The Commonwealth of Massachusetts Department of Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 March 30, 2005 Dr. Peter Holland Superintendent Belmont Public Schools 644 Pleasant Street Belmont, MA 02478 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Holland: Enclosed is the Department's Coordinated Program Review Follow-up Monitoring Report together with findings regarding your district’s Coordinated Program Review Mid-cycle Review. This report contains the Department's findings based on the onsite activities conducted in your school district to verify the implementation status and effectiveness of corrective steps taken in response to your Coordinated Program Review Report issued on February 8, 2000. While the Department of Education found certain noncompliance issues to be resolved, others were partially corrected, not addressed at all and/or new issues were identified by the Department’s onsite team. As the Department previously informed you, in cases where a district fails to fully and effectively implement a Corrective Action Plan, which was proposed by your district and approved by the Department, the Department must then prepare a Corrective Action Plan for the district, which must be implemented without further delay. You will find these requirements for corrective action and further progress reporting included in the attached report together with any steps that must be taken by the district to fully implement new special education requirements. Please provide the Department with your written assurance that the Department's requirements for corrective action will be implemented by your school district within the timelines specified. Your statement of assurance must be submitted to the Department's Onsite Chairperson by April 10, 2005. Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Onsite Team Chairperson at 781-338-3724. Sincerely, Jennifer Weissman, Coordinated Program Review Follow-up Chairperson Program Quality Assurance Services John D. Stager, Administrator Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Scott Stratford, School Committee Chairperson Patricia Aubin, District Program Review Follow-up Coordinator Gerald Mazor, Collaborative Director Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW Belmont Public Schools ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on April 21, 2000 Progress Reports Submitted on December 17, 2001, July 17, 2002, January 8, 2003, September 1, 2003 and July 29, 2004 Onsite Visit Conducted on March 16, 2005 Date of this Report March 30, 2005 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Special Education Requirements SE 1 Assessments are Partially implemented Student record Assessments for English speaking students are Partially not implemented Student record review and interviews indicated that Provide a description of the procedures the district will Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting evaluations are not always conducted in the student’s native language or other mode of communication when necessary. implement when a student who does not speak English has been referred for a special education evaluation (for example, who will conduct assessments in other languages) by July 1, 2005. Provide copies of evaluation consent forms and all completed assessments for students who do not speak English who were evaluated for special education between July 1 – December 1, 2005 by December 15, 2005. appropriately selected and interpreted for students referred for evaluation review SE 2 Student record review Required and optional assessments appropriately selected and interpreted. Interviews Substantially Implemented Interviews The district conducts required assessments and optional assessments, as appropriate, for students referred for special 2 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified education evaluations. SE 3 Special requirements for determination of specific learning disabilities Substantially Implemented Student record review Interviews The district consistently implements the special requirements for determination of specific learning disabilities. 3 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Some vision statements do not contain all of the required elements and in some instances there is no correlation between the vision statement and the annual goals. Provide training for IEP Chairpersons on the writing of vision statements and the correlation between the vision statement and annual goals and provide the agenda and attendance sheets to the Department by July 1, 2005. Provide copies of vision statements (6 from students age 16 and over from different types of placements ) to the Department by December 15, 2005. Additionally, conduct an internal review for compliance with this requirement and provide the results of the review to the Department by December 15, 2005. SE 6 Determination of transition services (Emphasis on practices in determining needed transition planning and services and consideration of courses of study related to needed transition) Partially Implemented Student record review Interviews Teams provide opportunities for vocational training and determine whether a student is likely to require services from adult human service agencies. SE 7 4 Partially not implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Transfer of parental rights at age of majority Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Partially implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The student records reviewed for students age 18 and above did not contain the required documentation. Provide training for high school chairpersons regarding the required transfer of rights at the age of majority documentation and provide the agenda, sample documentation and attendance sheet to the Department by July 1, 2005. Conduct an internal review of special education students records for students age 18 and older and indicate to the Department how many were found in compliance with this requirements by December 15, 2005. If any were found to be in noncompliance with this requirements, indicate the corrective action taken by the district with the December 15, 2005 progress report. Interviews Student Record Review In some instances students age 18 and over are signing their own IEPs. Interviews indicate that proper procedures are in place regarding the transfer of parental rights at the age of majority. 