MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Sudbury CPR Onsite Year: 2012-2013 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 09/04/2013. Mandatory One-Year Compliance Date: 09/04/2014 Summary of Required Corrective Action Plans in this Report Criterion SE 18B Criterion Title Determination of placement; provision of IEP to parent SE 55 Special education facilities and classrooms CR 23 Comparability of facilities CR 25 Institutional self-evaluation CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18B Determination of placement; provision of IEP to parent Partially Implemented Department CPR Findings: Student record review indicated that following the development of the IEP, the district does not consistently provide the proposed IEP and placement to the parent immediately. Description of Corrective Action: The district has developed a new system for processing IEPs in order to better facilitate timely processing and submission of the documents to parents. The new system was in place as of September 3, 2013 and is as follows: 1. Liaison writes IEP, puts packet together and gives to building Team Chair within 3 days of the meeting date. 2. Team Chair meets with administrators, as needed, to review/correct and return IEP package to liaison for any technical or content corrections within 2 days of receiving the IEP. 3. Liaison corrects/reprints and gives the IEP back to the Team Chair within 24 hours and resubmits to Team Chair. 4. Team Chair reviews final/corrected IEP, signs and send IEP package to Central office within 24 hours. 5. A completed IEP package is expected to be sent to the central special education office for administrator signature, processing, and mailing to parents. The timeline for the entire process is one week (eg - Tuesday to Tuesday). This new process addresses the delays that have occurred when errors need to be corrected prior to sending the IEP to parents. The new process also allows principals to be involved and offer supervisory and evaluative support to the Teams to maintain compliance. Title/Role(s) of Responsible Persons: Expected Date of Deborah N Dixson, Director of Student Services Completion: 06/30/2014 Evidence of Completion of the Corrective Action: All required school signatures on IEPs will be within 5 days of Team meetings. Mailing of IEPs will be within 10 days of Team meetings. Description of Internal Monitoring Procedures: A spreadsheet will be maintained at the central office which includes timelines, due dates, date received, and date mailed to parents. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 2 CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18B Determination of placement; provision of IEP to parent Basis for Status Decision: Corrective Action Plan Status: Approved Status Date: 10/17/2013 Department Order of Corrective Action: Required Elements of Progress Report(s): The district will provide a narrative description of its updated procedures related to providing parents with two IEPs/proposed placement copies within ten days of IEP development to include its administrative internal oversight and tracking system, e.g. spreadsheet review, identifying the person(s) responsible with date of the system's implementation to ensure compliance. Also provide evidence of staff training on this procedure, which will include but not be limited to memorandums, email correspondence, training agenda, attendance sheets and copies of the materials presented. Please submit to the ESE by January 15, 2014. Subsequent to staff training, submit the results of an administrative review of a sample of student records from all levels indicating on the Notice of Proposed School District Action (N1) that two copies of the IEP have been provided to parents. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to ESE on or before by May 30, 2014. *Please note when conducting administrative monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 01/15/2014 05/30/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 3 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 55 Special education facilities and classrooms Partially Implemented Department CPR Findings: At Curtis Middle School, speech and language groups meet and pass through the Skills Group scheduled in an adjoining room, thereby disrupting instruction. Description of Corrective Action: Over the course of the year, the director and principal will explore alternative space and room options for the speech pathologist. Title/Role(s) of Responsible Persons: Expected Date of Deborah N Dixson, Director of Student Services Completion: Stephen Lambert, Principal, Curtis Middle School 08/30/2014 Evidence of Completion of the Corrective Action: By the 14-15 school year, the speech pathologist will be reassigned to a room that is utilized for only that purpose. Description of Internal Monitoring Procedures: There will be ongoing discussions throughout the year to resolve this. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 55 Special education facilities and Approved classrooms Status Date: 10/17/2013 Basis for Status Decision: The school district's plan does not address interruptions to instruction for the current school year. Department Order of Corrective Action: The school district must assign designated space for the speech pathologist at Curtis Middle School that does not require speech groups to pass through other rooms while in use thereby disrupting instruction. *Please note that school districts must demonstrate effective resolution of noncompliance identified by the Department as soon as possible but in no case later than one year from the issuance of the Department's Final Program Review Report. Required Elements of Progress Report(s): Provide a letter of written assurance from the Superintendent and Principal at Curtis Middle School that there is a new space assigned to the speech pathologist for the 201314 school year, a floor plan with the new space indicated, and student delivery schedules for speech and language. Please submit to ESE on or before January 15, 2014. The ESE will conduct an onsite visit to observe this new space by 05/30/2014. Progress Report Due Date(s): 01/15/2014 05/30/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 23 Comparability of facilities Partially Implemented Department CPR Findings: At the Curtis Middle School, staff interviews and onsite observation revealed that English Language Education instruction is delivered in the school library while the library is occupied with other student groups; therefore, auditory distractions are frequent. Description of Corrective Action: This item is already corrected, with ELL instruction taking place in a dedicated space this year. Title/Role(s) of Responsible Persons: Expected Date of Todd Curtis, Assistant Superintendent Completion: Stephen Lambert, ECMS Principal 09/03/2013 Evidence of Completion of the Corrective Action: ELL instruction is currently being delivered in a dedicated space. Description of Internal Monitoring Procedures: Continue to monitor. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 23 Comparability of facilities Corrective Action Plan Status: Approved Status Date: 10/17/2013 Basis for Status Decision: Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a letter of written assurance from the Superintendent and Principal that at Curtis Middle School, the district has provided English language learners with instructional space that is comparable to the instructional space of others. Please submit to ESE by January 15, 2014. The Department will conduct an onsite visit to verify this space by May 30, 2014. Progress Report Due Date(s): 01/15/2014 05/30/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 5 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: Documentation and staff interviews indicated that the district does not evaluate all aspects of its K-8 programming annually to ensure that all students, regardless of race, color, sex, gender identity, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities. Description of Corrective Action: The district will conduct an annual self-evaluation of programming related to ensuring equal access. The process will be developed during the course of this year through examination of procedures used by other districts and/or exemplars that may be available, with an expectation that we will be able to review the proposed process and initial data at our administrative summer retreat in August of 2014. Title/Role(s) of Responsible Persons: Expected Date of Todd Curtis, Assistant Superintendent Completion: 08/30/2014 Evidence of Completion of the Corrective Action: Documented process in place. Description of Internal Monitoring Procedures: We will place the development of the process on our administrative team agenda at regular intervals in order to provide updates and opportunities for revision and correction. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Partially Approved Status Date: 10/17/2013 Basis for Status Decision: *Please note that school districts must demonstrate effective resolution of noncompliance identified by the Department as soon as possible but in no case later than one year from the issuance of the Department's Final Program Review Report. Department Order of Corrective Action: The district must not wait until its summer August 2014 administrative retreat to remedy noncompliance. Required Elements of Progress Report(s): The district will submit its planned scheduled dates and projected list of name(s) and role(s) of those participating in conducting the annual self-evaluation of its K-8 programming related to ensuring equal access to all programs, including athletics and other extracurricular activities. Please submit this to ESE by January 15, 2014. By May 30, 2014, please submit to the Department the self-evaluation results including but not limited to data/findings of evaluations along with a narrative of administrative plans to remedy any identified noncompliance. Progress Report Due Date(s): 01/15/2014 05/30/2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 6 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW District: Sudbury Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Todd Curtis / Assistant Superintendent 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: April 1, 2015 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 Program Placement and Rating: Partially Implemented Structure Department CPR Finding: Documentation submitted by the district indicated that ELL students at all proficiency levels receive 60 minutes of direct ESL instruction per week at the district’s elementary schools and 50-100 minutes per week at the district’s middle school. Current hours of ESL instruction provided to ELLs at all proficiency levels are insufficient and, therefore, inconsistent with Department guidelines. Please see the “Transitional Guidance on Identification, Assessment, Placement, and Reclassification of English Language Learners August 2013” as found on http://www.doe.mass.edu/ell/guidance_laws.html. Document review indicated that the district does not have an ESL curriculum used for direct ESL instruction or a plan to develop one that is aligned to the Massachusetts Curriculum Frameworks and the WIDA ELD