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
August 18, 2006
Michael Contompasis
Interim Superintendent
Boston Public Schools
26 Court Street
Boston, MA 02186
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Contompasis:
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 Public
Schools Coordinated Program Review Report issued on October 28, 2002.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.
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,
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 10,
2006.
Your staff's cooperation throughout these follow-up monitoring activities is appreciated.
1
Should you like clarification of any part of our report, please do not hesitate to contact
the Mid-cycle Review Chairperson at 781-338-3733.
Sincerely,
Nathan Lemmon, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Elizabeth Reilinger, Chairperson, Boston School Committee
Carolyn Riley, Unified Student Services Director, Boston Public Schools
Patricia Crowley, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Mid-cycle Cover Letter 2006.doc
Rev. 6/5/06
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Boston Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): March 11 – 27, 2002
Date of Coordinated Program Review Corrective Action Plan Approval: April 4, 2002
Dates of Corrective Action Plan Progress Reports: December 20, 2002, July 30, 2003, March 1, 2004, January 13, 2006
Dates of this Mid-cycle Review Onsite Visit: May 1 – 5, 2006
Date of this Report: August 17, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 1 of 44
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
Corrective
Action Not
Effective
Student records and
interviews indicate that
the district is still not:
1) Consistently assessing
in all areas of suspected
disability;
2) Not assessing in all
areas consented to;
3) Assessing in some
areas w/o consent;
4) Not specifying the
types of assessments.
Conduct training for ETF staff
and others responsible for
deciding which assessments
are appropriate. Center training
on the requirement to:
1) Assess in all areas
consented to; and
2) Assess only with
parental consent when
determining eligibility
for special education
services; and
3) Add specificity to the
types of assessments
listed (name them) on
Special
Education
Criteria
Originally Cited
in CPR Report
and Monitored
in Mid-cycle
SE 2
Required and
Optional
Assessment
Student
Records and
Interviews
766 and “Core”
evaluation language still
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 2 of 44
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
prevalent
the Consent to
Evaluate form.
Evidence of this training
including an agenda and
attendance sheets should be
provided by September 30,
2006.
Document the results of the
district’s periodic internal
monitoring for compliance
with this standard. Please
develop a checklist with the
following items:
1) Assessments in all
areas of suspected
disabilities?
2) Assessments
conducted consistent
with signed consent?
Please select a sample of
student records for recently
conducted evaluations (posttraining) from each level:
Elementary, Middle and High
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 3 of 44
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
School and across all clusters
(30 total) and report the rate of
compliance by building. The
results should indicate the date
the review was conducted, the
number of records reviewed
and a description of additional
steps taken where noncompliance was noted. Identify
the person(s) responsible for
conducting the review and the
person(s) responsible for
follow-up activities. Report to
the Department by December
29, 2006.
SE 3
SE 4
Reports of
Assessment
Results
Reserved
Student
Records and
Staff
Interviews
Corrective
Action Not
Effective
Assessment reports do not
address diagnostic
impression and specific
recommendations
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 4 of 44
Provide a detailed memo by
September 30, 2006 (District
Policy Statement) to all
persons in the district
responsible for assessing and
developing reports of
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 results to provide
clear and unambiguous
language that assessment
reports must contain diagnostic
impressions and specific
recommendations for the IEP
Team to consider. Specific
recommendations must be in
the report and not left entirely
to “be discussed at the Team
meeting.” Provide the
Department with evidence of
this memo by September 30,
2006.
Conduct a random, districtwide review of assessment
reports that were written
following the dissemination of
the memo to check that
assessment repots have
complete information. Report
the results by building and by
cluster (rates of compliance at
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 5 of 44
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
all levels and clusters – 30
records total) and report to the
Department the results by
December 29, 2006, as well as
a description of the specific
additional steps taken where
non-compliance was noted and
the person(s) responsible.
SE 5
Participation in
General State
and DistrictWide
Assessment
Programs
Student
Records and
Staff
Interviews
New Issue
Identified
Alternate assessments do
not list standards and
strands to be assessed.
Part of the requirement
for an MCAS
performance appeal is to
clearly define what the
student will need to
demonstrate in terms of
knowledge and skills for
each subject.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 6 of 44
Provide to the Department by
September 30, 2006, a written
standard protocol for ETFs and
other special education staff to
follow when guiding students
and parents through the
alternate assessment process.
Protocol needs to include a
rubric to include:
1) Required Strands; and
2) Required Forms.
Please see the web for details.
http://www.doe.mass.edu/mcas
/alt/06scoreguide.pdf.
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
Conduct self-monitoring by
checking all applicable files at
the secondary level for
compliance. Report to the
Department of Education the
rates of compliance by building
and by cluster by December
29, 2006. The results should
indicate the date conducted, the
number of records reviewed, a
description of additional steps
taken where non-compliance
was noted and the person(s)
responsible for ensuring
implementation.
SE 7
Age of Majority
Notices
Student
Records and
Staff
Interviews
Corrective
Action Not
Effective
Student records and
interviews indicate that
the Age of Majority
notices were not placed in
student files and not
consistently provided to
students a year prior to
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 7 of 44
Provide the Department with a
copy of a memo to all ETF
staff at Hyde Park High School
containing the requirements for
notifying parents when the
student is approaching the Age
of Majority - one year prior to
the student reaching age
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
their 18th birthday at Hyde
Park High School.
eighteen. Document with the
Department that this review
has occurred by September
30, 2006.
Also, create a database for
ETFs with the date each
student receiving special
education services turns 17
years of age and provide that
list to the person responsible
for sending Age of Majority
Notices and copy the
Department by December 29,
2006.
