Massachusetts Department of Elementary and Secondary Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 July 5, 2007 Dr. Michael F. Fitzpatrick, Superintendent Blackstone Valley Regional Vocational Technical High School 65 Pleasant St. Upton, MA 01568 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Fitzpatrick: Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted on May 24, 2007 to verify the implementation and effectiveness of corrective action approved by the Department to address findings of noncompliance included in the Blackstone Valley Regional Vocational Technical High School Coordinated Program Review Report issued on September 9, 2004. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been newly created or substantially changed in response to IDEA 2004. Another component of the Department’s Mid-cycle Review is the review of your school district or charter school's self-assessment in the area of English learner education (ELE). (In the remainder of this letter, please read “district” as meaning “school district or charter school.”) The purpose of this review is to determine whether your district is implementing the significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient students, that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your district’s ELE self-assessment (documentation and any written analysis of compliance) and, based solely on that self-assessment, is providing you in this report with findings on your ELE program and the corresponding corrective action to be implemented. Your district is urged to request technical assistance in relation to any of these findings or this prescribed corrective action from me or from staff in the Department’s Office of Language Acquisition and Achievement at 781338-3534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/ . While the Department of Education found your district to have resolved certain noncompliance issues, others were partially corrected, or the Department’s onsite team identified new issues of noncompliance, either noncompliance with special education criteria added or substantially changed in response to IDEA 2004, noncompliance with ELE criteria, or other new noncompliance. 1 In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that must be implemented without delay. You will find these requirements for corrective action included in the attached report, along with requirements for progress reporting. Please provide the Department with your written assurance that all of the Department's requirements for corrective action will be implemented by your district within the timelines specified. You must submit your statement of assurance to me by July 23, 2007. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 781-338- 3780. Sincerely, George K. Haile, Mid-cycle Review Chairperson Program Quality Assurance Services Priscilla O. McPhee, Assistant Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Michael D. Peterson, School Committee Chairperson Linda Gross, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION Blackstone Valley Regional Vocational Technical High School Date of Coordinated Program Review (Focused Monitoring CPR): 9/9/04 Date of Coordinated Program Review Corrective Action Plan Approval: 2/1/05 Dates of Corrective Action Plan Progress Reports: 7/29/05, 3/20/06 Dates of this Mid-cycle Review Onsite Visit: 5/24/07 Date of this Report: July 5, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Special Education Criteria SE 9 – Eligibility Determination Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Originally Cited in CPR Report and Monitored in Mid-cycle Document Review and Student Record Review Assessments were consistently completed and IEPs provided to parents within the required timelines. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 1 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 18A – IEP Development and Content Student Records and Interviews Staff, students and parents actively participate in developing the IEP. IEPs contain all required elements. SE18B – Determination of Placement; Immediate Provision of IEP to Parent Student Records and Interviews Students are consistently placed in the least restrictive setting. Parents receive documentation of goal areas and service delivery, as part of the shared meeting notes, at the conclusion of Team meetings. Proposed IEPs are consistently sent to parents in a timely manner. Corrective Action Not Implemented Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 2 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 20 – Least Restrictive Program Selected Student Records and Interviews All students are included in regular education shops and often in regular core subject academic classes, with inclass or pull-out support as needed. SE 22 – IEP Implementation and Availability Documentati on and Interviews Staff, including aides, access IEPs through a password protected computer program. Staff are consistently notified when IEP consent is received. SE 25 – Parental Consent Student Records and Interviews Parent consent is consistently received in all cases where it is required. SE 26 – Parent Participation in Meetings Student Records and Interviews Parents consistently participate in IEP Team meetings. The school routinely uses telephone conference calls to include parents who cannot attend. Corrective Action Not Implemented Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Conference call participation is not always well documented in student records. Clarify procedures to document parent participation in Team meetings when using a conference call, such as using the parent contact form. Submit, by October 19, 2007, evidence that procedures have been communicated to Team Chairs. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 3 of 17 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Document Review and Interviews The school has held the annual parent rights training and advertised to develop the PAC. The school does not have an active PAC at this time. SE 32 – Parent Advisory Council for Special Education The school routinely conducts a Functional Behavioral Assessment and develops Behavioral Intervention Plans for students with interfering behaviors. Behavioral Goals and supports are often included in IEPs. SE 43 – Behavioral Interventions Student Records and Interviews SE 44 – Procedure for Recording Suspensions Document Review and Interviews The school has a written procedure, understood by appropriate staff. SE 45 – Procedures for Suspension Up to 10 Days and after 10 Days Document Review and Interviews The district has appropriate suspension procedures outlined in the student handbook. Key staff understand the procedures. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 4 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Submit, by October 19, 2007, plans to develop an active PAC this school year. Include dates for parent training and any other scheduled events to attract parent participation, including PAC participation in evaluating special education programs and services. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 47 – Procedures for students not yet determined to be eligible Document Review and Interviews Administrative staff understand the requirements for protection of students who are not yet eligible but may be eligible. SE 48 – FAPE Document Review, Student Record Review and Interviews The school consistently includes all students in general education academic and vocational shop classes, with pull-out or in-class support as needed. All eligible students are encouraged to participate in non-academic and extracurricular activities. Document Review and Interviews The school has an appropriately licensed and experienced administrator for its special education program. The administrator collaborates effectively with the principal and superintendent. (Free, Appropriate, Public Education): Equal Opportunity to Participate in Educational, Nonacademic, Extracurricular and Ancillary Programs SE 50 Responsibilities of the Principal and Administrator of Special Education Corrective Action Not Implemented Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 5 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 54 – Professional Development Regarding Special Education Document Review and Interviews The school provides an array of professional development opportunities for all staff and utilizes resources from the BICO Collaborative for additional training opportunities. SE 55 – Special Education Facilities and Classrooms Document Review, Interviews and Observation The school provides up-todate accessible spaces for all students and staff. Eligible students are served within regular education spaces and in comparable spaces for any required pull-out services. Corrective Action Not Implemented Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 6 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Partial Document Review, Student Record Review and Interviews Student records indicated that IEPs contain the new Transition Planning Chart. Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Partial Student records and interviews indicated that Transition planning begins during the latter part of Grade 10. The district policy indicates transition planning should begin by the end of Grade 9. Direct all IEP Team Chairs to include the Transition Planning Chart with all IEPs for students turning 16 during the IEP period . Special Education Criteria created or revised in response to IDEA-2004 SE 6 – Determination of Transition Services Charts include appropriate information. Submit, by October 19, 2007, evidence that all Team Chairs have been notified of these requirements. Submit, by February 1, 2008, 2007, an administrative review of student records for students turning 16 for evidence of the Transition Planning Chart. Report on the number of records reviewed and the number in compliance, and any additional corrective action taken. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 7 of 17 Criterion Number and Topic SE 8 – Evaluation Team Composition SE 12 – Frequency of Re-Evaluation SE 13 – Progress Reports and Content Criterion Implemented Method(s) of Verification Student Records and Interviews Document Review and Student Record Review Student Records Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Team meetings consistently include all required participants, including representatives from vocational shops. Student records include sign-off forms for parents to excuse a required member from the IEP Team. Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Parents give verbal agreement and sign-off forms are not always signed by the parent to document their agreement. There was not always evidence that excused participants had submitted written input, as required. Remind all IEP Team Chairs to always have parents sign the excusal form, as needed. Submit by October 19, 2007, a copy of the reminder provided for Team Chairs to ensure excusal forms are always signed by the parent. Re-evaluations were consistently completed within the three year timeline. Progress Reports are well written and contain a descriptive narrative that clearly addresses progress made toward goals and objectives. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 8 of 17 Submit, by February 1, 2008, an administrative review of student records to determine if all excusal forms have been signed by parents and if excused participants have submitted written input for the Team. Report on the number of records reviewed and the number in compliance, and any additional corrective action taken. Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented SE 14 – Annual Review Team Meeting Partial Student Records and Interviews Records include documentation of annual meetings and amendment meetings held throughout the school year. Criterion Determined to be Partially Implemented or Not Implemented Partial Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Annual meetings are often held at the end of the IEP period, resulting in IEPs that lapse before a new IEP is approved. Modify the Annual Review Team meeting schedule to provide time for parental review and approval of a new IEP by the time the previous IEP lapses. Submit, by October 19, 2007 a plan to address this issue and evidence that the plan has been communicated to Team Chairs. Submit, by February 1, 2008, an administrative review of timelines for holding annual IEP review Team meetings to ensure a new IEP is proposed before the previous IEP lapses. Report on the number of records reviewed and the number in compliance, and any additional corrective action taken. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 9 of 17 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented SE 25B – Resolution of Disputes Student Records and Interviews Staff are proactive in reconvening an IEP Team to address parent concerns. There have been no BSEA hearings or PQA complaints during the past two years. SE 33 – Involvement in the General Curriculum Document Review, Student Record Review and Interviews All students are included in regular education shops and often in regular core subject academic classes, with in-class or pull-out support as needed. SE 46 – Suspension of Students with Disabilities Exceeding 10 Days Document Review and Interviews The district has appropriate suspension procedures outlined in the student handbook. Key staff understand the procedures. Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 10 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification MOA 7 – Information in Languages Other than English Document Review, Student Record Review and interviews The school obtains translated documents, as needed, through use of an outside agency. MOA 7A – School Year Schedules Document Review and Interviews The school provides a school year of 191 days. MOA 7B – Structured Learning Time Document Review and Interviews The school provides more than 1100 hours of structured learning time. (Refer to full text of 20062007 CPR requirements) Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Civil Rights (MOA) and Other General Education Requirements Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 11 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements MOA 7C – Early Release of High School Seniors MOA 9 – Hiring and Employment Practices of Prospective Employers of Students MOA 10A Notification of School District Staff and the General Public Document Review and Interviews Document Review and Interviews The school requires all student employers to sign a statement assuring they will not discriminate. Document Review The handbook contains all required information, up-to-date references and a grievance procedure with contact information. MOA 11A Designation of Coordinator(s); Grievance Procedures Document Review and Interviews The handbook includes a grievance procedure and indicates the titles of coordinators and contact information. MOA 17A – Use of physical restraint Document Review, Student Record Review and Interviews The school has trained all staff using the DOE power-point presentation and has staff that are fully trained. Although the school provides more than the required number of school days, it releases Seniors after the 168th day. Regulations require that the school only release Seniors no more than twelve days from the last scheduled school day. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 12 of 17 Submit, by October 19, 2007, a schedule for the 2007-2008 school year indicating that Seniors are released no more than twelve days from the last scheduled day of school, and assurance from the Superintendent that this schedule will be followed in the future. Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification MOA 21 – Staff Training Regarding Civil Rights Responsibilities Document Review and Interviews All staff have received training regarding their responsibilities under civil rights law. MOA 22 – Accessibility of Programs and Services for Students with Disabilities Document Review and Observation The school building is fully accessible. MOA 23 – Comparability of Facilities and Programs Document Review, Interviews and Observation Spaces used for special education services are comparable and all programs are open to eligible students. MOA 25 – Institutional Self-Evaluation Document Review and Interviews The school has put together study groups to review program and service components. The administration meets with each group and incorporates recommendations into the school improvement plan. (Refer to full text of 20062007 CPR requirements) Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 13 of 17 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Blackstone Valley Regional Vocational Technical School English Learner Education (ELE) Requirements Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) All students identified from the home language survey as speaking a different language at home are evaluated for English proficiency. However, there is no clear monitoring of the return of home surveys. Students who indicate a different language on the registration form must also be evaluated. Required Corrective Action, Timelines for Implementation, and Progress Reporting Submit, by October 19, 2007, a plan to include a review of registration forms and the return of home language surveys to identify students to be evaluated for English proficiency, and for followup to receive missing home language surveys. Include a report on the review of previous registration forms to ensure any LEP student not previously identified has been identified and tested. Indicate the results of any testing conducted as a result of this review. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 14 of 17 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 4 Waiver Procedures ELE 5 Program Placement and Structure ELE 6 Program Exit and Readiness ELE 7 Parent Involvement ELE 8 Declining Entry to a Program ELE 9 Instructional Grouping Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting The school has a teacher to provide ESL for ELE students. ELE students would participate in general education classes. There were no identified ELE students at the time of the review. Teachers have not been trained in SEI. Submit, by October 19, 2007, a schedule for professional development as indicated in ELE 15. Indicate the plan for ensuring all ELE students would have access to sheltered content instruction, as described in MGL 71A, Section 2 and 4. Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 15 of 17 ELE Criterion Number and Topic ELE 10 Parental Notification ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE 13 Follow-up Support ELE 14 Licensure Requirements Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 16 of 17 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 15 Professional Development Requirements ELE 16 Equitable Facilities ELE 17 Program Evaluation Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting One teacher/coordinator is SEI trained. The school has not provided professional development for teachers who may have LEP students in the future. Submit, by October 19, 2007, a plan that provides teachers and administrators with high quality training in: 1) second language learning and teaching 2) sheltering content instruction 3) assessment of speaking and listening, 4) teaching reading and writing to LEP students. ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Blackstone Valley Regional Vocational Technical School Coordinated Program Review Mid-cycle Report July 5, 2007 Page 17 of 17