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
September 15, 2006
Kathleen Sullivan, Executive Director
Boston Collegiate Charter School
11 Mayhew Street
Boston, MA 02125
Re: Mid-cycle Coordinated Program Review Report
Dear Ms. Sullivan:
Enclosed is the Department of Education's Mid-cycle Coordinated Program
Review Report (Mid-Cycle Report). This report contains findings based on
onsite monitoring conducted to verify the implementation and effectiveness of
corrective action approved by the Department to address findings of
noncompliance included in the Boston Collegiate Charter School Coordinated
Program Review Report issued on November 21, 2003. 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.
As you know, 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). 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 ELE self-assessment documents and, based solely on that selfassessment, is providing you in this report with comments on your ELE program
and, where necessary, corrective action to be implemented. Your school is urged
to request technical assistance in relation to any of these comments or prescribed
corrective action. To secure assistance, you may consult with your Mid-cycle
Review Chairperson. You may also consult with staff in the Department’s Office
of Language Acquisition and Achievement at 781-338-3534 and obtain additional
1
ELE guidance documents through the Department’s web site at
http://www.doe.mass.edu/ell/.
The Department will notify you of your district's next regularly scheduled
Coordinated Program Review several months before it is to occur. At this time
we anticipate the Department's next routine monitoring visit to occur sometime
during the 2009 school year, unless the Department determines that there is some
reason to schedule this visit earlier.
While the Department of Education found your district to have resolved certain
noncompliance issues, others were partially corrected or not addressed at all, 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. Where the district has failed to implement its approved
Corrective Action Plan, the Department views these findings to be serious.
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 school district
within the timelines specified. Your statement of assurance must be submitted to
the Mid-cycle Review Chairperson by September 25, 2006.
Your staff's cooperation throughout these follow-up monitoring activities is
appreciated. Should you like clarification of any part of our report, please do not
hesitate to contact the Mid-cycle Review Chairperson at 781-338-3741.
Sincerely,
Jane L. Ewing, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
2
c:
David P. Driscoll, Commissioner of Education
Susan Fortin, Boston Collegiate Charter School Board of Trustees,
Chairperson
Jenna Ogundipe, School Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
3
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
BOSTON COLLEGIATE CHARTER SCHOOL
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): May 5-9, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: March 12, 2004
Dates of Corrective Action Plan Progress Reports: June 28, 2004-September 13, 2005
Dates of this Mid-cycle Review Onsite Visit: April 25-26, 2006
Date of this Report: September 14, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 1 of 30
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Special
Education
Criteria
Originally
Cited in CPR
Report and
Monitored in
Mid-cycle
MOA 4
Disproportionality
The school reviewed the
disproportionality data and
determined that most of the
students entered the school
with active IEPs.
Disproportionality in other
areas included the
categorization of students
with multiple disabilities and
placement of students by
grade and educational
environment. Students with
multiple disabilities tended to
be students with SLD and
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 2 of 30
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
Student records indicate
that the school uses the
WIAT or another
assessment to fulfill the
required educational
Please review current practice
in providing initial evaluations
and re-evaluations and provide
training to appropriate staff,
including teachers, on how to
additional health or
emotional needs receiving
services in these areas. Thus
they were categorized as
students with multiple
disabilities.
According to the school,
student placement in
education environments by
grade level reflects conscious
and careful decision-making
by IEP Teams. BCCS
actively employs multisensory and inclusionary
teaching practices to support
all students and particularly
students on IEPs in the
general education classroom.
SE 2
Optional
Assessments
Student
records and
documentation
New issue
identified
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 3 of 30
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
assessment. No report
indicating the student’s
current progress;
communication,
memory, or attention
issues; or behavior in
class as observed by a
staff member familiar
with the student were
found in student files.
develop the appropriate content
for these reports.
The “Educational
Assessment: Part A” and
“Part B” forms are
recommended by the
Department as they
contain all of the
necessary elements to
meet the requirements of
603 CMR 28.04(2)(a) 2.
While the educational
assessment is a required
assessment for an initial
/re-evaluation, the use of
this form is not required.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 4 of 30
Please review subsequent
Educational Assessment
reports to make sure that the
Educational Assessment
reports are complete and
address all required elements.
