MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Woburn CPR Onsite Year: 2011-2012 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 01/25/2013. Mandatory One-Year Compliance Date: 01/24/2014 Summary of Required Corrective Action Plans in this Report Criterion SE 2 Criterion Title Required and optional assessments SE 4 Reports of assessment results SE 8 IEP Team composition and attendance SE 9 SE 14 Timeline for determination of eligibility and provision of documentation to parent Review and revision of IEPs SE 18A IEP development and content SE 18B Determination of placement; provision of IEP to parent CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion SE 19 Criterion Title Extended evaluation SE 21 School day and school year requirements SE 24 SE 25 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 Parental consent SE 26 Parent participation in meetings SE 36 SE 43 IEP implementation, accountability and financial responsibility Procedures for approved and unapproved out-of-district placements Behavioral interventions SE 44 Procedure for recording suspensions SE 45 Procedures for suspension up to 10 days and after 10 days: General requirements Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Appropriate special education teacher licensure SE 37 SE 46 SE 51 CR 7 CR 7B Information to be translated into languages other than English Structured learning time CR 7C Early release of high school seniors CR 9 Hiring and employment practices of prospective employers of students Student handbooks and codes of conduct CR 10A CR 17A CR 18 Use of physical restraint on any student enrolled in a publicly-funded education program Responsibilities of the school principal CR 25 Institutional self-evaluation CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 2 Required and optional assessments Partially Implemented Department CPR Findings: A review of student records indicated that Educational Assessments Part A (a school history) and Part B (current teacher assessment) are not routinely conducted or kept in the student records. In addition, classroom observations that were consented to are not always conducted or found in the student records. Description of Corrective Action: * review of evaluation procedures and timelines with building principals, special education and regular education teachers by 07/01/2013. * review of expectations regarding the completion of Ed-A,B as well as classroom observations by 07/01/2013 * training regarding completion of Ed A, B and Observations with Principals, Classroom Teachers and Special Education Teachers by 10/2013 * Policy and Procedure manual updates by 09/01/2013 Title/Role(s) of responsible Persons: Expected Date of Team Chairperson Completion: Principals 01/24/2014 Regular and Special Education Teachers Evidence of Completion of the Corrective Action: * attendance at staff meetings and notes attached regarding the above mentioned subject prior to 07/01/2013 * copies of handouts provided at each of the meetings * Policy and Procedure Manuals in place in all buildings by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will include quarterly review on random sample of initial and re-evaluation packets for students referred for evaluation to ensure all documents are included in the file. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 2 Required and optional assessments Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions: staff training on completing required and optional assessments (Ed Assessments A & B, classroom observations) consented to by parents, policy and procedure revisions, and an internal record review of files to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By 6/14/13, submit documentation (agendas, signed attendance sheets, training materials) that staff training was conducted on the requirements for completing evaluations consented-to by parents, specifically Ed Assessments A & B and classroom observations. For the five student records that were found out of compliance during the record review, submit copies of the completed assessments. By 11/29/13, after implementation of all corrective actions, conduct an internal record review at each level, including students in out-of-district placements. Report the number of records reviewed and the number that contained all completed evaluation reports MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 3 where parental consent was received. If any non-compliance identified, report the root cause(s) and the district's plan to remedy the non-compliance. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 4 Reports of assessment results Partially Implemented Department CPR Findings: A review of student records indicated that home assessments, speech language assessments and achievement assessments do not always contain educationally relevant recommendations or define in detail the student´s needs and offer explicit means of meeting those needs. Description of Corrective Action: *On 11/03/12 a workshop was held in district regarding report writing and providing specific recommendations based on findings. Sample reports were distributed to teachers. *Team Chairpeople will develop a template for Home Assessments to report on concerns and make recommendations by 07/01/2013. *Speech Therapists met on 11/15/12 to develop a template for writing speech reports including providing recommendations based on findings. Title/Role(s) of responsible Persons: Expected Date of Team Chairperson Completion: Special Educators 01/24/2014 Speech Therapists Evidence of Completion of the Corrective Action: * attendance for each of the above mentioned workshops with copies of handouts and documents developed * all documents to be held on file and accessible for all Chairpeople, special educators and speech therapists, in the Special Education Office Description of Internal Monitoring Procedures: The internal monitoring process will consist of quarterly sampling of reports for review of recommendations. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 4 Reports of assessment results Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train staff regarding the requirements of evaluation reports and conduct internal reviews of student records to ensure that noncompliance has been remedied. Department Order of Corrective Action: Required Elements of Progress Report(s): By 6/14/13, submit documentation (agendas, signed attendance sheets, training materials) from the staff training that was conducted on 11/03/12 on the requirements of evaluation reports and the inclusion of educational recommendations. By 11/29/13, following training and implementation of all corrective actions, conduct an internal review of evaluation reports from each level. Report the number of evaluation reports reviewed and the number of reports that contained educationally relevant recommendations. If any non-compliance identified, report the root cause(s) and the district's plan to remedy the non-compliance. *Please note that when monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 5 grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 8 IEP Team composition and attendance Partially Implemented Department CPR Findings: A review of student records indicated that IEP Teams do not always obtain written parental consent to excuse the attendance of a required IEP Team member. The district does not always have a special education teacher of the student or a general education teacher of the student attend the IEP Team meeting when the participation of a general education teacher is required. In addition, please see SE 26. Description of Corrective Action: * Team Chairpeople met on 01/18/2013 and developed a plan for printing meeting excusal forms for all meetings. * Policy on attendance and attendance excusal added to the updated Policy and Procedure manual by 09/01/2013 Title/Role(s) of responsible Persons: Expected Date of Team Chairperson Completion: Director of Special Education 09/01/2013 Evidence of Completion of the Corrective Action: * attendance of chairperson meeting with attached agenda for discussion * all files must have the attendance sheet and printed excusal form * Policy and Procedure manual for all Chairpeople complete with instructions and blank forms Description of Internal Monitoring Procedures: The process for internal monitoring will consist of quarterly monitoring of a random sample of 5 files, to be sure all documents are in place. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 8 IEP Team composition and Status Date: 04/09/2013 attendance Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action of training Team chairpersons on the requirements of Team composition, the procurement of written parental consent to excuse the attendance of required Team members and its review of records to ensure implementation of all corrective actions. Department Order of Corrective Action: Required Elements of Progress Report(s): By 6/14/13, submit documentation of the training conducted on 1/18/2013 on the requirements of IEP Team composition and attendance. Conduct a review of student records after the 1/18/13 training and report: the number of student records reviewed from each level, the number that contained signed attendance sheets of all required IEP Team members and/or written excusals from parents excusing the absent Team member. If any non-compliance is identified, report the root cause(s) and the district's plan to remedy the ongoing non-compliance. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 7 Progress Report Due Date(s): 06/14/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 9 Timeline for determination of eligibility and provision of Partially Implemented documentation to parent Department CPR Findings: A review of student records indicated that home assessments are not consistently conducted within the required timelines for completing evaluations. Classroom observations are not consistently conducted after receipt of parental consent. At all levels, the district does not always conduct evaluations within 30 school working days nor determine eligibility within 45 days after receipt of the parent's written consent to an evaluation. Description of Corrective Action: *Team Chairpeople meet to develop home assessment protocol by 07/01/2013- protocol to include method of conducting home assessment and method by which to report on information found through the home assessment. * Team Chairpeople will meet by 07/01/2013 to discuss the assignment of student observation and the method by which the observation will be documented. * Review the obligations of the information agreed to on the evaluation consent form with the Special Education Staff as a whole by 07/01/2013. * Updated Policy and procedure manual with process for eligibility timelines for all Chairpeople by 09/01/2013 Title/Role(s) of responsible Persons: Expected Date of Team Chairpeople Completion: Special Education Staff 01/24/2014 Evidence of Completion of the Corrective Action: * attendance and agenda for Chairperson meeting * documents developed pertaining to home assessments and protocol will be made available to all staff members attendance taken at Chairperson meetings and notes form each meeting regarding home assessments and observations * Policy and Procedure Manuals in each building by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of quarterly review of files for documentation. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 9 Timeline for determination of Status Date: 04/09/2013 eligibility and provision of documentation to parent Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action of training Team chairpersons on the requirements of 30 and 45 day timelines, the creation of procedures to ensure that timelines are being met, as well as its internal review of the tracking data to ensure implementation of all corrective actions. See SE 2 regarding classroom observations. Department Order of Corrective Action: Required Elements of Progress Report(s): By 6/14/13, submit the following documentation: Evidence (agendas, signed attendance MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 9 sheets, training materials) that training was conducted for Team chairpersons on the required 30 and 45 day timelines and the revised procedures for tracking 30 and 45 day timelines. By 11/29/13, submit the results of the district's timeline tracking data at all levels and report: the number of evaluations conducted after the training, the number of records that had assessments completed in 30 days and the number that had Team meetings convened within 45 days after receipt of parental consent. If non-compliance is identified, report the root cause of the ongoing non-compliance and the district's plan to remedy it. