemented Department CPR Finding: A review of district documents and student records demonstrates that the district did not submit sample notification letters in the home language(s) informing parents of the reasons for identification of the student as LEP, 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 will develop sample notification documents. The district will provide notification documents to parents in a language they can understand when they identify a student as LEP, recommend a program placement or change in placement and other reasons as listed above. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Sample letters and notifications in various languages Description of Internal Monitoring Procedures: Monthly review by ELL Committee CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Parent Notification Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Notification letters to parents must be provided in a language they can understand, annually, or when a student is identified as LEP, a program placement or change in placement is recommended. The letters must contain the reason for the identification of the student, the child’s level of English proficiency, program placement or method of instruction, and the parent’s right to apply for a waiver. 30 Department Order of Corrective Action: Required Elements of Progress Report(s): By May 18, 2011, submit drafts of the sample parent notification letters with all required elements in the home language(s) of the district. By September 15, 2011, conduct an administrative review of ELE records to ensure that parents are receiving the notification letters with all required elements, at least annually. Please submit: The number of student records reviewed; The number of student records in compliance; For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance; and The district’s plan to remedy any continuing non-compliance *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): May 18, 2011; September 15, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal Access to Academic Programs and Services Rating: Partially implemented Department CPR Finding: Document review and interviews indicate that the district did not indicate that notices such as activities, responsibilities, and academic standards provided to all students are provided to limited English proficient (LEP) students in a language and mode of communication that they understand. The district did not submit a list of all academic programs and services. Narrative Description of Corrective Action: The district will send notices for activities, responsibilities, and academic standards to all students including students with limited English proficient (LEP) in a language and mode of communication that they understand. The district will maintain a list of all academic programs and services. Title/Role of Person(s) Responsible for Implementation: ELL Committee Expected Date of Completion for Each Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Documentation of notices and list of programs Description of Internal Monitoring Procedures: ELL Committee will monitor monthly. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 11 Equal Access to Academic Programs and Services Status of Corrective Action: Approved Partially Approved 31 Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By May 18, 2011, submit a list of languages of ELE students for which the district will provide translations and a plan to conduct the translations. Submit a list of all academic programs and services. By September 15, 2011, submit a sampling of the notices that are provided to all students that were provided to ELE students in a language they understand. Progress Report Due Date(s): May 18, 2011; September 15, 2011 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 12 Equal Access to Nonacademic and Extracurricular Programs Rating: Partially implemented Department CPR Finding: Document reviews and interviews reveal that the district did not provide information to LEP students regarding, extracurricular activities and school events in a language they understand, or a list of sample extracurricular activities in which LEP students currently participate. Narrative Description of Corrective Action: The district will provide information to LEP students regarding, extracurricular activities and school events in a language they understand. The district will maintain a list of sample extracurricular activities in which LEP students currently participate. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Documentation of activity notices and list of sample extracurricular activities in which LEP students currently participate. Description of Internal Monitoring Procedures: ELL Committee to monitor quarterly CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 12 Equal Access to Nonacademic and Extracurricular Programs Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By May 18, 2011, submit a list of languages of ELE students for which the district will have to provide translations and a plan to conduct the translations. Submit a list of all extracurricular activities in which LEP students currently participate. By September 15, 2011, submit a sampling of the notices that are provided to all students that were provided to ELE students in a language they understand. Progress Report Due Date(s): May 18, 2011; September 15, 2011 32 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 13 Follow-up Support Rating: Partially implemented Department CPR Finding: Student record review and interviews show that the district did not provide evidence that it actively monitors students who have exited an English learner education program for two years and provides language support services to those students, if needed Narrative Description of Corrective Action: The district will actively monitor students who have exited an English learner education program for two years. The district will provide FLEP students with language support services, if needed. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee, Building Corrective Action Activity: November 2011 Principal Evidence of Completion of the Corrective Action: Documentation of student monitoring and services provided. Description of Internal Monitoring Procedures: ELL Committee to monitor quarterly CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 13 Follow-up Support Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: Department Order of Corrective Action: Required Elements of Progress Report(s): By May 18, 2011 submit a description of policies and procedures for actively monitoring, for two years, all students who have exited an ELE program. By September 15, 2011, provide evidence, such as a description of the procedure used by the district, and copies of monitoring forms, that the district has monitored students who have exited an ELE program for two years following their exit. Submit a list of FLEP students and the language support services they were provided. Progress Report Due Date(s): May 18, 2011; September 15, 2011 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 by the district indicates that there are no licensed ESL teachers working with students in the Palmer Public Schools, as required. 33 Narrative Description of Corrective Action: The district will contract a licensed ESL teacher as needed to provide services for ELE students. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Coordinator Corrective Action Activity: June 2011 Evidence of Completion of the Corrective Action: List of available contract ESL providers, service contracts. Description of Internal Monitoring Procedures: ELL committee to review bi-annually CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 14 Licensure Requirements Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district is planning to contract a licensed ESL teacher to provide services to English language learners. The bi-annual internal monitoring procedure proposed by the district to ensure that ESL staff has the required ESL license may not accurately capture changes in ESL personnel during the school year. Quarterly monitoring of ESL staff in the district would ensure a timely reporting of ESL staff changes and timely closing of gaps in ESL personnel. Department Order of Corrective Action: Provide ESL license(s) for all ESL teacher(s) contracted. Required Elements of Progress Report(s): By May 18, 2011, submit copies of ESL license (s) and hiring letters for all ESL teacher(s) contracted. Progress Report Due Date(s): May 18, 2011 34 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 15 Professional Development Requirements Rating: Partially implemented Department CPR Finding: Content instruction is based on the appropriate Massachusetts Curriculum Framework; however, it is clear that LEP students do not receive sheltered content instruction as no teachers have completed all of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction, as described in the Commissioner’s Memorandum of June 2004. However, the district indicated that communication has begun with Hampshire Educational Collaborative regarding their Center for English Language Education. Narrative Description of Corrective Action: Hampshire Educational Collaborative will be contracted with to provide on site PD in SEI. Interested staff will be trained in SEI. LEP students will receive sheltered content instruction with trained teachers. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ELL Committee Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: Contracts with HEC, teacher training certificates. Description of Internal Monitoring Procedures: ELL Committee to monitor monthly. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: 15 Professional Development Requirements Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: In regard to content instruction, the district is planning to contract with Hampshire Educational Collaborative to provide SEI PD training to teachers on site. The district could consider focusing its SEI category training efforts first on content area teachers who are instructing ELLs so that they can complete their training in all 4 categories and subsequently, ensure ELLs are placed with SEI trained teachers. Department Order of Corrective Action: Provide a list of content area teachers, particularly those instructing ELLs, that shows SEI training categories completed. Required Elements of Progress Report(s): By May 18, 2011, submit evidence of the implementation of the SEI category training plan. Include attendance sheets of content area teachers instructing ELLs, and indicate grades/subjects taught, and dates of SEI training categories completed. Submit an update by September 15, 2011. By May 18, 2011, submit a sample of ELLs from the district’s schools indicating placement with content area teachers who have completed all four categories of SEI. Submit an update by September 15, 2011. 35 Progress Report Due Date(s): May 18, 2011; September 15, 2011 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: Review of district documentation, and interviews indicate the district does not conduct periodic evaluations of the effectiveness of the ELE program in developing students’ English language skills and increasing their ability to participate meaningfully in the educational program, or that it takes steps to make appropriate program adjustments or changes that are responsive to the outcomes of a program evaluation. Narrative Description of Corrective Action: The district will conduct periodic evaluations of the effectiveness of the ELE program. Evaluations of student progress will occur at the same frequency of report cards and program evaluations will occur annually. Adjustments to the programs will be made based on the results of the evaluations. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: ESL Teachers, ELL Corrective Action Activity: November 2011 Committee Evidence of Completion of the Corrective Action: Evaluation results Description of Internal Monitoring Procedures: ELL Committee to monitor quarterly 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: Required Elements of Progress Report(s): By May 18, 2011, submit a description of the process used and copies of instruments the district will use to evaluate the effectiveness of the ELE program. By September 15, 2011, submit an evaluation report, and a description of the possible program adjustments or changes that will be made as a result of the evaluation. Progress Report Due Date(s): May 18, 2011; September 15, 2011 36