Provide a sample of
Educational Assessment
reports from initial evaluations
and re-evaluations between
October 2006 and January
2007 to the Department by
January 22, 2007.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification

Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
Assessments such as the
WJIII or the WIAT
should be noted under
“Assessments in all areas
of the suspected
disability” and listed by
name on Evaluation
Consent Form (N1A).
Please see forms A and
B on the DOE website at
http://www.doe.mass.edu
/sped/28mr/28r1.doc).
SE 11
Parental
request for
independent
evaluation
Document
review
Not to have
been effective
The school’s only
document submission
consists of a letter to
parents requesting an
independent evaluation;
this letter did not
incorporate all aspects of
603 CMR 28.04(5) and
therefore it is not
possible to determine
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 5 of 30
Please review 603 CMR
28.04(5) and Administrative
Advisory SPED 2004-1:
Independent Educational
Evaluations (see
http://www.doe.mass.edu/sped/
advisories/04_1.html) and
revise the school’s policies and
procedures to reflect current
regulatory requirements for
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
whether the school has
sufficiently developed
policies for independent
evaluations.
Independent Evaluations.
Please submit a revised parent
letter to the Department by
November 11, 2006.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 6 of 30
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 12
Child Find
SE 18A
IEP
development
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Substantially
implemented
Document
review and
interviews
Student
records and
document
review
Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
New issue
identified
√
The administrative page
on several student IEPs
lacked the student’s
SASID number,
language of instruction,
and in some cases,
parents’ home language.
Please provide training to
appropriate special education
staff on IEP development,
including the development of
measurable goals and
appropriate objectives, and
provide evidence of the
training, including the
presenter’s name, training
agenda, and the signed
attendance sheet for the
training to the Department by
November 11, 2006.
Boston Collegiate Charter
School submitted its school
policy that all students
attending BCCS in need of
special education services are
identified and evaluated.
Additionally, several
student IEP goals lacked
specificity and were not
measurable; student
objectives were often
activities. Several IEPs
lacked specially designed
instruction or specialized
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 7 of 30
Please review 9 randomly
selected IEPs for evidence that
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
support (e.g., the reason
to develop an IEP).
student IEP goals and
objectives are measurable and
appropriate, and that IEPs
contain specially designed
instruction or appropriate
specialized support or
appropriately describe services
in the service delivery grid.
Please refer to
Department guidance on
IEP development, which
include the following:
http://www.doe.mass.edu
/sped/iep/proguide.pdf
http://www.doe.mass.edu
/sped/cspd/F2.pps
http://www.doe.mass.edu
/sped/IDEA2004/spr_me
etings/iep_guideupdt.doc
http://www.doe.mass.edu
/sped/IDEA2004/spr_me
etings/iep.html.
SE 22
IEP
implementation
and availability
Substantially
implemented
Document
review and
student records
According to student record
review, student IEPs are
appropriately implemented.
BCCS immediately informs
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 8 of 30
Additionally, please review 20
IEP administrative pages to
ensure that they are properly
filled out, including providing
the student SASID and family
language.
Please provide the results of
these reviews to the
Department by January 22,
2007.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been 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
Partially
implemented
According to
documentation provided
for this criterion, the
school has tried to
establish a school-wide
parent advisory council
on special education,
with membership offered
to all parents of children
with disabilities and
other interested parties at
BCCS and has developed
by-laws for the PAC.
Please provided documentation
that indicates that BCCS will
continue its efforts to recruit
parents and other interested
parties at BCCS to establish a
PAC, including fliers,
proposed agendas, and any
other materials advertising the
PAC and its functions, to the
Department by November 11,
2006.
parents in writing of any
delayed services.
SE 32
Special
Education
Parent
Advisory
Council
Partially
implemented
Document
review and
interviews
The school submitted a copy
of its PAC by-laws, a flier,
signed attendance sheet and
meeting agenda for
September 15, 2005.
However, the school has
an obligation to continue
to develop a functioning
PAC.