5 Partially not implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Substantially Implemented Student record review Substantially Implemented Interviews Student record review SE 8 Evaluation Team composition SE 9 Eligibility determination Interviews SE 10 End of school year evaluations Substantially Implemented Student record review Evaluation Teams consistently have all required people in attendance. The district follows the regulatory timelines in making eligibility determinations. The district also provides appropriate services to students not found eligible for special education. End of school year evaluations are consistently conducted within the required timelines. Interviews SE 13 Progress Reports Partially Student Parents receive special Partially not 6 Some progress reports do Provide training for special Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) and content Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting record review Interviews education progress reports as often as parents are informed of the progress of non-disabled students. Progress reports include written information on the student’s progress toward the annual goal. 7 Implemented not contain information regarding whether the student’s progress is sufficient to enable the student to achieve the goals by the end of the IEP period. education providers on this requirement and provide the agenda and attendance sheet to the Department by July 1, 2005. Conduct an internal review of progress reports from the first issuance at each level during the 2005-2006 SY and report the level of compliance to the Department by December 15, 2005 including any further corrective action taken by the district if any progress reports are found not to contain all required information. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Interviews indicate that screening is not always appropriately conducted for English language learners. Indicate the district’s plan to ensure that screening is conducted appropriately for English language learners by July 1, 2005. Provide documentation that this plan is being implemented by SE 14 Annual review Team meeting Substantially Implemented Student record review Interviews SE 15 Outreach by the School District (Child Find) Substantially Implemented Student record review Interviews Document review SE 16 Screening Partially Implemented Interviews The district conducts annual review IEP Team meetings on or before the anniversary date of the implementation of the IEP. The district has annual or more frequent outreach to community groups, schools, and professionals from which promotion or transfer of students in need of special education may be expected. Screening is appropriately conducted for English speaking students. 8 Partially not Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting December 15, 2005. 9 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 17 Initiation of services at age three and Early Intervention transition procedures SE 18A IEP development and content Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Substantially Implemented Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Student record review indicated that IEPs are not always provided to the parent immediately following the Provide the district’s plan for tracking and ensuring that all IEPs are provided to the parent immediately (within 3-5 days) of the Team meeting by July 1, Interviews The district is to be commended for its coordination and transition procedures with Early Intervention. Also, eligible students consistently have IEPs in place by their third birthdays. Student record review IEP Teams develop IEPs with appropriate content. Interviews SE 18B Determination of placement; immediate provision of IEP to parent Partially Implemented Student record review Interviews IEP Teams determine the appropriate placement to deliver the services on student IEPs. Placement selected by the Team is the 10 Partially not Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting least restrictive environment consistent with the needs of the student. 11 development of the IEP at the Team meeting. 2005. Provide a copy of the tracking system used from September 1-December 1, 2005 by December 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 20 Least restrictive program selected Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Partially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Substantially Implemented Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting IEP Teams do not always state why the removal from the general education classroom is considered critical to the student’s program and the basis for its conclusion in the nonparticipation justification on IEP 6. Provide training for Team Chairpersons on writing nonparticipation justifications and provide the agenda and attendance sheet to the Department by July 1, 2005. Provide 3 copies of nonparticipation justifications from each level (elementary, middle and high school) written during the 2005-2006 SY to the Department by December 15, 2005 along with the results of the district’s internal monitoring for compliance with this criterion. Student record review IEP Teams select the least restrictive environment for students. Interviews SE 22 IEP implementation and availability (Emphasis on Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Student record review Interviews The school district has an IEP in effect for eligible students at the beginning of each school year and begins 12 Partially not Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation provision of IEP services without delay; provision of the IEP at the beginning of the school year; and, alternative methods of service delivery where there is a lack of space and/or personnel)) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified IEP services without delay once an IEP has been accepted by the student’s parent. 13 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting SE 23 Confidentiality of personally identifiable information Partially Implemented The district makes efforts to protect confidentiality of personally identifiable information. Partially not Implemented The records selected for the student record review did not contain logs of access. Please provide the district’s statement of assurance that logs of access will be added to special education files by July 1, 2005. The district provides notice at all of the required times. Partially not Implemented District notices (N1 and N2 forms) do not contain all of the required elements in the narrative. Further, evaluation consent forms do not always list the specific assessments to be conducted (for example, several evaluation consent forms reviewed in the student records simply listed “learning”). Provide training for Team Chairpersons on writing district notices and provide the agenda and attendance sheet to the Department by July 1, 2005. Provide 3 copies of N1 forms from each level (elementary, middle and high school) written during the 2005-2006 SY to the Department by December 15, 2005 along with the results of the district’s internal monitoring for compliance Interviews SE 24 Notice to parents Student record review Partially Implemented Student record review Interviews 14 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting with this criterion. 