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 22, 2006 Robert Calabrese, Superintendent Billerica Public Schools 365 Boston Rd Billerica, MA 01821 Re: ’06 Mid-cycle Coordinated Program Review Report Dear Superintendent Calabrese: Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report. This report contains findings based on onsite monitoring activities conducted to verify the implementation status and effectiveness of corrective action activities approved by the Department that were intended to address findings of noncompliance included in the Billerica Public Schools ’03 Coordinated Program Review Report issued on April 24, 2003. (In the remainder of this letter, please read “district” as meaning “school district or charter school.”) As you know, one component of the Department’s Mid-cycle Review process is the review of your district's self-assessment in the area of English learner education (ELE). The purpose of this activity is to determine if your district is beginning to implement the significant changes in M.G.L. Chapter 71A, this state’s law governing the education of limited English proficient students that was adopted by voters as Question 2 in 2002. The Department has reviewed your district’s ELE self-assessment documents and is providing you now with advisory comments and actions to be implemented in anticipation of your district’s next scheduled Coordinated Program Review. Where indicated in our report, your district is urged to request technical assistance in areas that, based solely on your self-assessment documents, were found not likely to be fully implemented. To secure assistance, you may consult with your Mid-cycle Review Chairperson or call Robyn Dowling-Grant in Program Quality Assurance Services at 781-3383732. You may also consult with staff in the Department’s Office of Language Acquisition and Achievement at 781-338-3534 and obtain additional ELE guidance documents through the Department’s web site at http://www.doe.mass.edu/ell/ . We are pleased with the substantial progress Billerica Public Schools has made in implementing its approved Corrective Action Plan, however, while the Department of Education found certain noncompliance issues to be resolved, others were partially corrected, not addressed at all and/or the Department’s onsite team identified new issues of noncompliance. In areas where the district has failed to implement fully its approved Corrective Action Plan, the Department views these findings to be serious. 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 12, 2006. 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 781-338-3703. Sincerely, Dean Paolillo, Coordinated Program Review Follow-up Chairperson Program Quality Assurance Services Darlene Lynch, Assistant Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Robert Keough, School Committee Chairperson Karen Malio, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Billerica Public Schools ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Date of Coordinated Program Review (CPR): January 13-17, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: August 25, 2003 Dates of Corrective Action Plan Progress Reports: October 24, 2004, January 12, 2005, January 31, 2005, May 12, 2005, August 25, 2005, January 6, 2005 Dates of this Mid-cycle Review Onsite Visit: February 6-8, 2006 Date of this Report: March 22, 2006 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Special Education Requirements (including new IDEA-2004 Requirements Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 1 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) SE 6 Determination of Transition Services Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Partial Student Record Review, Documentation and Interviews Early childhood transition activities were conducted for young children and appropriate evaluations, including home assessments, were conducted. Partial The student record review indicates that the Team considers the parent and student input in developing the student’s Transition Plan. However, the vision statements for older students do not always indicate what activities will be conducted to facilitate meeting the student’s vision. The district will again review the requirements for post-secondary transition in IDEA 2004 with staff. Verification of the training will be provided to the Department by June 30, 2006. The district has developed district-wide transition procedures and has incorporated these procedures into its policies and procedures manual. The district has developed a transition checklist that was updated on January 27, 2005. SE 8 IEP Team composition and attendance Yes Student Record Review and Interviews Team attendance sheets demonstrate that the required personnel are attending the Team meeting. A person with the authority to commit the resources of the district was in attendance. SE 12 Yes Student Record The student record review and Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 2 of 23 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Frequency of re-evaluation Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Review and Documentation the review of the 05-06 IEP logs indicate substantial implementation of completing the three-year re-evaluation. SE 13 Progress Reports and content Yes Student Record Review and Documentation Progress reports were completed consistent with the report card cycle in the student records examined. The progress reports documented the progress towards meeting the student’s annual IEP goals. The district’s policy and procedure manual identifies the required elements of progress reports and the responsibilities of special education staff in the completion of progress reports. SE 14 Review and revision of IEPs Yes Student Record Review and Student records indicate that the district conducts annual reviews. Chairperson annual review logs demonstrate the district actively tracks and records the completion of annual IEP reviews. Documentation Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 3 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements SE 25B Resolution of disputes Yes Documentation and Interviews The district is implementing the new requirement for offering dispute resolution meetings prior to proceeding to the BSEA. SE 30 Notice of procedural safeguards Yes Student Record Review N1 notices document that the district is providing parents with copies of the interim notice of procedural safe guards or in past years, the parent’s rights brochure. SE 46 Procedures for suspension of students with disabilities more than 10 days Yes Student Record Review The student records documented the reconvening of members of a student’s Team to conduct manifestation determinations when necessary. (Refer to full text of 20052006 CPR requirements) Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 4 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Student Records and Interviews See the comment to the right. In general, the district is selecting assessments that appropriately target the suspected areas of disability. Partial