Please be aware that
parent advisory council
duties include but are not
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 9 of 30
In addition, please schedule a
meeting for parents, guardians
and any other interested parties
to discuss the rights of students
under state and federal
education law, and provide
documentation of this meeting,
to the Department by January
22, 2007.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
limited to: advising the
district on matters that
pertain to the education
and safety of students
with disabilities; meeting
regularly with school
officials to participate in
the planning,
development, and
evaluation of the school
district’s special.
Meeting notes from
September 15, 2005 do
not indicate that these
PAC responsibilities
were conveyed to the
meeting’s attendees.
In addition, the school or
district is obliged to
conduct, in cooperation
with the parent advisory
council, at least one
workshop annually on
the rights of students and
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 10 of 30
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to have
been Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
their parents and
guardians under the state
and federal special
education laws. This may
be done a variety of
ways, including by a
qualified staff member.
Again, documentation
from 2005-2006 does not
indicate that the rights of
students and parents
under the state and
federal special education
laws were part of the
September 2005
meeting.
SE 54
Professional
development
Substantially
implemented
Document
review and
interviews
The school provided copies
of staff meeting agendas and
dates of staff meetings and
professional development
days where differentiated
instruction was provided to
teachers.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 11 of 30
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
SE 6
Determination
of Transition
Services
Substantially
implemented
Document
review and
student
records
The school had been using a
summary form for transition
planning, which they have
replaced with the Department’s
version as of May 2006.
Reviewed student IEPs
contained transition-related
goals and objectives.
SE 8
IEP Team
composition
and attendance
Substantially
implemented
Student
records and
document
review
As part of its documentation,
the school submitted a blank
copy of the Department’s
Reference Sheet for IEP Team
Membership, which implies that
BCCS intends to use the form.
SE 9
Timeline for
determination
of eligibility
Substantially
implemented
Student
Records
Within 45 school working days
after receipt of parental consent,
the school determines whether a
student is eligible for special
(Refer to full
text of 20052006 CPR
requirements)
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
Interviews
Criterion
Determined
to be
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 12 of 30
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
and provision
of
documentation
to parent
Document
review
education and provides the IEP,
written notice and proposed
placement or written
explanation of finding of no
eligibility to the parent.
SE 12
Frequency of
re-evaluation
SE 13
Progress
Reports and
content
Substantially
implemented
Student
records and
interviews
According to school
documentation, parents of
students with disabilities receive
written IEP progress reports one
week after regular education
report cards are sent to parent
and provided dates by which
progress reports were sent out.
In addition, the school provided
a description of how progress
reports are developed, who is
involved (both grade-level
teachers and related service
providers), and what questions
and goals are addressed in the
reports (progress toward the
annual goals in the IEP and
whether such progress is
sufficient to enable the child to
achieve the goals by the end of
the year). Finally, the Director
of Student Support proofreads
all progress reports before they
are mailed out to families.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 13 of 30
Criterion
Number
and
Topic
Criterion
Implemented

Method(s)
of
Verification
Basis of Determination that
Criterion was Implemented
SE 14
Review and
revision of
IEPs
Substantially
implemented
Student
records and
interviews
Student records indicate that the
school conducts most annual
reviews within the anniversary
date of students’ IEPs.
SE 25B
Resolution of
disputes
Substantially
implemented
Interviews
and
document
review
The school has developed
appropriate procedures for
dispute resolution.
SE 30
Notice of
procedural
safeguards
Substantially
implemented
Interviews
and
document
review
The school’s notice of
procedural safeguard contains
all elements included in the
Massachusetts Interim Notice of
Procedural Safeguards; it issues
this notice to parents of special
education students at the
beginning of the year as well at
other required junctures in the
special education process.