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 14 Review and revision of IEPs Partially Implemented Department CPR Findings: A review of student records indicated that at the middle and high school levels, annual review IEP Team meetings are not consistently held on or before the anniversary date of the IEP. In addition, the district has a practice of including bullying prevention and intervention statements under additional information after the IEPs have been issued to parents, rather than using the amendment process to add required and important information to previously proposed and accepted IEPs. Description of Corrective Action: *Team Meeting Protocol will be developed for all levels and will address all aspects of the IEP including the bullying prevention protocol. * Middle and High School Liaisons will meet with the Special Education Director prior to 07/01/13 and the topic of the meeting will be IEP meeting scheduling and IEP development. * Updated Policy and Procedure Manual will be made available for all Chairpeople and Team Meeting/Parent Participation guidelines highlighted Title/Role(s) of responsible Persons: Expected Date of Middle and High School Liaisons, Team Chairpeople Completion: 01/24/2014 Evidence of Completion of the Corrective Action: * attendance at Middle and High School Staff Meetings with agenda as well as handouts provided to the staff * Policy and Procedure Manuals in all buildings including all necessary documentation. Description of Internal Monitoring Procedures: The internal monitoring process will consist office staff will quarterly review files and check for appropriate documentation. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 14 Review and revision of IEPs Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action of training special education staff on the requirements of including bullying prevention and intervention statements in IEPs, the implementation of tracking to ensure that annual reviews are conducted prior to the expiration date of the previous IEP, and an internal review to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, the district will submit evidence (agendas, sign-in sheets) that training was conducted on tracking annual review timelines and documenting individual skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing in applicable IEPs. Following staff training and implementation of all corrective actions, the district will conduct two internal reviews. By November 29, 2013, report the number of IEPs developed for students on the autism spectrum or whose disabilities affect their social skills development from each level (Elementary, MS, HS). Report the number of those MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 11 IEPs that contain the individual skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing. Conduct a second internal review of annual review tracking data and report: The number of annual reviews conducted at each level (Elementary, MS, HS) and the number that had IEPs developed on or before the expiration date of the previous IEP. If ongoing non-compliance is identified, report the root cause, a plan remedy it and the specific actions taken to ensure full compliance of each student record. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18A IEP development and content Partially Implemented Department CPR Findings: A review of student records indicated that the IEP does not specifically address the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing for students identified with a disability on the autism spectrum or a disability that makes them vulnerable to bullying, harassment, or teasing. The district uses template language on all IEPs under the additional information section of the IEP stating that the student "will participate in age appropriate anti-bullying activities." There is no indication in the IEPs, summary notes or Notices of Proposed Action (N1) that the IEP Team considers the specific and individual skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing for each student. Description of Corrective Action: On 10/22/13 the Team Chairpeople met with the Director and discussed the inclusion of the bullying prevention in the IEP. * Bullying prevention will be included in the team meeting checklist and if found to be a concern for the student the team will develop goals and objectives to address the concern and accommodations in PLEP B. * Team Chairperson will address bullying in the N1 letter. * Update Policy and Procedure Manual will incorporate Bullying as a consideration for the IEP by 09/01/2013. Title/Role(s) of responsible Persons: Expected Date of Team Chairpeople and Liaison’s Completion: 01/24/2014 Evidence of Completion of the Corrective Action: * attendance from the Chairperson meeting with agenda * All IEP's will address the impact of bullying and either provide steps to provide children with the tools necessary, or document that it was discussed and the team does not feel at this time that the child is a target for bullying. * Impact of Bullying will be added as a consideration, to the Policy and Procedure Manual, when drafting an IEP, by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of quarterly review of N1 letters for documentation of bullying discussion and evidence of the discussion in the IEP. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18A IEP development and content Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The district proposed a comprehensive plan of corrective action and on November 1, 2012, submitted documentation (agenda, signed attendance sheets) that staff training was conducted on the district's revised procedures for documenting and developing individual skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing in IEPs. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, after the implementation of all corrective actions, the district will MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 13 conduct an internal review of student records at each level (Elementary, MS, HS). Report the number of recently developed IEPs of students who are on the autism spectrum or whose disabilities affect social skills development and the number of those records that contain documentation in IEPs that the Team has considered and specifically addressed the individual skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing. For any records that are not in compliance, provide a description of the root cause analysis of the non-compliance and the specific corrective actions taken by the district to remedy any identified noncompliance in each student record. In addition, for the three student records that were found out of compliance during the record review, submit the required IEP pages and N1 notices. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 14 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: A review of student records indicated that after the IEP has been fully developed, the IEP Team does not immediately determine the appropriate placement to deliver the services on the student´s IEP or provide parents with a proposed placement along with the proposed IEP and required notice. In some instances, the district takes several months to provide parents with the proposed placement. In addition, for some out-of-district placements, the district does not develop or propose the IEP, but rather relies on the outof-district placement to write, propose and send completed IEPs to the district which the district then sends to the parent. Description of Corrective Action: * Chairperson meeting prior to 07/01/2013 to discuss the following- attendance will be taken and agenda attached. Team Chairpeople participate in all Out of District meetings for the purpose of programming and goal development. Team Chairpeople are responsible for writing the N1 letter and placement page for all OOD IEP's. The district approves the IEP proposed by the individual school and send to the parent. In district meetings, placement assurance will be provided through meeting flow chart checklist that Chairpeople will complete during the course of the meeting with Placement being the last point to address. Chairpeople will be responsible for completing the checklist for OOD meetings as well and return to the district to be filed. All Out of District IEP's will be input into the district data base. Title/Role(s) of responsible Persons: Expected Date of Team Chairpeople Completion: 01/24/2014 Evidence of Completion of the Corrective Action: All Out of District students' files reviewed to ensure completion of the IEP and the Checklist developed from #18A Description of Internal Monitoring Procedures: The internal monitoring process will consist Director review of all Out of District IEP's prior to mailing to the families. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 18B Determination of placement; Status Date: 04/09/2013 provision of IEP to parent Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action to train staff regarding the requirements of determination of placement and provision of IEP to parents that include revised tracking procedures, writing N1 notices and placement pages, as well as the responsibilities of the district for developing IEPs for students in out- of-district placements. Department Order of Corrective Action: Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 15 By June 14, 2013, the district will submit documentation (agendas, sign-in sheets, training materials) that training was conducted on the requirements for tracking and providing proposed IEPs and placements to parents, writing N1 notices, completing a flow chart checklist and ensuring that proposed IEPs, placements and paperwork for students in out-of-district are completed as required. By November 29, 2013, the district will conduct two internal reviews. Following training and implementation of all corrective actions, conduct an internal review of the tracking data and report the number of IEP Team meetings conducted at each level (Elementary, MS, HS) and the number in which the proposed IEP and placement were provided immediately. Conduct a second internal review of students placed in out-of-district placements and report: The number of out-of-district Team meetings conducted, the number that had proposed IEPs, placement pages and N1s provided within required timelines. If any ongoing non-compliance is identified, report the root cause, a plan to remedy it, and the specific actions taken to ensure full compliance for each record reviewed. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 16 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 19 Extended evaluation Partially Implemented Department CPR Findings: A review of student records and interviews indicated that the district engages in procedural misuse of the extended evaluation process. For general education students who have been placed by community crises teams (an intervention utilized by the guidance counselor for general education students in crises), the district obtains consent from parents to conduct extended evaluations. The district is using this process in lieu of conducting initial evaluations to determine eligibility for special education. The district places these general education students in 45-day placements and identifies this as an extended evaluation for a 45-day assessment, which is not an option supported by regulation. The district also uses extended evaluations instead of following disciplinary procedures to remove students with disabilities from school for behavioral or attendance issues and places these students into an Interim Alternative Educational Setting (IAES) for the purpose of an evaluation without conducting manifestation determinations. See also SE 46. Description of Corrective Action: Workshop to be conducted with Team Chairpeople and Building Principals regarding the Extended Evaluation Procedure prior to 07/01/13 Updated Policy and Procedure Manual for all Chairpeople to highlight chapter on Extended Evaluations and include all necessary documentation. Title/Role(s) of responsible Persons: Expected Date of Team Chairperson Completion: 01/24/2014 Evidence of Completion of the Corrective Action: Attendance will be taken at workshop and informative hand out distributed to all. Policy and Procedure Manuals in all buildings by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of Extended Evaluations being documented in the same manner as initials and re-evaluations are in the office and reviewed quarterly for compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 19 Extended evaluation Corrective Action Plan Status: Partially Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action to train staff on the proper use and requirements for extended evaluations; however, the Department would like guidance staff to be included in the training as guidance staff are responsible for the misuse of the extended evaluation process in the programming of general education students. Department Order of Corrective Action: The district will include guidance counselors in the training and will conduct an internal review of extended evaluations to ensure that staff are using extended evaluations MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 17 appropriately. Required Elements of Progress Report(s): By June 14, 2013, submit documentation (agendas, signed attendance sheets, training materials) that training was conducted for administrators, Team chairs and guidance staff on the proper use of extended evaluations. By November 29, 2013, following training and after implementation of all corrective actions, conduct an internal review. Report the number of extended evaluations conducted by the district from each level and report the number of records in compliance. For any records out of compliance, indicate the root cause with specific actions taken to remedy the non-compliance. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 18 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 21 School day and school year requirements Partially Implemented Department CPR Findings: A review of student records and interviews indicated that the district does not identify an extended day or year program if the student demonstrated or is likely to demonstrate substantial regression in his or her learning skills and/or substantial difficulty in relearning such skills. An extended school year is automatically recommended and determined based on the student's placement rather than an individual student’s demonstrated substantial regression of skills. Description of Corrective Action: Extended Year Services discussed as part of the IEP checklist Workshops will be conducted with the special education department discussing determining EYS, what services the child requires and how they will be delivered on or before 07/01/2013 EYS to be included in updated Policy and Procedure Manual by 09/01/2013 Title/Role(s) of responsible Persons: Expected Date of Chairpeople Completion: 09/01/2013 Evidence of Completion of the Corrective Action: IEP meeting checklist (from 18A) will indicate if the team discussed the EYS and specifics of programming for students. Policy and Procedure Manual in each building by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of an quarterly review of files to specifically target EYS discussion and planning. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 21 School day and school year Status Date: 04/09/2013 requirements Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action to train staff on the school day and school year requirements, the revision of policies for the procedure manual on ESY and an internal review. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit documentation of training (agenda, signed attendance sheets, training materials) on the requirements of extended school year and a revised policy on ESY. By November 29, 2013, the district will conduct an internal review and report the number of IEPs developed, the number of records in compliance and if non-compliance is determined, indicate the root cause with specific steps to remedy the non-compliance. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 19 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 20 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 24 Notice to parent regarding proposal or refusal to initiate or Partially Implemented change the identification, evaluation, or educational placement of the child or the provision of FAPE Department CPR Findings: A review of student records indicated that the district does not consistently send a written notice to the parents within five school days of receipt of the referral when the child is referred for an evaluation to determine eligibility for special education. Description of Corrective Action: Review policy on referrals and five day turn around for all referrals at the monthly Chairperson meeting before 07/01/2013 Provide each Chairperson with an updated Policy and Procedure Manual for reference by 09/01/2013 Title/Role(s) of responsible Persons: Expected Date of Chairpeople Completion: 01/24/2014 Evidence of Completion of the Corrective Action: Attendance and agenda provided for Chairperson Meeting Manuals in place for all Chairpeople Description of Internal Monitoring Procedures: The internal monitoring process will consist of quarterly check on random sample of five referrals, through on line data base, to review timelines. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 24 Notice to parent regarding Status Date: 04/09/2013 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: The Department accepts the district's proposed corrective action to train staff on the requirements of sending notice within five school days of receipt of a referral to determine eligibility for special education, including its plans to conduct quarterly monitoring. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit documentation (agenda, signed attendance sheets, training materials), that training was conducted on the requirement to send parents written notice within five days of receipt of a referral. By November 29, 2013, following training and implementation of all corrective actions, conduct an internal review of the district's tracking data of new referrals for eligibility. Report the number of records reviewed and the number of records in compliance. If ongoing non-compliance is identified, report the root cause, a plan to remedy it and the steps taken to ensure full compliance. *Please note that when monitoring, the district must maintain the following documentation and make it available to the Department upon request: a) List of student MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 21 names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 22 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 25 Parental consent Partially Implemented Department CPR Findings: A review of student records indicated that the district does not always conduct evaluations (such as home assessments, classroom observations, communication and developmental assessments) after obtaining parental consent as part of an initial evaluation or reevaluation to determine special education eligibility. Description of Corrective Action: * Review parental consent to assessments and obligation to complete assessments in 30 school days with Chairperson by 07/01/2013 * document protocol for scheduling and obtaining assessments within 30 school days. * review timeline in Policy and Procedure Manual Title/Role(s) of responsible Persons: Expected Date of Chairpeople Completion: 01/24/2014 Evidence of Completion of the Corrective Action: * attendance and agenda from Chairperson meeting * Policy and Procedure Manuals in each building by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of review of file's prior to the team meeting to be sure that all documentation is in place. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 25 Parental consent Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train staff on the requirements of parental consent and to conduct an internal review of records to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit evidence (agendas, signed attendance sheets, training materials) that training was conducted on the district's responsibilities to complete all evaluations consented to by the parents. For the five student records that were found out of compliance during the CPR record review, submit the initials of each student, the name of assessments and the dates of completion. By November 29, 2013, following training and implementation of all corrective actions, review a sample of student records from each level (Elementary, MS, HS) that required home assessments, classroom observations, communication and developmental assessments and report: the number of records in which parents consented to the evaluations, and the number of student files that contained evaluation reports for all assessments consented- to by the parents. If non-compliance is identified, report the root cause, a plan to remedy it and the specific actions taken to ensure full compliance for each file reviewed. *Please note that when 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 record review; b) Date of the review; c) Name of MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 23 person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 24 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 26 Parent participation in meetings Partially Implemented Department CPR Findings: A review of student records evidenced that it is the district's practice to reschedule multiple Team meetings until parents can attend without sending additional IEP Team meeting notices. Student records demonstrated that the district does not document its multiple attempts to facilitate or obtain the parents' participation in IEP Team meetings. Interviews confirmed that the district does not conduct IEP eligibility meetings or IEP Team meetings when parents do not attend. As a result, IEP Team meetings are delayed up to nine months. Description of Corrective Action: * Review policy for scheduling and re-scheduling meetings for parent participation on or before 07/01/2013 * add Parental attendance and re-scheduling guidelines to the Policy and Procedure Manual by 09/01/2013. Title/Role(s) of responsible Persons: Expected Date of Chairpeople or Liaisons Completion: 01/24/2014 Evidence of Completion of the Corrective Action: * attendance and agenda from Chairperson meeting regarding scheduling and rescheduling team meetings for parent participation * Updated Policy and Procedure Manuals in each building by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of documenting and filing all "parental absence" attendance sheets and meeting invitations with the IEP, in the child's main file. Files will be reviewed quarterly for compliance. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 26 Parent participation in meetings Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train staff regarding the requirements of parent participation in meetings, revised policies for the procedures manual, and a review of student records to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit the revised procedures for Team chairpersons to document their multiple attempts to facilitate or obtain the parents' participation in IEP Team meetings. Submit documentation (agendas, sign in sheets, training materials) that training was conducted on these procedures. By November 29, 2013, following training and implementation of all corrective actions, conduct a review of student records where parents did not attend IEP Team meetings from each level (Elementary, MS, HS) and report: the number of records reviewed, the number of records in compliance, and if non-compliance is identified, report the root cause, a plan to remedy it, and the specific actions taken to ensure full compliance with each student record. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 25 *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 26 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 36 IEP implementation, accountability and financial Partially Implemented responsibility Department CPR Findings: A review of student records and interviews indicated that the district does not always develop, propose and monitor the full implementation of the IEP of each out-of-district placement. In addition, please see SE 18B. Description of Corrective Action: * Review the policy for participating in meetings for students in out of district placements with Chairpeople and provide documentation of obligations * Input all Out of District IEP's in to the district database Title/Role(s) of responsible Persons: Expected Date of Completion: Chairpeople 01/24/2014 Evidence of Completion of the Corrective Action: * attendance and agenda from Chairperson meeting discussing the above mentioned content Description of Internal Monitoring Procedures: *The internal monitoring process will consist of having all IEP's for Out of District students submitted to the Director complete with checklist developed as a part of (18A), to be reviewed prior to sending to the family. All Out of District IEP's will be input into the district data base and reviewed quarterly to monitor progress. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 36 IEP implementation, accountability Status Date: 04/09/2013 and financial responsibility Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train staff regarding the requirements of monitoring students in out-of-district placements and its review of student records to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit documentation (agendas, signed attendance sheets) that training was conducted on the requirements for monitoring students in out of district placements. By November 29, 2013, following training and implementation of all corrective actions, conduct a review of student records. Report the number of students in out-of-district placements and the number of files that contain monitoring plans. If ongoing noncompliance is identified, report the root cause, a plan to remedy it, and specific actions taken to ensure full compliance for each student record. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 27 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 37 Procedures for approved and unapproved out-of-district Partially Implemented placements Department CPR Findings: A review of student records and documents indicated that out-of-district monitoring activities are not consistently documented and kept in the files of every eligible student who has been placed out-of-district. In addition, written contracts with all public and private out-of-district placements do not contain a statement that the district can conduct unannounced site visits. Description of Corrective Action: * In written contracts with Out of District Schools, include language that would provide the district with quarterly progress reports and behavior reports when necessary, as well as document the districts right to unannounced site visits. * review Policy and Procedure Manual for Out of District procedures Title/Role(s) of responsible Persons: Expected Date of Team Chairpeople Completion: 01/24/2014 Evidence of Completion of the Corrective Action: * New written contract for schools. Description of Internal Monitoring Procedures: The internal monitoring process will consist of new contracts to be provided to each school prior to 09/01/2013. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 37 Procedures for approved and Status Date: 04/09/2013 unapproved out-of-district placements Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions of revising contracts to require unannounced site visits and staff training on the requirements for monitoring students in out-of-district placements. See also SE 36. Department Order of Corrective Action: Required Elements of Progress Report(s): By September 6, 2013, conduct a review of all out-of-district contracts. Report the number of students in out-of-district placements and the number of those contracts that contain a statement ensuring that the district can conduct unannounced visits. Lastly, for the five student records that were found out of compliance during the CPR record review, submit copies of their monitoring plans and revised OOD contracts. See also SE 36. Progress Report Due Date(s): 09/06/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 28 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 43 Behavioral interventions Partially Implemented Department CPR Findings: A review of student records indicated that for students identified with disabilities other than an emotional disability, the district removes students from their current placement into day programs or IAES settings for behavioral infractions without first implementing behavioral interventions and supports, or convening IEP Teams to consider positive behavioral interventions or the need for functional behavioral assessments. Description of Corrective Action: Meet with building Principals, Guidance Counselors and Team Chairpersons regarding the following content: * Instructional Student Support process when a child exhibits a concerning behavior * utilize the resources of the building; psychologists, counselors, ABA therapists to observe the child in the setting * acquire consent of the parent for completing a Functional Behavioral Analysis Add IAES protocol to Policy and Procedure Manual with all pertinent documentation by 09/01/2013 Title/Role(s) of responsible Persons: Expected Date of Team Chairpersons Completion: Building Principals 01/24/2014 Guidance Councilors Evidence of Completion of the Corrective Action: *Attendance and agenda provided for a meeting to discuss procedure for moving a child to an IAES. * Policy and Procedure Manual in all buildings by 09/01/2013 Description of Internal Monitoring Procedures: The internal monitoring process will consist of the Director signing off on all IAES settings ensuring appropriate procedures were followed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 43 Behavioral interventions Corrective Action Plan Status: Partially Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train staff on the implementation of behavioral interventions and procedures for moving a student into an IAES. However, the district did not include an internal review of student records to ensure that behavioral interventions were being implemented. Department Order of Corrective Action: After revised procedures and training on the implementation of behavioral interventions, the district will conduct an internal review of students who have been removed from their current placements into day programs or IAES settings for behavioral infractions to ensure that behavioral interventions and supports, or convening IEP Teams to consider positive behavioral interventions or the need for functional behavioral assessments, were first implemented prior to removing students to more restrictive placements. Required Elements of Progress Report(s): By June 14, 2013, submit the district's revised procedures for moving students into an IAES and evidence of staff training (agendas, signed attendance sheets, training MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 29 materials) on the implementation of behavioral interventions. By November 29, 2013, after training and implementation of all corrective actions, conduct a review of student records. Report the number of students placed in IAES settings for behavioral infractions and the number whose files documented the implementation of positive behavioral interventions, supports, or functional behavioral assessments, prior to placing the student in a more restrictive or IAES setting. If ongoing non-compliance is identified, report the root cause, a plan to remedy it and specific actions taken to ensure full compliance for each file reviewed. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 30 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 44 Procedure for recording suspensions Partially Implemented Department CPR Findings: A review of student records and interviews indicated that in some instances, the district removes special education students from school with parental consent for extended periods of time for behavioral infractions, but does not count the removal time as a suspension. Description of Corrective Action: *review protocol for all students regarding behavioral infractions as defined in the Policy and Procedure Manual with Principals and Guidance Counselors Title/Role(s) of responsible Persons: Expected Date of Director of Special Education Completion: Building Principals 01/24/2014 Guidance Councilors Evidence of Completion of the Corrective Action: * review behavior plans with staff * document all absences based on behavioral infraction as a suspension * plan a manifestation meeting for the student and plan for return Description of Internal Monitoring Procedures: The internal monitoring process will consist of Principals, Guidance Counselors and Chairpeople notifying the Director in an instance of a behavioral infraction resulting in disciplinary action for a Special Education Student. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 44 Procedure for recording Status Date: 04/09/2013 suspensions Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions of conducting training for principals, Team chairpersons and guidance counselors on the Policy and Procedures Manual and required protocols for students with patterns of behavioral infractions, as well as internal monitoring to ensure ongoing compliance. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, the district will submit its protocols for students with patterns of behavioral infractions and documentation (agendas, signed attendance sheets, training materials) that training was conducted on these procedures. By November 29, 2013, after training and implementation of all corrective actions, conduct an internal review and report the number of special education students removed from school with parental consent for extended periods of time for behavioral infractions, the number of suspensions reported for these students and the number that evidenced that appropriate procedures were followed. If district procedures were not followed and on-going non-compliance was identified, report the root cause, a plan to remedy it and any specific actions taken to ensure full compliance for each student record. *Please note that when 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 record review; b) Date of the review; c) Name of MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 31 person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 32 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 45 Procedures for suspension up to 10 days and after 10 Partially Implemented days: General requirements Department CPR Findings: A review of records and interviews indicate that the district places special education students in 45-day interim alternative educational settings (IAES) as a placement for behavioral infractions that are not articulated in federal regulation (possessing weapons, drugs or committing serious bodily harm would allow the district to unilaterally place the student in an IAES). After placing the student in the IAES, the district acquires parental consent to conduct re-evaluations. In several cases, this resulted in removing students from full inclusion placements into day programs or IAES settings, without conducting manifestation determinations and examining whether the student could remain in less restrictive environments with added supports, services or behavior plans. In several cases, special education students remained at home at the request of the parent without the district providing any educational services, followed by placing students in an IAES for the purpose of conducting evaluations as evidenced by signed parental consent to evaluate forms in the student records. These evaluations included required assessments and optional assessments such as psychological, social, and projective assessments. In some instances, these evaluations included functional behavioral assessments. This process may take several months before the district returns the student to school or changes the placement of the student to implement services. The district does not provide parents with the written notice of procedural safeguards after instituting these removals from the student's placement. The district also places students with disabilities with disciplinary infractions of any length (i.e. less than 10 days of suspension and more than 10 days of suspension) in an IAES for the purpose of an evaluation which the district indicates is an "extended evaluation," though there was no evidence that parents consented to an evaluation prior to the "extended evaluation." Lastly, the district will obtain parental consent for a second "extended evaluation" to keep the student an additional 45 days or longer in the IAES with the intention of obtaining additional evaluation information. Description of Corrective Action: * review policy on discipline related to behavior by 10/01/2013 with principals and team chairperson * document procedure for recommending a 45-day assessment placement for a student with building principals and team chairperson * document process for contacting and recommending a 45 day assessment placement for a child and the "interim" as the placement is being determined Title/Role(s) of responsible Persons: Expected Date of Chairperson Completion: Building Principals 01/24/2014 Director of Special Education Superintendent Evidence of Completion of the Corrective Action: agenda from the meeting with principals and Chairpeople procedure for 45-day assessments documented in the Policy and Procedure Handbook all student specific documentation filed in the main file MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 33 Description of Internal Monitoring Procedures: The internal monitoring process will consist of review all 45 day placements for appropriate documentation in the child's main file. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 45 Procedures for suspension up to Status Date: 04/09/2013 10 days and after 10 days: General requirements Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train principals, guidance staff and Team chairpersons on procedures for placing students in IAES settings, requirements for conducting behavior manifestation determinations, providing parents with written notice of procedural safeguards, and ceasing the use of extended evaluations for students who were never identified as eligible for special education. As part of the CAP, the district will internally monitor students placed in 45 day placements to ensure that all required procedures were followed. See also SE 43 and SE 44. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit evidence (agendas, signed attendance sheets, training materials) that training was conducted for principals, guidance staff and Team chairpersons on procedures for placing students in IAES settings, procedures for conducting behavior manifestation determinations, the requirements for providing parents with written notice of procedural safeguards, and ceasing the use of extended evaluations for students who were never identified as eligible for special education. In addition, for the three student records that were found out of compliance during the CPR record review, submit the initials of each student and required documentation (evidence that the district provided FAPE during students' extended absences, manifestation determination documentation, N1 notices documenting actions taken by the district). See also SE 43 and SE 44. By November 29, 2013, following training and implementation of all corrective actions, the district will conduct an internal review of all students placed in 45-day interim alternative educational settings (IAES). Report the number of student records reviewed, the number in compliance and if any ongoing non-compliance is identified, report the root cause, a plan to remedy it and the specific actions taken to ensure full compliance for each student reviewed. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 34 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 46 Procedures for suspension of students with disabilities Partially Implemented when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Department CPR Findings: The student record review indicated that the district does not convene the IEP Team within 10 days of the student's removal from school to conduct manifestation determinations to determine whether the behavior was caused by or had a direct and substantial relationship to the disability or whether the behavior was the direct result of the district´s failure to implement the IEP. The suspension or removal data kept by school building administrators and/or guidance counselors is not routinely shared with IEP Team chairpersons who are responsible for conducting manifestation determination meetings. As a result, the district is not identifying or documenting the need to reconvene IEP Teams to address the needs of students with behavioral issues or for students who are subject to disciplinary action to examine the appropriateness of the IEP or placement. Description of Corrective Action: * guidance counselors to provide team chairperson with documentation of suspension * team chairperson schedule a manifestation meeting Title/Role(s) of responsible Persons: Expected Date of Building Principal Completion: Guidance Councilors 01/24/2014 Team Chairperson Evidence of Completion of the Corrective Action: * meeting invitations and attendance sheets along with notes for all manifestation meetings in the main file * plans developed for the student maintained in the main file Description of Internal Monitoring Procedures: The internal monitoring process will consist of quarterly reviewing files of children suspended for proper documentation. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 46 Procedures for suspension of Status Date: 04/09/2013 students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions of clarifying procedures for the reporting and tracking of suspensions, staff training on the district's procedures for suspension of eligible students that exceed 10 days and quarterly monitoring of student records for suspended students. Department Order of Corrective Action: Required Elements of Progress Report(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 35 By June 14, 2013, submit documentation (agendas, signed attendance sheets, training materials) that training was conducted for principals, guidance staff and Team chairpersons on the requirements of this criterion. By November 29, 2013, following staff training and implementation of all corrective actions, conduct an internal review of eligible students who have been suspended 10 days. Report the number of students suspended 10 days and the number of records in compliance. If ongoing non-compliance is identified, report the root cause, a plan to remedy it and the specific actions taken to ensure that each student file is in full compliance. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 36 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 51 Appropriate special education teacher licensure Partially Implemented Department CPR Findings: A review of documentation and interviews indicated that the district employs a staff member with a speech language certification as a special needs classroom teacher who designs and provides direct special education services for students in a language-based special education classroom. This staff member does not hold licensure as a special needs teacher. Description of Corrective Action: All employees will hold the proper certification for the role they lead in the district. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education Completion: Superintendent of Schools 01/24/2014 Evidence of Completion of the Corrective Action: District ensure all staff are properly licensed. Description of Internal Monitoring Procedures: The internal monitoring process will consist of District monitoring of staff licenses and renewals annually. The internal monitoring process will consist of new staff hired only with proper certification approved and on file with the Superintendent. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 51 Appropriate special education Status Date: 04/09/2013 teacher licensure Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective action of ensuring that special education teachers assigned to substantially separate special education classes are appropriately licensed. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, the district will submit evidence that the self-contained language based teacher holds a current license for special education. Progress Report Due Date(s): 06/14/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 37 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7 Information to be translated into languages other than Partially Implemented English Department CPR Findings: The document review and staff interviews indicated that the district does not ensure that major publications of the district (handbooks, codes of conduct, course of studies) are translated into the major languages of the district. The district relies on Google translations available on the district's website; however, this translation software is often inaccurate and not accessible to all parents. Description of Corrective Action: * Identification of major languages in district using Rediker Software Student Management System (by 2/25) * Translation of major publications of the district (handbooks, course of studies) by Catholic Charities (by 6/30) * Dissemination of the translated documents to appropriate staff, as well as posting of the translated documents online (by 9/1) * Conduct training with administrators to ensure staff are aware of need to translate major documents and that they know the appropriate contact person for obtaining the translation of documents (by 9/1) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent for Curriculum Completion: 09/01/2013 Evidence of Completion of the Corrective Action: Copies of translated documents Copy of agenda, attendance sheet and meeting notes from training with administrators Description of Internal Monitoring Procedures: Annual review of major languages of district to be conducted by Assistant Superintendent of Curriculum (to be completed annually in October) Annual review of major district publications to ensure that publications are available in district major languages (to be completed annually in October) CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 7 Information to be translated into Status Date: 04/09/2013 languages other than English Basis for Partial Approval or Disapproval: The Department accepts the district's proposed corrective actions to train staff regarding the requirements of translated information and the procurement of translated handbooks and courses of studies. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 13, 2014, the district will submit documentation that training was conducted for administrators to ensure they know the appropriate contact person for obtaining the translation of documents. By September 6, 2013, submit copies of the translated documents (student handbook and course of study). Progress Report Due Date(s): MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 38 06/14/2013 09/06/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 39 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7B Structured learning time Partially Implemented Department CPR Findings: A review of documents and staff interviews indicated that at the high school level, the district requires students to participate in only two years of physical education. State law requires physical education for all students at all grade levels every year. Description of Corrective Action: * Establishment of working group to review the CPR finding and to establish a plan for corrective action. (by 3/1) * Review of graduation requirements related to physical education participation by working group (by 5/1) * Development of new policy/practice for physical education participation by working group (by 6/1) * Establishment of plan for implementation of new policy/practice, including training for school guidance counselors on enforcement of policy (by 6/30) * communication to students/families about new policy/practice (by 6/30) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent Completion: High School Principal 09/01/2013 Wellness Department Head Guidance Department head Evidence of Completion of the Corrective Action: * Copies of meeting agendas, attendance and notes related to correcting physical education requirements * Copy of student course of studies indicating the updated requirements for participating in physical education Description of Internal Monitoring Procedures: Annual review of student course of studies Annual review of a sampling of student transcripts to ensure compliance with policy/practice CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 7B Structured learning time Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's corrective action of developing a new policy/practice to ensure that all students receive physical education. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit the new policy regarding physical education. By September 6, 2013, submit the updated course of studies. Progress Report Due Date(s): 06/14/2013 09/06/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 40 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 7C Early release of high school seniors Partially Implemented Department CPR Findings: A review of documentation and interviews indicated that seniors are released six days earlier than permissible. Description of Corrective Action: * Establishment of working group to review district calendar, including release of seniors (by 4/30) * Revision of school calendar, including release date for seniors (by 6/30) Title/Role(s) of responsible Persons: Expected Date of Superintendent Completion: High School Principal 01/24/2014 Evidence of Completion of the Corrective Action: * submission of school calendar indicating release date for seniors and for all other students Description of Internal Monitoring Procedures: * Annual review of school calendar by administration and approval by school committee CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 7C Early release of high school Status Date: 04/09/2013 seniors Basis for Partial Approval or Disapproval: The Department will accept the district's revised calendar to ensure compliance for the early release of high school seniors. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, the district will submit a revised school year calendar documenting that high school seniors are not dismissed more than 12 school days before the regular scheduled closing date of the high school. Progress Report Due Date(s): 06/14/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 41 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 9 Hiring and employment practices of prospective employers Partially Implemented of students Department CPR Findings: A review of documents and staff interviews indicated that the district does not require prospective employers of students to sign statements that they comply with federal and state laws prohibiting discrimination in hiring or employment practices. Description of Corrective Action: * Establishment of working group to develop a policy around prospective employers of students to sign statements that they comply with federal and state laws prohibiting discrimination in hiring or employment practices (by 4/1) * Development of statement for prospective employers to sign (by 6/1) * Training for appropriate staff in the use of the forms (by 8/30) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent for Business and Finance Completion: High School Principal 09/01/2013 Guidance Department Chair Evidence of Completion of the Corrective Action: * Copies of agendas, attendance and meeting minutes from working group * Submission of copy of statement to be signed by prospective employers * Copy of training agenda and attendance for staff Description of Internal Monitoring Procedures: Annual review by Assistant Superintendent for Business and Finance of records signed by prospective employers CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 9 Hiring and employment practices of Status Date: 04/09/2013 prospective employers of students Basis for Partial Approval or Disapproval: The Department accepts the district's corrective actions of developing statements for prospective employers, establishing policies and procedures for procurement of these statements from employers and training appropriate staff on the requirements of this criterion. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit the district's newly developed policies and procedures, the form and evidence (agendas, signed attendance sheets) that training was conducted on the procurement of signed statements of compliance from prospective employers of students. By November 29, 2013, conduct an internal review and report the number of students involved in work-study, apprenticeship training programs and cooperative work experiences, and the number of signed statements received by the district from these prospective employers. If non-compliance is identified, report the root cause of the ongoing non-compliance and the steps taken by the district to ensure full compliance with this criterion. Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 42 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 10A Student handbooks and codes of conduct Partially Implemented Department CPR Findings: A review of documents indicated that student handbooks do not contain procedures for accepting, investigating and resolving complaints alleging discrimination or harassment; and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. Description of Corrective Action: * Establishment of working group to review student handbooks to ensure that all required regulations/policies are provided to students, including procedures for accepting, investigating and resolving complaints alleging discrimination or harassment; and the disciplinary measures that the school may impose if it is determined that harassment has occurred (by 5/1) * Review of procedures and handbook with school attorney to ensure compliance (by 6/1) * Revision of school handbooks for 2013-2014 school year (by 8/30) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent for Curriculum Completion: 09/01/2013 Evidence of Completion of the Corrective Action: * Copies of agendas, attendance and meeting notes of working group * Evidence of review by school attorney * Copies of school handbooks with appropriate procedures included Description of Internal Monitoring Procedures: * annual review of handbook by school committee and school attorneys to ensure that all required policies/procedures/practices are included CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 10A Student handbooks and codes of Status Date: 04/09/2013 conduct Basis for Partial Approval or Disapproval: The Department accepts the district's proposed plan to revise its student handbooks. Department Order of Corrective Action: Required Elements of Progress Report(s): By September 6, 2013, the district will submit a copy of the updated student handbook that will include procedures for accepting, investigating and resolving complaints alleging discrimination or harassment; and the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. In addition, the district will replace and post the revised version on the district's website. Progress Report Due Date(s): 09/06/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 43 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 17A Use of physical restraint on any student enrolled in a Partially Implemented publicly-funded education program Department CPR Findings: The document review and staff interviews indicated that while special education staff received training, general education staff did not receive training on the use of physical restraint within the first month of the school year. Description of Corrective Action: * Review of required trainings for school staff (by 6/1) * Development of professional development training for general education staff on the use of physical restraint (by 8/1) * Development of professional development training calendar, which includes training for staff on the use of physical restraint (by 8/1) * Provide training to all staff on the use of physical restraint (by 10/1) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent for Curriculum Completion: Director of Special Education 10/01/2013 Evidence of Completion of the Corrective Action: * District professional development calendar * Copies of agendas, meeting minutes and attendance sheets from staff training on the use of physical restraint Description of Internal Monitoring Procedures: Annual submission by each school of agenda, meeting minutes and attendance sheets identifying that staff have been trained on the use of restraints (to be submitted to the Assistant Superintendent) CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 17A Use of physical restraint on any Status Date: 04/09/2013 student enrolled in a publicly-funded education program Basis for Partial Approval or Disapproval: The Department has accepted the district's proposal to provide staff training on the use of physical restraint within the first month of the school year. Department Order of Corrective Action: Required Elements of Progress Report(s): By September 6, 2013, submit documentation (agenda, signed attendance sheets, training materials) that training was or will be conducted for general education staff on the use of physical restraint within the first month of school. Progress Report Due Date(s): 09/06/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 44 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 18 Responsibilities of the school principal Partially Implemented Department CPR Findings: A review of student records, documents and staff interviews indicated that principals obtain parent signatures for consent prior to implementing English as a Second Language (ESL) services and Title 1 services thus delaying the provision of these services to students. In addition, the schools do not have procedures to ensure that the Student Assistance Teams (SAT) document attempted interventions and place this information in the student record. Additionally, when an individual student is referred for an evaluation to determine eligibility for special education, the schools do not ensure that the documentation of the instructional support services for the student is provided as part of the evaluation information reviewed by the IEP Team. Description of Corrective Action: * Review of Title I and ELL Handbook to ensure that procedures for implementing services to students are clearly defined (by 7/1) * Training for administrators (principals and assistant principals), ESL and Title I staff on the implementation policies/practices (by 9/15) * Review of IST policies and practices with principals, particularly around the use of appropriate forms for documenting IST practices and the location of these records (by 10/15) * Review of procedures (with administration and special education Chairpeople) for submitting documentation when a referral for an evaluation to determine special education eligibility has been made, including the submission of IST meeting notes and student work samples (by 10/30) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent for Curriculum Completion: Director of Title I 01/24/2014 Special Education Director Evidence of Completion of the Corrective Action: * Copies of revised ELL and Title I handbooks indicating procedures for obtaining parent consent and for implementing services * Copies of agendas, meeting notes and attendance sheets documenting training of administration and special education Chairpeople on the IST practices, including the completion of IST forms, collection of data, location of student information, and submission of required documents when a student is being referred for an eligibility determination evaluation Description of Internal Monitoring Procedures: Annual review of procedures/practices around implementing ESL and Title I services with administration Annual sampling of student records to ensure that IST documentation (when appropriate) is included Annual sampling of student referral packets to ensure that appropriate IST documentation is included CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 18 Responsibilities of the school principal Corrective Action Plan Status: Approved Status Date: 04/09/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 45 Basis for Partial Approval or Disapproval: The Department accepts the district's proposal to train administrators, ESL and Title I staff on the requirements for program implementation. In addition, the district will review Instructional Support Team procedures and forms, and conduct staff training on the requirements to document interventions and supports provided to students prior to referring a student for special education eligibility. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, submit a description of the revised IST policy and procedures to ensure that documentation of interventions and supports are included in student records when referring students for special education eligibility. Submit evidence (agendas, signed attendance sheets, training materials) that training was conducted on documenting instructional supports and services for students as part of the evaluation information reviewed by the IEP Team. By November 29, 2013, following training, conduct an internal review from each level and report the number of evaluation requests received by the district from IST teams and the number of those records that contained documented interventions and supports that were considered part of the evaluation information and reviewed by the IEP Team. If any noncompliance is identified, report the root cause of the non-compliance and the steps taken to remedy it. Progress Report Due Date(s): 06/14/2013 11/29/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 46 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: The document review and staff interviews indicated that the district does not annually conduct an institutional self-evaluation of its K-12 programming to ensure that all protected classes have equal access to the district's programs and services. Description of Corrective Action: * Establishment of a working group to develop an institutional self-evaluation of its K-12 programming (by 5/1) * Identification of annual timeline for institutional self-evaluation review (by 6/1) * Completion of annual institutional self-evaluation for the 2013 school year (by 8/30) Title/Role(s) of responsible Persons: Expected Date of Assistant Superintendent Completion: Principals 08/30/2013 Evidence of Completion of the Corrective Action: * Copies of minutes, meeting notes and attendance sheets from working group * Copy of institutional self-evaluation form * Copy of institutional self-evaluation review and recommendations for the 2013 school year Description of Internal Monitoring Procedures: Annual review completed and recommendations presented to superintendent CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Approved Status Date: 04/09/2013 Basis for Partial Approval or Disapproval: The Department accepts the district's proposed plan to develop and conduct an institutional self-evaluation. Department Order of Corrective Action: Required Elements of Progress Report(s): By June 14, 2013, the district will submit a copy of the self-evaluation tool. By September 6, 2013, the district will submit the results of its institutional K-12 selfevaluation to ensure that all protected classes have equal access to the district's programs and services. Progress Report Due Date(s): 06/14/2013 09/06/2013 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 47 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION COORDINATED PROGRAM REVIEW Woburn Public Schools Corrective Action Plan Forms Program Area: English Learner Education Prepared by: Gary Reese, 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: August 20, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 48 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 5 Program Placement and Structure Rating: Partially Implemented Department CPR Finding: District documentation indicated the development of a content based ESL curriculum for high school students. However, no ESL curriculum was available for review for the elementary and middle grades. Regarding the ESL curriculum, the district should note that the Department has new regulations in place which may affect the district’s corrective action plan (CAP). Please refer to: http://www.doe.mass.edu/retell/ for more information. Documentation and onsite interviews indicated that ELLs do not receive a sufficient amount of direct ESL instruction as recommended in the Departments guidance document titled: “Guidance on Using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and Make Reclassification Decisions for Limited English Proficient (LEP) Students.” (Please refer to http://www.doe.mass.edu/mcas/mepa/guidance.html - p. 5). This is more evident for ELLs at beginning MEPA (Massachusetts English Proficiency Assessment) levels 1 and 2 in elementary school. Also, the district did not specify the number of days per week that students receive ESL instruction, and instead of specific minutes per session, per number of days a week, the district reported a range. For example, for level 1 and 2 the district reported 1.5 – 2.5, hours of ESL instruction provided to ELLs. ELLs in high school at levels 4 and 5, receive 45 minutes of ESL instruction. Depending on the number of sessions of ESL instruction provided to these students per week, per semester, students may receive hours of ESL instruction consistent with Department guidance. Also, onsite interviews indicated that at the elementary schools (for example – at Shamrock elementary) there are scheduling conflicts, which then prevent students from receiving ESL instruction. Please refer to ELE 15 for comments on Sheltered English Immersion (SEI) professional development training. The Department concluded that the district does not have a fully implemented SEI program. An ESL curriculum for the early grades and middle school was not available for review, most content area teachers have not received SEI Category Training, and the amount of hours of ESL instruction provided to ELLs is inconsistent with Department guidance. Narrative Description of Corrective Action: The district ELL teachers will be meeting as grade-level groups to discuss and develop a formalized ELL curriculum that is in alignment with WIDA. ELL teachers will go through webinar trainings through WIDA in order to facilitate this process. The ELL staff held a meeting on September 9, 2013 to discuss ESL instruction guidelines, both in terms of amount of service delivery, as well as groupings of students. Following this meeting, the Assistant Superintendent for curriculum is meeting individually with each staff member to review her schedule and determine level of compliance. Recommendations for additional staffing will be presented in the 2014-2015 school year budget that is developed in the spring. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 49 Title/Role of Person(s) Responsible for Expected Date of Completion for Each Implementation: Gary Reese, Assistant Corrective Action Activity: April 2014 – ELL Superintendent for Curriculum Curriculum ELE Teachers – elementary, middle and high school August 2014 – Student/staff schedules Evidence of Completion of the Corrective Action: Finalized ELL Curriculum for all grade level groupings, proficiency levels – that is in alignment with WIDA standards and the Massachusetts Curriculum Frameworks – by April 2014 Staff/Student schedules which reflect the appropriate service delivery time by instructional grouping – by August 2014 Description of Internal Monitoring Procedures: Random selection of 15 student schedules to determine compliance with instructional time regulations – October 2014 and annually thereafter CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Status of Corrective Action: Approved Partially Approved Criterion: ELE 5 Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): By January 24, 2014, please provide: 1) A detailed plan that shows that the district is providing sufficient ESL instruction to all ELL students during the 2013-2014 school year based on the Department's Guidance on using MEPA Results to Plan Sheltered English Immersion (SEI) Instruction and make Reclassification Decisions for Limited English Proficient (LEP) Students from September 2009 found at http://www.doe.mass.edu/mcas/mepa/2009/guidance.doc 2) Please complete district information in the attached spreadsheet labeled ELL List for each ELL student in the district. Progress Report Due Date(s): January 24, 2014 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: A review of documentation, student records and interviews indicated that the district does not ensure that major publications of the district (handbooks, codes of conduct, course of studies, progress reports, report cards etc.) are translated in the major languages of the district. The district relies on Google translations available on the district's website; however, this translation software is often inaccurate and not accessible to all parents. See CR 7. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 50 Narrative Description of Corrective Action: The district conducted a review of the primary languages of its families. The two major languages in the district are Spanish and Portuguese. We have identified individuals in the district that are able to provide translations in our two major languages (Donna Janas, Portuguese; Cecilia Semler, Spanish). These two individuals have been contracted to translate major documents for our families. For low incidence primary languages, we will provide translations upon request. Per a discussion with Lynn Summerill from the DESE regarding translation of the handbook, Mrs. Summerill identified the key portions of the handbook that needed to be translated for students, which include the code of discipline, discrimination and harassment policy/procedure, student due process requirements, and promotion and graduation requirements. These documents have been translated into our two primary languages. The translators are currently working on translating our report cards and will work with the teachers during progress report time to provide translated reports. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Expected Date of Completion for Each Corrective Action Activity: 10/1 – Handbook documents Superintendent for Curriculum 11/30 – progress reports Elementary, middle and high school principals 12/30 – report cards Evidence of Completion of the Corrective Action: Copies of Handbook documents – by October 1 Copies of progress reports – by November 30 Copies of report cards – by December 30 Description of Internal Monitoring Procedures: March 2014 and annually thereafter – a random selection of ten student files will be selected and reviewed to determine if translated documents have been provided. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 7 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district’s implementation of criterion CR 7 (Information to be translated into languages other than English) was fully approved on July 29, 2013. The district submitted documentation that training was conducted for administrators on how to obtain interpreters and translated documents (handbook codes of conduct, CR & grievance procedures, graduation requirements etc.) in Portuguese and Spanish, the two high frequency languages of the district. Training documentation (agendas, signed attendance sheets) and statements of assurance were submitted describing the district’s plan to have progress reports and report cards translated for the 2014 SY and a course of studies that will be published in Spanish and Portuguese at the start of the 2015 school year. As a result of the district’s actions, the Department has reviewed and approved the district’s plan to increase the district’s translated documents for parents. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): N/A Progress Report Due Date(s): No further progress reports required. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 51 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 9 Instructional Grouping Department CPR Finding: A review of documentation and interviews indicated that students are not always grouped by proficiency levels. However, onsite interviews indicated that there is great variance among schools. For instance, instructional groupings are dictated by school and staff scheduling rather than student need and their English proficiency levels. Narrative Description of Corrective Action: The ELL staff held a meeting on September 9, 2013 to discuss ESL instruction guidelines, both in terms of amount of service delivery, as well as groupings of students. Following this meeting, the Assistant Superintendent for curriculum is meeting individually with each staff member to review her schedule and determine level of compliance. Recommendations for additional staffing will be presented in the 2014-2015 school year budget that is developed in the spring (in order to appropriately meet instructional grouping guidelines). Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Superintendent for Curriculum ELE Teachers – elementary, middle and high school Expected Date of Completion for Each Corrective Action Activity: August 2014 – student/staff schedules Evidence of Completion of the Corrective Action: Staff/Student schedules which reflect the appropriate service delivery time by instructional grouping Description of Internal Monitoring Procedures: Random selection of 15 student schedules to determine compliance with instructional time regulations – October 2014 and annually thereafter CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 9 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: N/A Department Order of Corrective Action: N/A Required Elements of Progress Report(s): Provide a copy of the most recent ESL teacher schedules for all grade levels district wide. All schedules should include the following for each block of time: 1. Names of the ELL students 2. Grade level for each student 3. English proficiency level for each student. Progress Report Due Date(s): January 24, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 52 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 10 Parental Notification Department CPR Finding: A review of documentation and interviews indicated that parent notification letters are not sent annually. In addition the parent notification asks parents for consent before providing students with ESL services and services will not begin prior to obtaining parental consent. Lastly, the district does not translate progress reports and report cards. Narrative Description of Corrective Action: Parent notification form has been revised to provide parents with an “opt-out” option, as opposed to an “opt-in” option for ELL services. Services will begin once testing is completed and a child is identified as requiring ESL services. This is also been made an annual notification form for notification of services. For a description of progress towards meeting the goal of translated report cards, see ELE criterion #7. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Expected Date of Completion for Each Corrective Action Activity: 12/2013 Superintendent for Curriculum ELE Teachers – elementary, middle and high school Elementary, Middle and High School Principals Evidence of Completion of the Corrective Action: Copy of Parent Notification form Copy of training agenda and minutes from a training with the ELE teachers on September 9, 2013 regarding parent notification requirements and expectations. Description of Internal Monitoring Procedures: October 2013 and annually thereafter – Ten student records will be randomly selected to ensure that parent notification letters are included and that they contain the appropriate language for parents to “opt-out” of services Teachers will sign off annually that services for students started once the students had been identified for services, not after the parents have accepted the services CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 10 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district has revised its parent notification letter, including discontinuing the practice of requiring parent signatures to begin services, and monitoring procedures that include reviews of student records. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): By January 24, 2014, submit the revised parent notification letter. Please note that the DESE has MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 53 developed a template parent notification letter, available at http://www.doe.mass.edu/ell/news12/TitleIII-ParentNotification.pdf. By April 25, 2014, please submit the results of an administrative review of student records, from elementary, middle and high school levels, for evidence of the following: 1) a revised annual parent notification is in each file, and 2) services begin as soon as identification of student’s language needs have been made & without requiring parental consent. This sample must be drawn from students whose parental notification occurred after all corrective actions have been implemented. Identify the number of records reviewed and the number of records in compliance. If the district identifies any files without the revised parent notification and/or the student is not receiving services, report the specific actions taken to remedy each identified student record, the root cause of the non compliance and a plan to remedy it. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): January 24, 2014 & April 25, 2014 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 11 Equal Access to Rating: Partially Implemented Academic Programs and Services Department CPR Finding: A review of documentation and interviews indicated the LEP students enrolled do not have content teachers who have received training in all four categories for sheltering content as required by the Department; therefore, LEP students do not have equal access to a full range of academic opportunities. In addition parents are not provided immediate access to ESL programming and Title I services unless the parent accepts entrance into these programs. Narrative Description of Corrective Action: The Woburn Public Schools will begin training teachers this year using the RETELL model. We were able to offer two in-district RETELL courses this school year, one focusing on skills for elementary level teachers and one for secondary level teachers. Between these two courses, as well as other courses being offered throughout the state, we had 56 teachers register for our first year of offering the RETELL courses. This exceeds our target for the year established by the state. We have had additional teachers interested in participating in the courses, but due to the state’s cap, they were not able to register at this time. Parent notification form has been revised to provide parents with an “opt-out” option, as opposed to an “opt-in” option for ELL services. Services will begin once testing is completed and a child is identified as requiring ESL services. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 54 Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Expected Date of Completion for Each Corrective Action Activity: July 1, 2014 Superintendent for Curriculum Ernie Wells and Eileen Mills, Elementary Principals / RETELL Coordinators Evidence of Completion of the Corrective Action: RETELL cohort list 2013-2014 Course listing for Woburn Public Schools for 2013-2014 school year Copy of Parent Notification form Copy of training agenda and minutes from a training with the ELE teachers on September 9, 2013 regarding parent notification requirements and expectations. Description of Internal Monitoring Procedures: We will be maintaining a database of teachers that have achieved the SEI endorsement and will review this annually to determine which teachers still need the endorsement. October 2013 and annually thereafter – Ten student records will be randomly selected to ensure that parent notification letters are included and that they contain the appropriate language for parents to “opt-out” of services CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 11 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: See ELE 10 and ELE 15. Department Order of Corrective Action: Required Elements of Progress Report(s): See ELE 10 and ELE 15 Progress Report Due Date(s): January 24, 2014 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: Not Implemented Department CPR Finding: A review of documentation and interviews indicated that the district does not translate information on the opportunities for athletics, and course of studies, nor does the district have a system to provide counseling service to LEP students in a language they understand. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 55 Narrative Description of Corrective Action: The Assistant Superintendent for Curriculum met with the middle and high school principals on Friday, September 13th to review guideline and expectations for translation of documents. A procedure was established to ensure that all opportunities for athletics and other extracurricular activities are translated. In addition, as the 2014-2015 course of studies is being developed, it will be translated as well. This translation will be done in the two primary languages for the district, Spanish and Portuguese. A meeting with the guidance department at the high school was held on September 18, 2013. A process for securing translators, when necessary, was developed with the counselors. This includes accessing two currently licensed counselors in the building who can assist with translating in Spanish (M. Marsh and K. Bolcome) as well as accessing a school psychologist in the district for translation in Portuguese (D. Janas). We have also identified a list of other translators that the counselors can access. These translators will sign a confidentiality agreement with the district. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Expected Date of Completion for Each Corrective Action Activity: June 30, 2014 Superintendent for Curriculum Middle and High School principals Middle and High School Guidance staff Evidence of Completion of the Corrective Action: Copies of training meeting agendas and notes for meetings on September 13 and September 18 Copies of translated documents, including program of studies (which will be available in the spring 2014) Copy of procedure identified for guidance counselors for securing translators for meetings with students so that the students have access to counseling services in a language they understand Description of Internal Monitoring Procedures: Annual review of athletics and extra-curricular postings with translations provided in both Spanish and Portuguese Annual review of program of studies to ensure that a translated document has been made available to students CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 12 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district submitted procedures for securing translators for counseling services. The district has the in-house capacity to meet the counseling needs of students in the top two high frequency languages in the district, Spanish and Portuguese. The district has also developed a list of outside translators that can be contracted for the low incidence languages when needed. Please also see DESE comments to ELE 7. As a result of these actions, the district has demonstrated full implementation of this criterion. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): N/A Progress Report Due Date(s): No further progress reports are required. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 56 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: A review of student records and interviews indicated that the district only monitors Formerly English Language Learners (FELL) students for one year not two, at high school level. Narrative Description of Corrective Action: The district has a two year Formerly English Language Learners (FELL) monitoring sheet. ELE teachers should have been working with classroom teachers and school administration to monitor FELLs for two years. Procedures were reviewed with the ELE teachers at a training on September 9, 2013. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Superintendent for Curriculum ELE Teachers – elementary, middle and high school Expected Date of Completion for Each Corrective Action Activity: October 1, 2013 Evidence of Completion of the Corrective Action: Copy of training agenda and sign off sheet Copy of FELL monitoring sheet Description of Internal Monitoring Procedures: In March 2014, and annually thereafter, the district office will randomly select five student FELL files for review to ensure that appropriate monitoring and documentation is occurring. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 13 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district has developed revised monitoring procedures and has conducted staff training on these procedures on 9/9/13. The district is also implementing internal monitoring procedures that will consist of annual reviews of Formerly English Language Learners (FELL) student records to ensure ongoing compliance. Department Order of Corrective Action: See below. Required Elements of Progress Report(s): By January 24, 2014 submit a copy of the districts monitoring form and evidence of staff training (agendas, signed attendance sheets). By April 25, 2014, after implementation of the revised procedures and staff training, review 5 FELL records from each level. Report the number of records that contain monitoring activities for two years. If noncompliance is identified, report the specific actions taken with each student records to ensure full compliance, report the root cause of the ongoing non compliance and submit a plan to remedy it. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): January 24, 2014 & April 25, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 57 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 15 Professional Development Requirements Department CPR Finding: Documentation reviewed indicated that the district has had a multi-year professional development plan that has been implemented since 2007-08 school year and subsequent years to date. The district reported that none of the teachers had completed all four their Sheltered English Immersion (SEI) Category Training. It is particularly evident at the high school level where no teacher has completed any of the SEI professional development training categories. Also, at the middle schools and the elementary grades very few teachers completed some of the SEI categories. Therefore, English language learners (ELLs) are not receiving instruction from content area teachers who have been trained in Sheltered English Immersion as required by Chapter 71A. The district should note that the Department’s regulations and requirements concerning SEI training have changed. Refer to: http://www.doe.mass.edu/retell/ for more information. Narrative Description of Corrective Action: The Woburn Public Schools will begin training teachers this year using the RETELL model. We were able to offer two in-district RETELL courses this school year, one focusing on skills for elementary level teachers and one for secondary level teachers. Between these two courses, as well as other courses being offered throughout the state, we had 56 teachers register for our first year of offering the RETELL courses. This exceeds our target for the year established by the state. We have had additional teachers interested in participating in the courses, but due to the state’s cap, they were not able to register at this time. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Expected Date of Completion for Each Corrective Action Activity: July 1, 2014 Superintendent for Curriculum Ernie Wells and Eileen Mills, Elementary Principals / RETELL Coordinators Evidence of Completion of the Corrective Action: RETELL cohort list 2013-2014 Course listing for Woburn Public Schools for 2013-2014 school year Description of Internal Monitoring Procedures: We will be maintaining a database of teachers that have achieved the SEI endorsement and will review this annually to determine which teachers still need the endorsement. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 15 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department accepts the district’s plan to ensure that all core academic teachers with ELLs and administrators that supervise core academic teachers of ELLs are endorsed. No further submission is required at this time. MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 58 Department Order of Corrective Action: N/A Required Elements of Progress Report(s): None required Progress Report Due Date(s): N/A COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Criterion & Topic: ELE 16 Equitable Facilities Rating: Partially Implemented Department CPR Finding: A facilities observation indicated that at the Malcolm White Elementary School, ELE instruction was conducted in a conference room which at times was shared space and did not have the instructional supplies and equipment comparable other instructional spaces in the overall student population. Narrative Description of Corrective Action: This finding is not accurate. On October 30, 2012, copies of the Malcolm White floor plan, as well as photographs of the ELE classroom, were sent to Lynn Summerill at the DESE. This is not a shared space. In addition, as the pictures demonstrated, the teacher has sufficient instructional supplies and equipment (including educational technology) comparable to the overall student population. We are including copies of these pictures and floor plan again as an addendum to this document. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Expected Date of Completion for Each Corrective Action Activity: September 30, Superintendent for Curriculum Eric Stark, Malcolm White Principal 2013 Evidence of Completion of the Corrective Action: Floor plan of school Photographs of classroom Description of Internal Monitoring Procedures: Review facilities and material availability annually with the ELE teachers to ensure that comparable facilities/ equipment/ instructional supplies are made available to the ELE department. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 16 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The Department has reviewed the district’s submissions and agrees that the facilities at the Malcolm White Elementary School are appropriate. ELE instruction is not a shared space. The instructional supplies and equipment are appropriate and comparable with other instructional spaces in the overall student population. No further action is required by the district. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): N/A Progress Report Due Date(s): No further progress reports are required MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 59 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN (To be completed by school district/charter school) Rating: Partially Implemented Criterion & Topic: ELE 18 Records of LEP Students Department CPR Finding: A review of student records indicated that the following required items were frequently omitted: home language surveys, previous schooling information, parent notification letters, progress reports, and FLEP monitoring plans. Narrative Description of Corrective Action: Required elements for student folders were reviewed with ELE staff on September 9, 2013. Staff were also asked to review their current folders to ensure that previous documentation was included. Title/Role of Person(s) Responsible for Implementation: Gary Reese, Assistant Superintendent for Curriculum ELE Teachers – elementary, middle and high school Expected Date of Completion for Each Corrective Action Activity: June 30, 2014 Evidence of Completion of the Corrective Action: Staff training agenda and minutes from training on September 9, 2013 Review of student records for current students Description of Internal Monitoring Procedures: In March 2014, and annually thereafter, the district office will randomly select ten student files for review to ensure that appropriate documentation is included. CORRECTIVE ACTION PLAN APPROVAL SECTION (To be completed by the Department of Elementary and Secondary Education) Criterion: ELE 18 Status of Corrective Action: Approved Partially Approved Disapproved Basis for Partial Approval or Disapproval: The district submitted a comprehensive CAP that includes staff training, implementation of internal monitoring systems and internal reviews of student records to ensure ongoing compliance. Department Order of Corrective Action: N/A Required Elements of Progress Report(s): By January 24, 2014, submit evidence (agendas, signed attendance sheets) of the training conducted on September 9, 2013. By April 25, 2014, following implementation of staff training and implementation of all corrective actions conduct an internal record review at each level and report: the number of ELL student records reviewed, the number that contained all required elements (home language surveys, parent notification letters, progress reports, and FELL monitoring plans). If any non compliance is identified, report the specific actions taken to correct each student file, and identify and report the root cause of the ongoing non compliance and a plan of action to remedy it. The district will maintain the following documentation and make it available to the Department upon request: list of student names and grade levels for the records reviewed, date of the review, name(s) of person(s) who conducted the review with roles and signatures. Progress Report Due Date(s): January 24, 2014 & April 25, 2014 MA Department of Elementary & Secondary Education, Program Quality Assurance Services Woburn CPR Corrective Action Plan 60