15 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting SE 26 Parent participation in meetings (Emphasis on district’s attempts to ensure parent participation at IEP Team meetings) SE 28 Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' rights SE 29 Communications Substantially Implemented Student record review Interviews Partially Implemented Student record review The district ensures that parents are part of IEP Teams. If a parent can not attend, the district uses other methods to ensure parent participation. See SE 18B Partially not Implemented See SE 18B See SE 18B Interviews indicate that the district has a list of interpreters Partially not Implemented Student record review did not contain any translated Provide a list of parents (by initials only) for whom Interviews Partially Implemented Student record 16 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting documents. Further, interviews indicated that when the district provides notice orally it is not documented in the student record. translation was necessary during the special education process from April 1December 1, 2005. Indicate next to the parent initial, the interpreter’s name and the language for written and oral communications and attach copies of a sample of translated documentation by December 15, 2005. Additionally, provide documentation that Team Chairpersons have been instructed to document oral notices when provided to parents who are speakers of languages other than English in the student record by December 1, 2005. are in English and primary language of home review and translators it can use for this purpose. Interviews 17 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation SE 32 Parent advisory council for special education Substantially Implemented Interviews Substantially Implemented Interviews SE 45 Procedures for suspension up to 10 days and after 10 days; general requirements SE 46 Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school The district has established a parent advisory council on special education which meets the requirements of state law and regulation. The district has appropriate procedures for suspending special education students. Document Review Interviews Substantially Implemented Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified The district has appropriate procedures for suspending students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative school days. 18 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified days or a pattern has developed for suspensions exceeding 10 cumulative days 19 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation SE 50 Responsibilities of the School Principal and Administrator of Special Education Interviews School principals and the Administrator of Special Education fulfill the responsibilities set forth in M.G.L. ch. 71 § 38Q and § 38Q ½ and 603 CMR 28.03(3). Interviews Special education teachers are appropriately certified. Interviews Belmont PS and LABBB Collaborative employees working in programs located at Belmont PS are appropriately certified or licensed. Substantially Implemented SE 51 Appropriate special education teacher certification SE 52 Appropriate certification/ licensure or other credentials – related service providers Substantially Implemented Substantially Implemented Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 20 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting SE 54 Professional development regarding special education Substantially Implemented Interviews Partially Implemented Interviews The district considers the needs of all staff in developing training opportunities and provides a variety of offerings, which include the required topics. SE 55 Special education facilities and classrooms Observations Interviews indicate that special education facilities in all elementary and middle schools are fully integrated into the school. 21 Partially not Implemented Interviews and observation indicate that special education classrooms at Belmont High School are clustered together. One hallway contains three special education classrooms and no other educational spaces. The district was required to correct this situation as a result of the findings of the last Coordinated Program Review. The school has a Provide the Department with the district’s plan to relocate Belmont High School special education classrooms in locations which maximize inclusion of students into the life of the school effective September 2005by July 1, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance plan for relocating these classrooms when a new high school is built but has not identified a short term plan. SE 56 Special education programs and services are evaluated SE 57 Special education child count Substantially Implemented Substantially Implemented Interviews Interviews Document review Special education programs, services and administrative areas are regularly evaluated. The district maintains an accurate special education child count. Other Requirements 22 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting MOA 1 Identification of limited English proficient students MOA 2 Program modification and support services for limited English proficient students Partially Implemented Document review Interviews The district indicates that it uses the appropriate assessments to identify students who are limited English proficient and assess their level of English proficiency. Document review Partially not Implemented Not Implemented Interviews 23 The district did not provide the names and qualifications of persons implementing the assessments. Provide the names and qualifications of persons implementing the assessments by July 1, 2005. The district’s ELE self assessment indicates that some limited English proficient students are placed in general education classrooms that are not sheltered English immersion classrooms. It further indicates that the district employs an ESL tutor, but not a certified ESL teacher. There is no evidence that the program is evaluated and Provide a description of how all ELE programs and services will be structured for the 20052006 SY, including staff qualifications and training for general education teachers, to ensure that they meet the requirements of M.G.L. Chapter 71A and Title VI by July 1, 2005. Provide an update on the status of the implementation of the district’s plan, including training, by December 15, Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting appropriately revised in an ongoing manner or that they are useful in assisting students in gaining English language proficiency. 