SE 46
Procedures for
suspension of
students with
Partially
implemented
Document
review
(Refer to full
text of 20052006 CPR
requirements)
Criterion
Determined
to be
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
Partially
implemented
BCCS did not submit
evidence of written
procedures or training
regarding conducting a
Please provide documentation
for training of staff in
conducting a manifestation
determination and other
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 14 of 30
disabilities
more than 10
days
manifestation
determination and other
discipline procedures; the
school did not submit a
description of Interim
Alternative Education
Settings (IAES) used by
the school to ensure
access to all IEP services
and the general
curriculum; and the
school’s student
handbook for 2005-2006
did not contain
appropriate procedures for
the discipline of students
with special needs and
students with Section 504
Accommodation Plans.
See PQA’s special
education instrument at
http://www.doe.mass.edu/
pqa/review/cpr/instrument
/sped.doc for guidance in
this area.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 15 of 30
discipline procedures
applicable to students with
disabilities consistent with
IDEA 2004, including training
materials, date of session, and
signed agenda sheet.
In addition, please provide a
description of possible IAES
sites that could be used by
BCCS if necessary.
Provide written procedures for
conducting a manifestation
determination and discipline
procedures for BCCS, to the
Department by November 11,
2006.
See also MOA 10 regarding
discipline of students with
disabilities in the student
handbook.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined Not
to have been
Implemented or
Not to have
been 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
MOA 1
Identification
of LEP
students
Partially
implemented
See ELE 3.
MOA 2
Program
modifications
and support
for LEP
students
Substantially
implemented
Document
review and
interviews
See ELE 5.
MOA 6
Availability of
in-school
programs for
pregnant
students
Substantially
implemented
Document
review and
interviews
School policy permits pregnant
students to remain in regular
classes and participate in
extracurricular activities with
non-pregnant students
throughout their pregnancy.
After giving birth, school policy
states that students are permitted
Partially
implemented
See ELE 3.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 16 of 30
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Requirements
to return to the same academic
and extracurricular program as
before the leave.
The school does not require a
pregnant student to obtain the
certification of a physician that
the student is physically and
emotionally able to continue in
school.
MOA 7
Information to
be translated
into languages
other than
English
Substantially
implemented
Document
review
MOA 9
Hiring and
employment
practices of
prospective
employers of
students
Partially
implemented
Document
review
Through the home language
survey, BCCS has identified six
families whose first language is
not English. The school has
hired a translator to translate the
student handbook and other
documents (progress reports,
grade reports, etc.) as needed.
Other school documents that
have been translated were
included as documentation.
Partially
implemented
Although Boston
Collegiate says it does
not have any career,
work-study, or
apprenticeship
programs requiring a
statement prohibiting
hiring discrimination
for its student
employers, the school
submitted fliers for
another criterion
advertising internship
opportunities for
students.
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September 15, 2006
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Please develop a statement for
potential student employers
(i.e. internships) to sign that
the employer complies with all
applicable federal and state
laws prohibiting discrimination
in hiring or employment
practices; please provide this
statement to the Department by
November 11, 2006.
Please note that this
criterion also applies to
prospective employers
who participate in
career days, workstudy and
apprenticeship training
programs, as well as
those offering
cooperative work
experience.
MOA 10
Student
handbooks and
codes of
conduct
Partially
implemented
Document
review
Partially
implemented
The school’s student
handbook for 20052006 did not contain
appropriate procedures
for the discipline of
students with special
needs and students
with Section 504
Accommodation Plans
(p. 23).
Please provide a copy of the
revised student handbook or an
addendum for the handbook for
2006-2007 that includes
appropriate procedures for the
discipline of students with
special needs and students with
Section 504 Accommodation
Plans and the method by which
the school will distribute the
addendum, to the Department
by November 11, 2006.
The school’s handbook also
does not include the name(s),
office address (es), and phone
number(s) of the person(s)
designated to coordinate
compliance under Title IX and
Section 504. Please provide a
revised student handbook or an
addendum for the handbook for
2006-2007 and the method by
which the school will distribute
the addendum, to the
Department by November 11,
2006.
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September 15, 2006
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MOA 12A
Annual and
continuous
notification
concerning
nondiscrimination
and
coordinators
Partially
implemented
Document
review
Partially
implemented
The school submitted
written materials and
other media used to
publicize a school, but
none included the
notice that the school
does not discriminate
on the basis of race,
color, national origin,
sex, disability,
religion, or sexual
orientation.