Standards. See the Department’s WIDA English Language Development Standards Implementation Guide (Part I) at http://www.doe.mass.edu/ell/wida/Guidance-p1.pdf MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 7 PART I - Service Time The CPR Report of Findings notes that “current hours of instruction provided to ELLs at all proficiency levels are insufficient and, therefore, inconsistent with Department guidelines.” During this school year, we have taken the immediate step of adding twelve instructional hours through an ESL tutor supervised by our single ESL teacher, while we prepare to evaluate the pattern of service and enrollment on a longer-term basis. These hours provide more support at the elementary level from the tutor directly, but also allow our licensed ESL teacher to see students, particularly at the middle school, more frequently, and to collaborate with content-area teachers more frequently. This evaluation, in particular, needs to weigh grouping strategies that would result in more time but significant spans of age and proficiency levels against smaller groups that use less time, and assess staffing and budgetary requirements to best meet student learning needs. PART II - WIDA Implementation The district’s plan for integrating the WIDA ELD standards into content area and ESL curriculum will rely upon the guidance provided by the Department in the August 2013 publication WIDA English Language Development Standards Implementation Guide (Part I). As noted in that publication, this is a significant undertaking and a multi-year process, and one in which district leaders have flexibility to develop a plan and approach for WIDA integration that reflects their local context and initiatives. The local context in the Sudbury Public Schools includes being a low-incidence district in which less than 1% of enrolled students qualify as English Language Learners. These students are spread across four of our five schools in the current year, and typically enrolled in a variety of grade levels at those different schools. The other element of district context that impacts our timeline is the recent receipt of our Coordinated Program Review results. In the following sections, numbers noted in parentheses refer to “strategies for developing an effective WIDA implementation plan” described on pages 10-12 in the above-referenced document. In this 201314 school year, our work has focused on two elements: 1. Providing support to our single ELE teacher and having her access Department provided and other professional development support to become familiar with the WIDA standards (#1, p. 10) 2. Increasing the collaboration time available for work between the ELE teacher and content area teachers, particularly at the content-rich secondary level (#7, p. 11) Beginning in the 2014-15 school year, the district will follow the timeline set out in the above-referenced document and add two major items: 3. Participation in RETELL course work by a core group of SPS teachers and administrators. This will allow us to provide the necessary training to district curriculum leaders and school administrators (#1, #4, #10, p. 10). 4. Formal development of “a short term and a long term plan”. This plan will provide greater detail about how to make strategic connections to our other important work such as Common Core and Educator Evaluation (#3), along with implementing professional development for all staff (#4). This long-term plan would cover from the 2014-15 school year through the 2018-2019 school year, modeled after the five year process shown in the Implementation Guide. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 8 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Todd Curtis / Assistant Corrective Action Activity: Embedded in Superintendent above. Evidence of Completion of the Corrective Action: Increased service time to ELL students, increased collaboration between ELE staff and content-area teachers. Formal plan for WIDA alignment based on evaluation conducted in item #4 above. Description of Internal Monitoring Procedures: The assistant superintendent and ELL staff hold monthly meetings to review the program and student progress. Larger programmatic monitoring will take place during weekly meetings of the Central Office Cabinet. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 5 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district reported in its proposed CAP that an immediate step was taken upon the receipt of the Coordinated Program Review results, by adding twelve instructional hours through an ESL tutor supervised by an ESL teacher. The district also states that these hours provide more support at the elementary level from the tutor directly. The district should note that that ESL instruction consistent with Chapter 71A can only be delivered by an ESL licensed teacher. In case the ESL tutor who provides ESL instruction in the elementary school is ESL licensed, please submit the license information. The Department appreciates that the district is following the guidance provided by the Department in the document “WIDA English Language Development Standards Implementation Guide (Part I)”. The district refers to pages 10 -12 in its proposed CAP, where some helpful strategies are suggested to develop an effective WIDA implementation plan. Such a plan is crucial to integrate the WIDA ELD standards into content area and ESL curriculum that districts currently use for instruction. However, the Department’s finding regarding the curriculum states that the district does not have an ESL curriculum used for direct ESL instruction. Therefore, the district’s plan to correct the noncompliance indicated in the Coordinated Program Review Final Report should also include a plan to develop an ESL curriculum that is aligned to the Massachusetts Curriculum Frameworks and the WIDA ELD Standards. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): 1) Please, complete district information in the attached spreadsheet labeled ELL List by school for each ELL student in the district. 2) Submit a plan that includes information about a process for developing ESL curriculum that integrates WIDA ELD standards as well as a plan for WIDA implementation training including information such as WIDA training opportunities for the district staff, responsible district staff, meeting dates, minutes and sign-in sheets as well as timelines for implementation 3) Please, submit the license information for the ESL tutor who provides ESL instruction in the district’s elementary schools. Progress Report Due Date(s): December 1, 2014, February 15, 2015 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 9 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 16 Equitable Facilities Rating: Partially Implemented Department CPR Finding: At the Curtis Middle School, staff interviews and onsite observation revealed that English Language Education instruction is delivered in the school library while the library is occupied with other student groups; therefore, auditory distractions are frequent. Narrative Description of Corrective Action: Equitable facilities for LEP students and delivery of ESL instruction were addressed as part of the CAP for the Civil Rights portion of our CPR (CR23). The Department will be visiting onsite in May of 2014 to verify assurances already submitted. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Todd Curtis / Assistant Corrective Action Activity: Completed Superintendent Evidence of Completion of the Corrective Action: Separate, dedicated space for ELL instruction. Description of Internal Monitoring Procedures: Continued monitoring by building administration in conjunction with district administration. Monthly meetings of assistant superintendent and ELL staff; general facilities planning in the context of annual budget procedures. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 16 Equitable Facilities Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: A site visit was conducted on May 23, 2014 and the ELL classroom was moved to Room 152 and meets the standard for instructional purposes. Department Order of Corrective Action: Required Elements of Progress Report(s): N/A Progress Report Due Date(s): No further progress reports are required for this criterion. COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 17 Program Evaluation Rating: Not Implemented Department CPR Finding: Interviews indicate the district does not evaluate the effectiveness of its ELL programs and services. No program evaluation materials were submitted as evidence of compliance for this criterion. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 10 Narrative Description of Corrective Action: The district reviews the effectiveness of its ELE program in the context of larger reviews of the effectiveness of all programs. The district is developing a more complete self-evaluation process related to the CAP for the Civil Rights portion of our CPR (CR25). This will assist us in evaluating the participation of LEP students in other elements of the educational program. In addition to that process, the district will examine achievement data specific to ELL students. These activities include: 1. Reviews of student data of ELE assessments such as WIDA 2. Reviews of student MCAS data, including comparisons to non-LEP peers 3. Reviews of local student achievement data, such as F&P reading assessments delivered in the SEI environment. The district monitors student progress through monthly meetings between the assistant superintendent, who oversees ELE programming, and ELE teaching staff, as well as through school-level reviews of student achievement data conducted by school administrators and teaching staff. Title/Role of Person(s) Responsible for Implementation: Todd Curtis / Assistant Superintendent Expected Date of Completion for Each Corrective Action Activity: Ongoing. Current school year progress reviewed beginning with yearend local data in June 2014, supplemented by state (MCAS) data in fall 2014. Evidence of Completion of the Corrective Action: Written report specifically directed at ELL achievement, to be produced by assistant superintendent no later than April 1, 2015. Description of Internal Monitoring Procedures: Monthly meetings between assistant superintendent and ELL staff. 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: The district outlined plans to examine achievement data specific to ELL students. The planned activities include: 1. Reviews of student data of ELE assessments such as WIDA 2. Reviews of student MCAS data, including comparisons to non-LEP peers 3. Reviews of local student achievement data, such as F&P reading assessments delivered in the SEI environment. Department Order of Corrective Action: Required Elements of Progress Report(s): Please submit copies of agendas, meeting minutes and sign-in sheets where discussions of ELL student achievement take place. Submit these along with an outline of the planned ELL Evaluation Tool by December 1, 2014. Submit the results of the selfevaluation process employed by the district to the DESE by February 15, 2015. Progress Report Due Date(s): December 1, 2014, February 15, 2015 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Sudbury CPR Corrective Action Plan 11