24 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Interviews indicated that information is not consistently translated when assistance is indicated. No copies of translated materials were provided. Provide the district’s procedures for translating documentation when assistance is requested by July 1, 2005. Provide sample copies of translated materials by December 15, 2005. MOA 7 Information to be translated into languages other than English Partially implemented Interviews MOA 9 Hiring and employment practices of prospective employers of students Substantially implemented Document review Interviews MOA 11A Designation of liaison/ Document review Substantially Implemented Document review Some school publications contain a statement directing people in need of assistance in understanding the document to contact the school This statement is translated into the major languages of the district. The district does not have any employers who recruit at school. The district provided the required documentation. Interviews 25 Partially not implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified coordinator(s); grievance procedures 26 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Interviews and documentation indicated that the only way counselors can communicate with limited English proficient students is through family members, parents or student volunteers. Provide the district’s plan for providing counseling to limited English proficient students with counseling in a confidential and unbiased manner (i.e. without family or students translating for the student) by July 1, 2005. Provide evidence that this plan is being implemented by December 15, 2005. MOA 12A Annual and continuous notification concerning nondiscrimination and coordinators Substantially Implemented The district provided the required documentation. Interviews MOA 14 Counseling and counseling materials free from bias and stereotype Document review Partially Implemented Document review Interviews Counseling and counseling materials are free from bias and stereotypes on the basis of face, sex, religion, sexual orientation, disability and homelessness. 27 Partially not Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district conducts an annual self evaluation of curriculum and program improvement. However, there is no annual evaluation to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability or housing Provide the district’s plan to conduct this annual assessment by July 1, 2005 and provide a copy of the 2005-2006 evaluation to the Department by July 1, 2006. MOA 15 Nondiscriminatory administration of scholarships, prizes and awards MOA 25 Institutional selfevaluation Substantially Implemented Document review Interviews Scholarships, prizes and awards administered by the district are non-discriminatory. While some private scholarships are restricted, there is no evidence that any are given preferential treatment. Document review Not Implemented Interviews 28 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance status, have equal access to all programs, including athletics and extracurricular activities. 29 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district is in the process of developing a home language survey but there is not currently one in use. Provide the Department with a copy of the district’s home language survey with a detailed description of how the survey will be made available at the time of enrollment to identify students who may need to be assessed for their English language proficiency. Also, provide a description of the assessment procedures and the qualifications of the personnel who will administer these assessments by July 1, 2005. Indicate the number of entering students from July 1, 2005-December 1, 2005 who were identified as limited English proficient, their grade level and the school to which ELE 3 Selfassessment Not Implemented Initial Identification 30 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting they are assigned by December 15, 2005. 31 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district does not currently use a waiver form but it provided a copy of a sample waiver form that it may use in the future. Further, the district did not provide a description of waiver implementation practices. However, not all staff who work with limited English proficient students have received SEI training and, therefore, not all general classrooms with limited English proficient students are sheltered English immersion classrooms. The description provided Provide a copy of the waiver form adopted by the district and district waiver implementation procedures by July 1, 2005. Provide a class roster of waived students by December 15, 2005. Selfassessment ELE 4 Not Implemented Waiver Procedures ELE 5 Program Placement and Structure ELE 6 Partially Implemented Partially Selfassessment The district has begun SEI training for staff who work with limited English proficient students. Partially not Implemented Self- The district provided a Partially not 32 Provide documentation that all limited English proficient students who do not have appropriate waivers are receiving instruction in sheltered English immersion classrooms by December 15, 2005. Provide a copy of the Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Implemented Program Exit and Readiness Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting by the district is not currently in use. Further, the district did not provide a copy of the communication to parents regarding the change in placement. communication to parents regarding the change in placement to the Department by July 1, 2005. Provide documentation that the district is implementing its program exit criteria by December 15, 2005. assessment description of the program exit criteria it will use to redesignate a student from limited English proficient to formerly limited English proficient. 33 Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) ELE 7 Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Provide a description of the actions the district has taken to involve parents of limited English proficient students on school advisory councils by July 1, 2005. Provide the number of parents of limited English proficient students on each school’s advisory council by December 15, 2005. Provide a description of how the district’s implementing procedures when a parent “opts out” of an ELE program by July 1, 2005. Provide documentation that these procedures are being implemented by December 15, 2005. See the requirements for MOA 2 with regard to providing the Partially Implemented Selfassessment All parents are invited to be part of the school advisory council. Partially not Implemented The district self-identified a need to have parents of limited English proficient students involved in the school advisory council. Partially Implemented Selfassessment The district indicated that all students are placed in the general education classroom and that parents may reject the offer of additional tutoring time. Partially not Implemented The district did not indicate what would happen if a parent “opts out” of a sheltered English immersion program, nor did it provide the required documentation. Partially Implemented Selfassessment The district states that students are grouped by level of Partially not Implemented The district did not provide the required class Declining Entry to a Program ELE 9 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Parent Involvement ELE 8 Comments Regarding Corrective Action Plan Implementation 34 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting rosters nor a general description of curriculum for each instructional group. The district does not currently provide Sheltered English Immersion (SEI) programs consistent with the requirements of M.G.L. Chapter 71A. Department with a description of the district’s plan to provide limited English proficient students with instructional programs that provide access to sheltered content and instruction in English language skills by July 1, 2005. Instructional Grouping proficiency for additional support by an ESL tutor. 