Please ensure that written
materials and other forms of
media that are used to
publicize the school include the
non-discrimination notice (e.g.,
the school does not
discriminate on the basis of
race, color, national origin, sex,
disability, religion, or sexual
orientation). Provide a copy of
that assurance by November
11, 2006.
The school’s materials,
including the
handbook, do not
include the name(s),
office address (es), and
phone number(s) of the
person(s) designated to
coordinate compliance
under Title IX and
Section 504.
MOA 13
Availability of
information
and counseling
on general
curricular and
occupational/v
ocational
opportunities
Partially
implemented
Document
review
Partially
implemented
Although BCCS
provided assurance
that if a LEP student
did need counseling in
his or her language it
would be provided, but
did not identify the
mechanism by which
this would occur.
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September 15, 2006
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Please identify the means by
which the school could provide
students counseling in his or
her native language (list of
service providers, etc.), to the
Department by November 11,
2006.
MOA 14
Counseling
and counseling
materials free
from bias and
stereotypes
Partially
implemented
Document
review
See MOA 13.
MOA 15
Nondiscriminatory
administration
of
scholarships,
prizes and
awards
Substantially
implemented
Document
review
BCCS’ documentation
demonstrated that scholarships,
prizes and awards sponsored or
administered by the school are
free of restrictions based upon
race, color, sex, religion,
national origin, sexual
orientation or disability.
MOA 16
Notice to
students 16 or
over leaving
school without
a high school
diploma,
certificate of
attainment, or
certificate of
completion
Partially
implemented
Document
review
The school submitted its notice
for students who have missed
five consecutive days of school
without contact; this document
also includes a paragraph about
home/hospital programming.
Partially
implemented
See MOA 13.
Partially
implemented
The submitted
document does not
satisfy the
requirements for MOA
16: Within ten days
from a student’s
fifteenth consecutive
unexcused absence, the
school provides written
notice to students age
16 or over and their
parents or guardians
(emphasis added).
The notice must be in
English and the
family’s native
language and states
that the student and the
parent or guardian may
meet with a
representative of the
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 20 of 30
Please develop a notice that
satisfies the requirements for
the criterion MOA 16 to
provide notice to students aged
16 or older and their parents
within 10 days of a student’s
15th consecutive unexcused
absence, to the Department by
November 11, 2006.
district within ten days
from the date the
notice was sent.
At the request of the
parent or guardian, the
district may consent to
an extension of the
time for the meeting of
not longer than
fourteen days.
At the meeting the
participants discuss the
reasons that the student
is leaving school and
alternative educational
or other placements.
The student and parent
or guardian are told
that attendance is
voluntary after the
student turns 16 but are
also informed of the
student’s right to
return to school.
MOA 17A
Use of physical
restraint on
any student
enrolled in a
publicly
funded
education
program
Partially
implemented
Document
review
BCCS provided a statement
regarding its policy on physical
restraints, including that
trainings for staff were held in
November 2004 and August
2005; a copy of its student
handbook pages, which serves
as notice to parents; copies of
materials from the staff
trainings; and copies of staff
member Peter Ferrara’s
certificate from CPI to verify his
Partially
implemented
According to 603
CMR 46.03(b), a
school’s policy
regarding restraint
must provide a
description and
explanation of the
school's or program's
method of physical
restraint, a description
of the school's or
program's training
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September 15, 2006
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Please develop a complete
policy on physical restraints
that incorporates all aspects of
603 CMR 46.00, and submit
the revised policy to the
Department by November 11,
2006.
in-depth training.
requirements, reporting
requirements and
follow-up procedures,
and a procedure for
receiving and
investigating
complaints regarding
restraint practices.
In addition, a school’s
principal or director
must also ensure that,
for employees hired
after the school year
begins, they receive
training within a
month of their
employment.
