MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW District: Westford Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Christine M. Francis, Ed.D. 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: October 19, 2012 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Not Implemented Criterion & Topic: ELE 4 – Waiver Procedures Department CPR Finding: Documentation indicated that parents are not consistently informed of their right to apply for a waiver. Additionally, interviews demonstrated that key personnel responsible for implementing these procedures are not clear on what the difference is between applying for a waiver and a parent choosing to opt out of the program. Narrative Description of Corrective Action: We will review our current form and the specific guidelines and definitions for “opt-out” and “waiver”. We will update our form to make the differences more explicit. We will notify all personnel involved about these updates and create a process so that the updated form is part of our district’s ELE procedures. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent, ELL Corrective Action Activity: spring 2012 teachers Evidence of Completion of the Corrective Action: updated form Description of Internal Monitoring Procedures: yearly program evaluation CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 4 – Waiver Procedures Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not fully describe their corrective action steps and internal monitoring process for this criterion. 1 Department Order of Corrective Action: The district will review and revise their forms and procedures related to the waiver and opting out process for LEP students. Once that is complete the district will train all relevant staff members on use of the revised forms and procedures. Further, the district will conduct a post training administrative file review to ensure ongoing compliance. Required Elements of Progress Report(s): The district will provide a narrative description of their revised procedures related to the waiver and opt-out process for LEP students, along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by January 30, 2013. Submit the results of an administrative review of student records. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before by March 29, 2013. *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): January 30, 2013 and March 29, 2013 2 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 – Program Placement Rating: Partially Implemented and Structure Department CPR Finding: Westford Public School district is a low incidence district. The district reported 52 English language learners (ELLs); the Department’s SIMS data base show 43 ELLs, but it does not track FLEP (Formerly Limited English Proficient) students. More than half of the ELLs are enrolled in grades 3-5 (32), eight (8) are in middle school, and only three (3) ELLs are enrolled in high school. The district states that it places English language learners (ELLs) in a sheltered English immersion (SEI) program and that licensed ESL teachers work with ELLs on an individual basis and/or in small groups. However, from documentation submitted, the district’s program model is not evident. Although ESL instruction encompasses the four language domains of listening, speaking, reading and writing, the district does not have an ESL curriculum that is based on the English Language Proficiency Benchmarks and Outcomes (ELPBO). In this regard, the district should note that the ELPBO will be phased out in the coming months, and any curricula work for ELLs that the district engages in going forward should be able to stand alone and withstand changes as requested. Also, documents reviewed indicate that the hours of ESL instruction the district provides to English language learners at all levels at the elementary school, with some exceptions in middle school and high school, is not equivalent to the recommended hours as outlined in the Department’s 2009 “Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students.” ELLs placed in level 4 of English proficiency at the middle and high school do - receive the recommended hours of instruction. The Department’s guidelines recommend that students in level 1 and 2 receive minimally 2.5 hours of ESL instruction a day; those in level 3, 1-2 hours per day, and those placed in levels 4 and 5, 2.5 hours per week. Content instruction is based on the appropriate Massachusetts Curriculum Frameworks; however, review of district’s documents shows that ELE students are not receiving sheltered content instruction as the training teachers have received has been very limited. For example, only one teacher has completed all four of the required categories of SEI professional development focused on the skills and knowledge necessary for sheltering instruction and described in the Commissioner’s Memorandum of June 2004 (see findings in ELE 15); ten (10) teachers have completed three of the four SEI category trainings; sixteen (16) teachers have completed training in two categories, and twenty-five (25) have completed one of the four category trainings. Based on the findings described above, the Department has determined that the district is not offering a SEI program that meets the requirements of Chapter 71A. 3 Narrative Description of Corrective Action: We will revise our current FLEP form with current assessment information and delineate the process to monitor these students. We will update our curriculum according to the new ELL standards which are developed. We are now carefully prescribing and delivering the required number of hours of instruction for ELL students. We have arranged for Category 2 training for 25 teachers, beginning in January. We will develop training opportunities in Categories 3 and 4 once the DESE has informed us of the new guidelines in this regard. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent, ELL Corrective Action Activity: spring 2012 teachers; Director of Pupil Services Evidence of Completion of the Corrective Action: documents as stated above; completion of Category 2 training by 25 teachers Description of Internal Monitoring Procedures: yearly program evaluation CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Criterion: : ELE 5 – Program Approved Partially Approved Disapproved Placement and Structure Basis for Partial Approval or Disapproval: The district committed to a schedule of SEI PD, but it is not clear how the trained teachers will be linked with ELLs. In addition, the training has changed since the proposed CAP was submitted. The district must have a process in place and documentation for monitoring FLEP students. Forms were not submitted for ESE review. The district states that it is now delivering appropriate hours of ESL, but does not provide evidence of this. The yearly program evaluation is not a timely means of monitoring the corrective action that is necessary. Department Order of Corrective Action: 1. Provide the Department the plan for making the SEI cohort training available to the core academic teachers of ELLs and the building administrators who supervise such teachers and to arrange for the participation of such teachers and administrators in the training. 2. Provide the Department with the district’s new ESL/ELD curriculum, which should be aligned with all Massachusetts Curriculum Frameworks (e.g., English/Language Arts, mathematics, science, social studies) and the WIDA English language development standards. See http://www.wida.us/standards/eld.aspx. 3. Provide the Department with evidence that all ELL students receive sufficient ESL instruction, consistent with the students’ levels of English proficiency and Department guidance (http://www.doe.mass.edu/mcas/mepa/2009/guidance.doc). 4. Provide the process and form the district will use to monitor students who have been reclassified as FLEP, and describe how the district has ensured that appropriate staff members are aware of this process and this form. Provide all of the above by January 30, 2013. 4 Required Elements of Progress Report(s): By March 29, 2013 provide a report of the monitoring of the following: 1. The status of implementation of the plan for making SEI cohort training available to the core academic teachers of ELLs and the building administrators who supervise them. 2. The implementation of the new ESL/ELD Curriculum, which should be aligned with all Massachusetts Curriculum Frameworks (e.g., English/Language Arts, mathematics, science, social studies) and the WIDA English language development standards. 3. A review of ELL student records at all levels, elementary, middle and high school, in order to determine implementation of sufficient hours of ESL instruction, consistent with students’ levels of English proficiency. 4. A review of ELL student records at all levels (elementary, middle and high school) in order to determine implementation of the FLEP monitoring form and exit procedures. *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 the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). Progress Report Due Date(s): January 30, 2013 and March 29, 2013 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 showed that the district has appropriate program exit criteria, however, the district’s policy did not include monitoring of ELLs for two years (for support needs and continued adequate performance) after students are transitioned to formerly limited English proficient (FLEP) status. Narrative Description of Corrective Action: As indicated above on ELE5, we will review our current FLEP form and the specific guidelines to monitor these students. We will notify all personnel involved about these updates and create a process so that the updated form is part of our district’s ELE procedures. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent, ELL Corrective Action Activity: spring 2012 teachers Evidence of Completion of the Corrective Action: revised form Description of Internal Monitoring Procedures: yearly program evaluation 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 Basis for Partial Approval or Disapproval: See ELE 5. Department Order of Corrective Action: See ELE 5. 5 Disapproved Required Elements of Progress Report(s): See ELE 5 concerning the FLEP monitoring form, and internal monitoring of the district’s use of the form. Progress Report Due Date(s): January 30, 2013 and March 29, 2013 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 8 – Decline Entry to a Program Department CPR Finding: See ELE 4. Rating: Not Implemented Narrative Description of Corrective Action: As indicated above on ELE4, we will review our current form and the specific guidelines and definitions for “opt-out” and “waiver”. We will update our form to make the differences more explicit. We will notify all personnel involved about these updates and create a process so that the updated form is part of our district’s ELE procedures. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent; ELL Corrective Action Activity: Spring 2012 teachers Evidence of Completion of the Corrective Action: revised form Description of Internal Monitoring Procedures: yearly program review CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 8 – Decline Entry to a Program Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See ELE 4 Department Order of Corrective Action: See ELE 4 Required Elements of Progress Report(s): See ELE 4 Progress Report Due Date(s): February January 30, 2013 and March 29, 2013 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: Not Implemented 6 Department CPR Finding: Interviews with staff members and a review of district documentation indicated that not all English Learners in the district are provided instruction in line with Guidance on Using MEPA Results to Plan Sheltered English Immersion Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students, available at http://www.doe.mass.edu/mcas/mepa/2009/guidance.pdf. Narrative Description of Corrective Action: Category 2 training will be offered to 25 teachers, beginning in January 2012. We will monitor changes regarding Category 3 and 4 training, and implement them once we have been informed by the DESE. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent, ELL Corrective Action Activity: Spring 2012 teachers Evidence of Completion of the Corrective Action: completed training by 25 teachers Description of Internal Monitoring Procedures: yearly program evaluation 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 Disapproved Basis for Partial Approval or Disapproval: See ELE 5 Department Order of Corrective Action: Required Elements of Progress Report(s): See ELE 5 Progress Report Due Date(s): January 30, 2013 and March 29, 2013 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 14 - Licensure Requirements Rating: Not Implemented Department CPR Finding: A review of district documentation indicated that English Language Learners (ELLs) are receiving ESL instruction which incorporates all four language domains. However, although the district states that the two ESL teachers hold an ESL license, no evidence was submitted. (Form missing, ESL Teacher Qualifications p. 58 CPR Procedures). Narrative Description of Corrective Action: We will complete the ESL Teacher Qualifications form and submit it. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent Corrective Action Activity: November 2011 Evidence of Completion of the Corrective Action: submitted licensure form Description of Internal Monitoring Procedures: yearly program evaluation 7 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: Department Order of Corrective Action: Required Elements of Progress Report(s): Submit evidence that all ESL teachers hold appropriate educator licensure by January 30, 2013 Provide a report of the annual review of ESL teacher licensure status by March 29, 2013 *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 the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). Progress Report Due Date(s): January 30, 2013 and March 29, 2013 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: A review of documentation demonstrated that the district does not have in place a multi-year strategic plan for offering Sheltered English Immersion Professional Development (SEI PD) to teachers who provide content instruction to ELE students in the district. The district’s plan includes only Category 2 training for 2010-2011 to be offered at only one of the Elementary schools, which currently has the largest number of ELLs. See also ELE 5 Program Placement and Structure for comments concerning the various levels of teachers’ completion of the four categories of SEI Professional development training. Narrative Description of Corrective Action: After the new guidelines for ELL categories are completed, we will develop a multi-year strategic plan. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent, ELL Corrective Action Activity: Fall 2012 teachers Evidence of Completion of the Corrective Action: description of multi-year plan Description of Internal Monitoring Procedures: yearly program evaluation 8 CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 15 - Professional Development Requirements Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See ELE 5. Department Order of Corrective Action: See ELE 5. Required Elements of Progress Report(s): See ELE 5. Progress Report Due Date(s): See ELE 5. 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: The document review and staff interviews determined that the district does not have a formal program of self-evaluation for its English Learner Education program. Narrative Description of Corrective Action: A formal program of yearly self-evaluation will be developed and introduced in Spring 2012. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent; Corrective Action Activity: Spring 2012 Director of Pupil Services, Principals, ELL teachers; Superintendent Evidence of Completion of the Corrective Action: description of program evaluation process Description of Internal Monitoring Procedures: yearly program review 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: This district has not fully addressed the issues identified in the finding, specifically what the self-evaluation will include to measure success of the overall program. Department Order of Corrective Action: The district will provide a narrative description of their proposed evaluation process, including the names/roles of those involved, types of data reviewed and what methods will be used to ensure ongoing compliance and program improvement. Required Elements of Progress Report(s): The district will provide a narrative description of their proposed evaluation process, including the names/roles of those involved, types of data reviewed, timelines for implementation and what methods will be used to ensure ongoing compliance and program improvement. Please provide this to the Department on or before January 30, 2013. 9 Please submit a narrative description of the 2011-2012 ELE program evaluation, a summary of findings and next steps. Please provide this to the Department on or before March 29, 2013. Progress Report Due Date(s): January 30, 2013 and March 29, 2013 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 18 - Records of LEP Students Rating: Partially Implemented Department CPR Finding: The student record review indicated that records did not consistently contain parental notification correspondence. Narrative Description of Corrective Action: Clarification and implementation of the procedure for filing parental correspondence in students’ files. Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Assistant Superintendent; Corrective Action Activity: Spring 2012 Principals; ELL teachers Evidence of Completion of the Corrective Action: description of procedures Description of Internal Monitoring Procedures: yearly program evaluation CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: Criterion & Topic: ELE 18 - Records of LEP Students Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district did not fully describe their corrective action steps and internal monitoring process for this criterion. Department Order of Corrective Action: The district will review and revise their procedures related to ELE student files, specifically as parent notification. The district will also develop an internal oversight system to ensure that all ELE student files are complete. Required Elements of Progress Report(s): The district will provide a narrative description of their new procedures related to parental notification and maintenance of ELE student records along with evidence of staff training on these procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Please submit this to the Department on or before by January 30, 2013. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by January 30, 2013. Submit the results of an administrative review of student records. Indicate the number of records reviewed, the number found to be compliant, an explanation of the root cause for any continued 10 noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department on or before by March 29, 2013. *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): January 30, 2013 and March 29, 2013 11