35 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Not Implemented The district indicated that it is not meeting this requirement. Partially not Implemented The district did not provide a description of implementation practices, a list of all academic programs and services, nor did it provide documentation that the Provide a copy of the parental notification in English and the primary/home languages in which it was provided to parents by July 1, 2005. Also provide a description of implementation practices of parental notification by July 1, 2005. For December 15, 2005, provide copies of report cards and progress reports, written in a language understandable to the parent (to the maximum extent possible). Provide a description of implementation practices, a list of all academic programs and services, and documentation that the ELE curriculum reflects the Curriculum Frameworks by July 1, 2005. Selfassessment ELE 10 Parental Notification ELE 11 Equal Access to Academic Programs and Services Partially Implemented Selfassessment The district provided a statement that all students have equal access to academic programs and services. 36 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting ELE curriculum reflects the Curriculum Frameworks. Further, interviews indicated that limited English proficient students do not have equal access to counseling. 37 Additionally, provide the district’s plan to ensure that limited English proficient students have equal access to counseling by July 1, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) ELE 12 Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Follow-up Support Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Provide a description of implementation practices by July 1, 2005. Provide copies of communications to limited English proficient students regarding access to all programs and services a list of all nonacademic programs, services and school sponsored extracurricular activities, including the membership of limited English proficient students in each by December 15, 2005. Provide an adult education course description and a description of how the district provides access for the limited English proficient students described in this criterion by July 1, 2005. Partially Implemented Selfassessment The district indicates that each school has access to an ESL tutor to provide support. Partially not Implemented The district did not describe how the ESL tutor ensures that limited English proficient students have equal access to the nonacademic programs and extracurricular activities available to their English speaking peers. Partially Implemented Selfassessment The district monitors students who have exited an English leaner education program for two years and provides language support services to those students, if needed. Partially Not Implemented The district did not indicate that, to the extent possible, it provides access to adult basic education in English for limited English proficient students for students who Equal Access to nonacademic and extracurricular programs ELE 13 Comments Regarding Corrective Action Plan Implementation 38 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance previously enrolled in a public secondary school in the Commonwealth directly from a country other than the U.S. and who were unable to achieve English language proficiency as determined by assessments. 39 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Not Implemented The district does not currently have a licensed teacher, although one is in the district budget for FY 06. No other information was provided. Provide an update on the 20052006 staffing situation for the ELE program by July 1, 2005. Provide the required documentation that all teachers of limited English proficient students are literate in English and hold the appropriate licenses or waivers from the DOE by December 15, 2005. Provide a copy of the district professional development plan for the 2005-2006 SY by July 1, 2005. Provide a list of topics covered at professional development opportunities from August – November 2005 and a roster of attendees by December 15, 2005. Provide a description of implementation practices by Selfassessment ELE 14 Licensure and Fluency Requirements ELE 15 Partially Implemented Selfassessment The district has trained staff on the administration of the MELA-O. Partially not Implemented The district does not currently meet the professional development requirements but indicates that it will in the 20052006 SY. Partially Implemented Selfassessment The district provided its assurance that it submits the Partially not Implemented The district did not provide a description of Professional Development Requirements ELE 17 40 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requiremen ts or Corrective Action Plan Determined to be Substantially Implemente d Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting implementation practices or program evaluation reports. July 1, 2005 and a copy of program evaluation reports by December 15, 2005. The district is not currently using a home language survey, therefore home language surveys are not in student records. Further, the district’s selfassessment could not confirm that student records contain all required elements, but rather suggested that principals should review limited English proficient student records to ensure that they do require all required documentation. Please develop a list of the student record documentation requirements for LEP students for distribution and review with all building principals by July 1, 2005. Please provide a report from each building principal indicating whether limited English proficient student records contain all required information December 15, 2005. DOE Data Submission Requirements and Program Evaluation ELE 18 required data to the DOE. Selfassessment Not Implemented Records of LEP students 41 42