Finally, 603 CMR
46.06 describes
reporting requirements,
which includes the
following:
(1) Circumstances
under which a physical
restraint must be
reported. Program staff
shall report the use of
physical restraint as
specified in 603 CMR
46.06(2) after
administration of a
physical restraint that
results in any injury to
a student or staff
member, or any
physical restraint of a
duration longer than
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 22 of 30
five minutes
(2) Informing school
administration. The
program staff member
who administered the
restraint shall verbally
inform the program
administration of the
restraint as soon as
possible, and by
written report no later
than the next school
working day. The
written report shall be
provided to the
principal or director of
the program or his/her
designee, except that
the principal or
director shall prepare
the report if the
principal or director
has administered the
restraint. The principal
or director or his/her
designee shall maintain
an on-going record of
all reported instances
of physical restraint,
which shall be made
available for review by
the Department of
Education, upon
request.
The on-going record is
the restraint log, which
schools are required to
maintain in case there
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
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is a restraint.
MOA 21
Staff training
regarding civil
rights
responsibilities
Substantially
implemented
Document
review and
staff
interviews
The school provides an annual
training on civil rights in August
just before school opens;
however, the school is also
committed to tolerance and
diversity, so other training
opportunities are provided
throughout the year.
Documentation included
materials from the trainings,
information about harassment
and discrimination from the
Office of Civil Rights;
information about the school’s
diversity council, and readings
about diversity from a
professional development day.
MOA 24
Curriculum
review
Substantially
implemented
Document
review
According to materials
submitted for the mid-cycle,
BCCS schedules time during a
professional development day
every year for department chairs
to meet with staff to review
instructional and education
materials for bias and
discrimination. Findings are
shared with an inquiry group.
MOA 25
Institutional
self-evaluation
Partially
implemented
Document
review
Partially
implemented
The school evaluates
its program annually
with a variety of
surveys, including a
diversity survey to
staff (for professional
development); a likert-
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
Page 24 of 30
Please develop a plan by which
the school evaluates all aspects
of its 5-12 program to ensure
that all students, regardless of
race, color, sex, religion,
national origin, limited English
proficiency, sexual orientation,
scaled satisfaction
survey to families that
asks about
extracurricular and
sports programs; and a
family questionnaire
that asks about the
student’s experience at
the school.
Although the
combined surveys
would provide
appropriate
information for the
school to evaluate its
student services, it may
not provide data on
student access.
disability, or housing status,
have equal access to all
programs, including athletics
and other extracurricular
activities and makes such
changes as are indicated by the
evaluation.
Please provide this
documentation to the
Department by November 11,
2006.
Other
Regulated
Programs
Addressed
During this
Mid-cycle
Review
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined Not
to have been
Implemented or
Not to have
been Effective
Or
New Issues
Identified
Basis of
Determination that
Implementation of
Corrective Action
was Incomplete or
Ineffective
Or
Basis of Finding of
New Noncompliance
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
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Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Requirements

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September 15, 2006
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BOSTON COLLEGIATE CHARTER SCHOOL
English Learner Education (ELE) Requirements
Mid-Cycle Review Comments and Corrective Action Based on the Department’s Review Of Local Self-Assessments
(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
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
According to the school’s self-assessment, all students take
MCAS. During 2005-2006, the school had a MELA-O trained
administrator, Nadia Cyprien. Ms. Cyprien was to complete
training for 5th and 6th grade level teams in MELA-O by April
24, 2006.
Please provide the qualifications of persons implementing assessment activities
and evidence of training for all MELA-O trained administrators currently
working for the school by November 11, 2006.
ELE 2
MCAS
Participation
According to the school’s self-assessment, all students take
MCAS.
No corrective action necessary.
ELE 3
Initial
Identification
All incoming students are given a home language survey at
the time of registration at BCCS. According to the selfassessment, students who indicate a first language other than
English have been assessed in reading and writing using the
LAS R/W. An ESL-certified teacher employed by the school
administers the assessment.
Students must be assessed in all four modalities, e.g., speaking, listening, reading
and writing. While the Department does not prescribe which assessments districts
must use, please refer to guidance at http://www.ncela.gwu.edu/expert/faq/.