In a few instances, the students primary language is identified as English on the IEP, however, the evaluators note that the student’s primary language is not English. The Department noted that in these instances, translators were used during the evaluations that spoke the student’s primary language. A concern remains that the district identified the student’s primary language as English on the IEP. The district will review the IEPs of multi-lingual students to ensure that the primary language is accurately identified on the student IEPs. The district will identify the number of IEPs reviewed; it’s method of verification and any corrective action that was initiated because of the district’s review. The corrective action is due by June 30, 2006. Other Special Education Requirements Originally Cited in CPR Report SE 1 Selection of Assessments Partial The Department notes that IEPs and the evaluations documented when the student was provided a translator or what assessments were conducted to determine the student’s English proficiency prior to the selection of assessments to determine the student’s eligibility for special education. Yes SE 2 Student Records, The district has made considerable improvement in Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 5 of 23 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Required Assessments SE 7 Transfer of Rights SE 9 Timelines for Determination of Eligibility Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Documentation and Interviews meeting this standard. Assessments focusing on the student’s suspected disability are selected and teacher and educational status assessments (or developmental profile for very young children such as three and four year olds) were contained in records examined. Partial Partial Student Records and Documentation Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements The student IEPs documented the transfer of rights in the additional information section. Partial The student record did not always contain the notice of the transfer of rights. The district will provide a memo to staff reminding chairpersons that the “transfer of rights” notice must be sent upon the child’s 17 birthday and documented in the student record, not just the IEP. The corrective action is due by June 30, 2006. See the comment to the right. Partial IEP logs indicate that when Team meetings are held near the end of the school year, the IEPs are not provided within the timelines required, in a few instances, the IEP was not provided to the The district will review with its chairpersons the “end of the year” requirements for developing an IEP and issuing the IEP to the parent(s). The district will provide evidence of the training conducted with staff in this regard. The Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 6 of 23 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance parent until the start of the following school year despite having sufficient time to complete the eligibility determination, develop an IEP and issue the IEP consistent with the requirements of 603 CMR 28.05(1). SE 11 Independent Evaluations Yes Documentation and Interviews The district’s policy and procedure manual contains processes that are consistent with federal and state regulation. The district has developed a letter to parents that fully encapsulates the district’s responsibility regarding Independent Educational Evaluations. Documentation and Interviews The district has established policies for conducting kindergarten screenings. The district has established screening procedures for three Yes SE 15 Outreach Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 7 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements corrective action is due by June 30, 2006. Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Placement forms did not always identify the specific The district will provide a memo to its chairpersons reminding them and four year olds. District interviews indicate that Billerica Public Schools makes annual outreach to a variety of groups from which students with disabilities may emerge or be identified. SE 17 Initiation of Services Yes Student Records, Documentation and Interviews The district is evaluating young children entering through Early Intervention and providing services to young children. SE 18A IEP Development Yes Student Record Review Parent concerns, comments and vision for the student are well documented in the IEP. Team meeting notes showed evidence of the consideration of parental concerns that were incorporated into the IEP. SE 18B Placement Partial Student Record Review See comment to the right. Partial Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 8 of 23 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance placement type and location. The parent did not always sign the placement form that corresponded to the student’s IEP. SE 19 Extended Evaluation Yes SE 20 Least Restrictive Environment Yes Student Records The review indicated that extended evaluations were used appropriately (only after determining the student’s eligibility for special education services). Student Records and Interviews The student records indicated that Teams consider the individual needs of students in determining placement. Some parental interviews indicated that at the middle school, an issue existed in the determination of a program for students in a language based program, however, further Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 9 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to ensure that the parent signs the placement page and that placement pages have a “check off” for the placement type and identify the specific location for the delivery of services. The district will provide a copy of the memo provided to staff by June 30, 2006. Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Partial The student record review indicates N1 notices are documented in the student record, however, the notices do not always address the key questions for the individual student. The district must review the federal notification requirements with all applicable staff. Verification of the staff training is to be provided by June 30, 2006. follow-up with district personnel and a review of district documentation indicate that the district is considering the Least Restrictive Environment and has an appropriate continuum of services for students with disabilities regardless of disability type. SE 24 Notice Partial Student Record Review See the comment to the right. SE 25 Parental Consent Yes Student Record Review The educational decision maker signed IEPs and the consent forms to evaluate or re-evaluate the student. Copies of the consent forms and signed IEPs were kept in the student record. The Department noted that in a few instances, the parent did not sign placement forms. Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 10 of 23 Criterion Number and Topic Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Yes Student Record Review Notices were translated into the appropriate language. In the selected records where translation was a concern the Team documented in the student record the parent’s desire to have the IEP in English. SE 32 PAC Yes Interviews The district has a special education parent advisory council that meets regularly and has access to district resources. SE 33 Curriculum Yes Interviews and Student Records Student records contained copies of the student schedules that demonstrate access to the general curriculum; IEPs documented the student’s ability to participate in the general education setting. SE 35 Assistive Technology Yes Documentation Documentation (including purchase orders) indicates the district is providing assistive (Refer to full text of 20052006 CPR requirements) SE 29 Communications Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 11 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Partial While the district is appropriately developing IEPs and determining the placement for students who require an out-of-district placement, the student records indicate that documentation of out-ofdistrict monitoring activities are not being kept with the student record. The district must review the requirements for out-of-district monitoring and for documenting that monitoring within the student record. Evidence of the training is to be provided by June 30, 2006. technology to students when needed. Some examples of the assistive technology provided are: Alphasmart systems, computers and FM systems. SE 37 Procedures for out of district Partial Student records See the comment to the right. SE 40 Instructional Groupings five+ Yes Documentation The district has documented its increased instructional groupings consistent with the requirements of state regulation. Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 12 of 23 Criterion Number and Topic Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements SE 41 Age Span Requirements Yes Documentation The district has documented corrective action regarding the age span requirements in its “life skills” program at the Billerica Memorial High School. Age spans are no longer exceeding the 48-month requirement. In addition, the district has documented its request for an age span waiver for its multi handicapped life skills program, consistent with the requirements of state regulation. SE 45 Procedures for Suspension Yes Student Records, Documentation and Interviews The student records documented the reconvening of members of a student’s Team to conduct manifestation determinations when necessary. SE 50 Responsibilities of Special Yes Student Records Pre-Referral and home and hospital information is documented in the student (Refer to full text of 20052006 CPR requirements) Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 13 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance record. Education Administrator SE 51 Teacher Licensure Yes Documentation Staff members have current licensure or waiver requests pending before the Department. SE 52 Related Service Licensure Yes Documentation Staff members have current licensure or have licenses pending from the Department. SE 54 Professional Development Yes Documentation The district has conducted considerable professional development that included (but was not limited to) the following areas: “E-Sped” training for the management of IEPs and IEP timelines, conducting assessments, the IEP process, transition planning, completing amendments to IEPs and conducting functional behavioral assessments. Attendance was documented at Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 14 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance all of the in-service training activities. In general, the district has actively engaged in diverse professional development for staff to improve the quality of special education services provided in the Billerica Public Schools. Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 15 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) SE 55 Special Education Facilities SE 56 Program Evaluation Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Partial Observation See the comment to the right. Partial Documentation The district has used an outside agency to evaluate its special education programs. The evaluation agency used parental surveys, graduation rates, and drop out rates for special Yes Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements The issues identified in the Department’s last Coordinated Program Review for the Hajjar School have still not been resolved. Observations indicate that issues identified by the onsite team in the district’s January 2003 Coordinated Program Review were not corrected by the district. An additional issue was noted at the Hajjar School. In one special education classroom, the school had “doubled up” its classroom space, creating a distracting environment for both classes of students. The district must address the outstanding area of noncompliance by June 30, 2006. A follow-up onsite visit will be scheduled for September 2006. Failure to correct the outstanding issues of noncompliance will lead to a withholding of federal funds. Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 16 of 23 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance education students in preparing its evaluation results. Recommendations were made to broaden the evaluation activities and in 2004, the evaluation included reviewing the Department’s Coordinated Program Review, surveying staff, conducting interviews and technical assistance in implementing the district’s corrective action activities. The Department recommends that future evaluation activities should include examining specific special education programs within Billerica Public Schools and analyzing placement data and MCAS success for students in special education. Civil Rights (MOA) and Other General Education Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 17 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Yes Reviewed data reports. The review of the district’s data indicated disproportionate representation in populations that are too low in number to be statistically relevant. Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Requirements MOA 4 Disproportional ity Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 18 of 23 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Billerica Public Schools English Learning Education (ELE) Requirements Mid-Cycle Review Advisory Comments Resulting From The Department’s Review Of Local Self-Assessment Documents (Please refer to full text of 2005-2006 CPR-ELE legal requirements and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) ELE Criterion Number and Topic Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission ELE 1 Annual Assessment The district indicates that students K-12 are evaluated using the MELA-O. The district has qualified MELA-O providers. Students in grades 3-12 are also evaluated using the MEPA. The district indicates that all students who are new arrivals to Billerica Public Schools are also assessed using the LAS-O for grades K-12 and LAS R/W for newcomers between grades 312. New arrivals are assessed upon entry into the school system. The district’s annual assessment procedures are consistent with state requirements. ELE 2 MCAS Participation The district is providing appropriate accommodations for limited English proficient students. The district is following state guidelines regarding the participation of LEP students in MCAS. ELE 3 Initial Identification The district has established procedures for the screening of all incoming students who may be limited English proficient. The Department notes, however, that the district’s home language survey is provided in English. The district should endeavor to develop home language surveys in the home languages of the Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 19 of 23 ELE Criterion Number and Topic ELE 4 Waiver Procedures Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission student’s that are potentially Limited English Proficient. Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review The district has developed waiver forms. The district has translated the documents regarding program descriptions and waiver practices in other languages. ELE 5 Program Placement and Structure The district indicates that students who are LEP are “mainstreamed” in general education; in addition, some students also receive tutorial services from ESL providers. The district indicates it has conducted extensive staff training at all schools in Sheltered English Immersion. Attendance sheets were provided, signed by all staff in participation at the SEI trainings. Training agendas were provided under ELE 15. ELE 6 Program Exit and Readiness The district uses assessment data (MELA-O, MEPA, LAS-O, LAS/RW) and classroom performance to determine whether a student should be designated as Formerly Limited English Proficient (FLEP). ELE 7 Parent Involvement Parent involvement is encouraged through the participation in school councils. It is not clear how parents are encouraged to participate. The district must document its efforts to solicit parent participation. For example, what written notifications were provided to parents of LEP students to participate in school councils? The district will document its activities to the Department as part of its June 30, 2006 progress report. Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 20 of 23 ELE Criterion Number and Topic ELE 8 Declining Entry to a Program Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission The district indicates that: “parents that have declined additional language support services will have their child placed in a classroom with a teacher that is trained in SEI.” It is unclear how this differs from a parent who allows entry into a SEI program? ELE 9 Instructional Grouping The district has indicated that their current practice is not to “mix” instructional age groups. ELE 10 Parental Notification The district provided copies of its English and other language written notifications to parents. ELE 11 Equal Access to Academic Programs and Services The district indicates that students who are Limited English Proficient (LEP) have access across the program areas and access to Special Education services. Teachers across grade levels and curriculum areas are trained in providing Sheltered English Immersion. ELE 12 Equal Access to Nonacademic and Extracurricular Programs The district indicates that students who are Limited English Proficient (LEP) have access across extracurricular and nonacademic programs. ELE 13 The district indicates that follow-up monitoring for LEP students is done by means of MELA-O observation and Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review The district must clarify what options exist for students of parents who do not wish their child to be enrolled in the district’s SEI classrooms. Describe what alternatives exist to provide these students with support. The district will identify the supports available to students as part of its June 30, 2006 progress report. There is insufficient information provided by the district on its follow-up procedures. The district is to identify which staff members are designated to Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 21 of 23 ELE Criterion Number and Topic Follow-up Support ELE 14 Licensure and Fluency Requirements Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission conversations with the student’s classroom teacher. Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review conduct the follow-up. Specifically indicate whether the district intends to use only the MELA-O trained personnel. Describe how the follow-up is documented and by whom. Identify what action the district takes if a student is not making progress. The district must develop a more formalized process for the monitoring of FLEP students. The district will provide a specific plan for its follow-up activities and describe how the follow-up is conducted in each of the school buildings within the school district as part of its June 30, 2006 progress report. The district has indicated that all staff within the Billerica Public Schools are fluent in English. Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 22 of 23 ELE Criterion Number and Topic Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission ELE 15 Professional Development Requirements The district provided its Professional Development plan dated September 2005. In that plan, the district indicates a district wide goals and objectives to provide SEI training to staff and assessment training to staff. Training agendas and teacher attendance sheets were provided. ELE 16 Equitable Facilities (To be reviewed during next CPR visit) The Department did not observe facilities for English Language Learners. Observations of facilities were limited to those buildings with special education noncompliance issues noted in the district’s last Coordinated Program Review. The district indicates all ELE students are housed in the same facilities as proficient English speakers. ELE 17 DOE Data Submission Requirements and Program Evaluation The district indicates it uses state testing data and local testing data to determine the English proficiency of LEP students in listening, speaking, reading and writing. The district should, however, examine its program evaluation elements more closely. Particularly consider: which staff members meet to review the data; When are reviews of the data conducted; and have any program changes been made as a result of the district’s activities? ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) The Department did not review student records for ELE students during the Mid-Cycle Review. ELE student records will be reviewed during the next Coordinated Program Review. The district indicates that all student data relating to ELL is placed in the individual school-based cumulative folder for the student. Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review Mid-cycle Cover Letter and Report Format 2006.doc Rev. 11/28/05 Billerica Public Schools Coordinated Program Review Mid-cycle Report March 22, 2006 Page 23 of 23