Charter School or District: Palmer Public Schools Corrective Action Plan Forms

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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
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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
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