The school’s summary of services for LEP students includes a
brief section on students whose parents opt out of the school’s
ELL program. However, this statement does not include a
description of the process by which parents are offered the
Please provide a description of BCCS’ waiver implementation practices and a
copy of the local waiver form. This is required whether or not the school has
identified LEP students.
ELE 1
Annual
Assessment
ELE 4
Waiver
Procedures
Please provide a revised identification process for LEP students that includes
speaking and writing, to the Department by November 11, 2006.
BOSTON COLLEGIATE CHARTER SCHOOL Coordinated Program Review Mid-cycle Report
September 15, 2006
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ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
opportunity to waive the requirements of G.L. c. 71A.
For guidance, see http://www.doe.mass.edu/ell/news03/waiverfrm_drft.pdf.
Please note that there are different requirements for students over and under 10
years of age.
ELE 5
Program
Placement and
Structure
The school submitted a program description and a sample
ELL student schedule, which includes English Language
Development (ELD) based on objectives from the English
Language Arts Frameworks and the English Language
Performance Benchmarks and Outcomes (ELPBO),
instruction in core content in sheltered classrooms, and access
to specialty classes the same as other students.
No corrective action required.
ELE 6
Program Exit
and Readiness
The school submitted a brief description of how students who
exit the ELL program will be monitored, but does not provide
a description of what criteria will be used to decide if students
should be exited.
A school or district cannot designate an LEP student as Formerly Limited
English Proficient (FLEP), until s/he is deemed English proficient, can
participate meaningfully in all aspects of the general education program without
the use of adapted or simplified English materials, and performs at “proficient”
levels on state-mandated assessments. Schools and districts are expected to
develop multiple exit criteria to determine whether a student can be re-designated
as FLEP.
For guidance, see http://www.doe.mass.edu/ell/sei/MEPA_guidelines.doc.
Please provide a description of the school’s ELL program exit criteria, including
who will participate and how parents will be informed of the change in
designation, to the Department by November 11, 2006.
ELE 7
Parent
Involvement
ELE 8
Declining Entry
to a Program
The school submitted a description of how they involve
parents, including monthly family workshops, parent-teacher
conferences, a yearly Open House, and various opportunities
for involvement at the grade level.
According to the school’s submission, all opted-out students
would receive classroom-based instruction from teachers who
are qualified to teach LEP/ELL students. The school plans to
monitor the progress of an opted-out student following the
No corrective action required.
Please include the district’s sample request form, or other means for documenting
the parents’ wish to “opt-out” of an ELE program, along with any forms used to
monitor student progress to the Department by November 11, 2006.
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September 15, 2006
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ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
issuance of each report card and provide academic or
language remediation without delay.
Please note that schools and districts are required to develop such procedures
whether or not they have currently identified LEP students enrolled.
ELE 9
Instructional
Grouping
The school has proposed an ELD structure where students are
grouped by Beginning/Early Intermediate, Intermediate, and
Transitioning.
No corrective action required.
ELE 10
Parental
Notification
According to BCCS’ documentation and self-assessment, the
school has not yet designed a sample notification letter to
parents.
Please develop a parent notification letter that includes the following elements.
This letter must be sent to families upon the placement of the student in any ELE
program and annually thereafter, a notice is mailed to the parents or guardians
written in the primary/home language, as well as in English. The letter must
inform parents of:
(a) the reasons for identification of the student as Limited English
Proficient (LEP);
(b) the child’s level of English proficiency;
(c) program placement and/or the method of instruction used in the
program;
(d) how the program will meet the educational strengths and needs
of the student;
(e) how the program will specifically help the child learn English;
(f) the specific exit requirements; and
(g) the parents’ right to apply for a waiver (see ELE 4), or to decline
to enroll their child in the program (see ELE 8).
Please provide a copy to the Department by November 11, 2006.
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September 15, 2006
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ELE Criterion
Number
and
Topic
ELE 11
Equal Access to
Academic
Programs and
Services
ELE 12
Equal Access to
Nonacademic
and Extracurricular
Programs
ELE 13
Follow-up
Support
ELE 14
Licensure and
Fluency
Requirements
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Although the school has provided its
assurance that any LEP student would
have the same access to the full range
of academic opportunities and supports
offered to non-LEP students, it is not
clear how LEP students would receive
academic support services, such as
guidance and counseling, in the
student’s primary language.
Please develop or identify a means by which the school would offer 1) academic
or guidance counseling in the student’s primary language and 2) social or
therapeutic counseling in the student’s native language, to the Department by
November 11, 2006.
Please see ELE 11.
Please see ELE 11.
The school’s monitoring procedure includes monitoring by the
school’s LAT and ILT for two years, triggered by each report
card. Additional language support, which would include
individual student success plans (ISSP), would be provided to
the student as needed. According to the submission, BCCS
may re-classify students who fail because of language
proficiency as ELL.
No corrective action necessary.
According to the school, one ESL-certified teacher is
employed at the school.
Please provide a copy of her ESL teaching license to the Department by
November 11, 2006.
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September 15, 2006
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ELE Criterion
Number
and
Topic
ELE 15
Professional
Development
Requirements
Comments Based on the Department’s Review of Local
ELE Self-Assessment
The school submitted a statement that it will train all 5th and
6th grade level teachers to administer the MELA-O. In
addition, there is an ESL-certified staff member at BCCS.
With the exception of Category 3, staff members have not
been trained in the all four Categories (1, 2 and 4).
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
The school noted that much of the Department’s ELL professional development
opportunities have been for trainers, e.g., for staff members with ESL or ELL
certification. This training is meant to enable a staff member to train other school
personnel on-site in the required elements of English Language Education and to
ensure the progress of LEP students in developing oral comprehension, speaking,
reading, and writing of English, and in meeting academic standards.
For guidance, see http://www.doe.mass.edu/ell/profdev.html. You may also
contact Dr. Judy Barcelo in the Office of Language Acquisition at (781) 3383557.
Please provide the following to the Department by November 11, 2006:
1) the school’s 2006-2007 Professional Development Plan;
2) a list of topics covered at recent professional development opportunities
and roster of attendees outside the school;
3) a list of topics covered at recent professional development opportunities
and roster of attendees within the school.
ELE 16
Equitable
Facilities (To be reviewed
during next
CPR visit)
ELE 17
DOE Data
Submission
Requirements
and Program
Evaluation
All students have equal access to all facilities and are not
segregated by language or disability.
No corrective action necessary.
The school has no students identified as LEP.
Please note that requirements under this criterion include a periodic evaluation of
the effectiveness of the school’s programming.
1. The school or district reports annually to the Department, the
following student information:
(a) the schools in which LEP students are enrolled;
(b) the grade levels of the students;
(c) the primary languages of each LEP student; and
(d) the types of English learner programs in which the district has
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September 15, 2006
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ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
enrolled LEP students, including sheltered English immersion,
two-way bilingual, transitional bilingual education (for students
with waivers only), or students whose parents have declined
services.
2. The district conducts periodic evaluations of the effectiveness of its
ELE program. The students are showing English language
development and the ability to participate meaningfully in the
educational program. Where the district documents that the program is
not effective, it takes steps to make appropriate program adjustments
or changes that are responsive to the outcomes of the program
evaluation.
Please provide a description of how the school would evaluate its ELE
programming for effectiveness to the Department by November 11, 2006.
ELE 18 Records
of LEP
Students(To be reviewed
during next
CPR visit.)
The school provided copies of student assessments for all
students enrolled at the school who indicated a first language
other than English on their Home Language Surveys. All of
the students assessed were found to be fully English
proficient.
For the next on-site review, BCCS should ensure that all LEP student records
include the following:
(a) home language survey;
(b) results of identification and proficiency tests and
evaluations, including MELA-O, MEPA, MCAS, or
other tests chosen by the Board of Education and the
district;
(c) information about students’ previous school experiences;
(d) copies of parent notification letters, progress reports and
report cards (in the native language, if necessary);
(e) evidence of follow-up monitoring (if applicable);
(f) documentation of a parent’s consent to “opt-out” of
English learner education; and
(g) Individual Student Success Plans for students who have
failed MCAS, if the district is required to complete plans
for non-LEP students.
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