Conduct a self-monitoring
activity to check all applicable
students in the database for
evidence of issuance of the
Age of Majority notice and
placement of the notice in the
student record. Report the rate
of compliance by building, any
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 8 of 44
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
additional steps taken to
address non-compliance and
the person(s) responsible for
follow-up to the Department by
December 29, 2006.
SE 9
Eligibility
Timelines
Student
Records and
Staff
Interviews
Corrective
Action
Determined
Not to Have
Been
Effective
Student records and
interviews indicate that
evaluations are not
consistently completed
with/in the 30-day
timeline and meetings are
not held within the 45-day
timeline. This finding
occurs across all levels
and clusters in the district.
Conduct a review of timeline
completion in each building
and each cluster to include the
following activities;
1. Conduct a survey with each
building based and citywide
ETF to determine the factors
for timeline violation; and
2. Design interventions in
response to all non-compliance
found and identify the
person(s) responsible.
3. Report to the Department on
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 9 of 44
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
these timeline completion
activities by December 29,
2006.
Conduct a second internal
monitoring by reviewing a
sample of student records for
timeline completion. The
sample should be drawn from
each level and across clusters.
Report the rate of compliance
by building and by cluster.
Identify any additional
corrective actions taken and the
person(s) responsible for
follow-up to the Department by
June 30, 2007.
SE 10
End of School
Year
Evaluations
Implemented
and Effective
Student
Records and
Interviews
Based on the final set of
progress reports from the
district and based on positive
responses in interviews (as well
as correct documentation in
sample student records) the
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 10 of 44
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
Corrective
This finding was observed
Provide documentation to the
district has met its obligation in
this area.
SE 15
Child Find
Implemented
and Effective
Student
Records and
Interviews
The district showed through
documentation and interviews
that its Child Find outreach is
annual and continuous with
those groups from which
promotion or transfer of
students in need of special
education may be expected or
would include students in need
of special education.
SE 17
Initiation of
Services at Age
Three
Implemented
and Effective
Student
Records and
Interviews
The district has demonstrated
that it implements procedures to
ensure the effective transition of
young children with disabilities
from Early Intervention
Programs through participation
in transition planning
conferences.
SE 18A
Student
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 11 of 44
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
IEP
Development
and Content
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s)
of
Verification

Records and
Interviews
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

Action
Determined
Not to Have
Been
Effective
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
across levels and clusters
in the school district. IEPs
do not include a
description of specially
designed instruction to
meet the needs of the
individual student.
Department that training has
been conducted with all ETFs
on the need for specific content
in IEPs by September 30,
2006. Provide the Department
with evidence that training
occurred on the following
topics and include names and
signatures of participants,
copies of materials used in the
training and the date. Topics
must include:
1) The description of
specially designed
instruction in each plan
must be student
specific and within the
context of the
individual students’
learning difficulties.
2) Goals need to be
measurable.
(Massachusetts
Regulations still
Benchmarks included
criteria that were not
measurable such as:
“given appropriate
instruction, given optimal
conductions, given
teacher support and
prompts, given the proper
learning environment,”
etc.) In some cases,
evaluation data is not
sufficient to guide the
development of
measurable goals on the
student’s IEP. Annual
reviews should be data
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 12 of 44
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
driven and many of the
district’s IEPs contain no
actual data to help with
this process. For example
- “Billie did very well this
quarter,” provides no
information (objective
criteria) that would
convey what the student
has learned or not learned
or that would be useful in
planning a quality IEP.
Vision statements do not
contain all required
elements.
IEPs that describe a need
for a one-on-one aide and
paraprofessional support
do not include this
information in the service
delivery grid with the
frequency and duration of
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 13 of 44
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
require objectives).
IEPs should state what
the goal is and what
the teacher will do in
terms of instruction
and assessment. Plans
that also include how
often the assessments
will occur and how
often the assessments
will be recorded are
helpful.
3) Vision statements must
contain all required
elements
4) Data used to develop
goals on each annual
IEP should not be
limited to data taken
from three-year reevaluation
assessments, but
rather, should come
from a variety of
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
the service.
objective data sources
on an annual basis.
5) IEPs that describe the
need for one-to-one
paraprofessional
support need to have
this information added
to the service delivery
grid for clarification of
the frequency and
duration of a
specifically defined
service.
Again, this is an area where the
school district must be able to
demonstrate effective selfmonitoring. Conduct a sample
review of records at each
school site and check for the
above listed criterion. Report
the results by building and by
cluster. Describe the additional
activities to be taken to address
continuing noncompliance and
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 14 of 44
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
identify the staff responsible
for carrying these activities
out. Submit the report to the
Department by December 29,
2006.
SE 18B
Determination
of placement
Provision of
IEP to Parent
Student
Records and
Interviews
Corrective
Action
Determined
Not to Have
Been
Effective
Student records and
interviews indicate that
the district does not
consistently issue student
placement at the same
time as the IEP.
Interviews indicate that
district personnel are
aware of the requirement.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 15 of 44
The district will develop a
system of oversight to follow,
particularly in schools where
this continues to be a problem
by September 29, 2006. The
system of oversight should
include;
1) Conduct a review
across levels
(elementary, middle
and high schools) and
clusters to check that
IEP proposals made by
the Boston Public
Schools contain
placement proposals.
2) Report the rate of
compliance by
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
building and by
cluster. Describe the
additional activities to
be taken to address
continuing
noncompliance and
identify the staff
responsible for
carrying these
activities out. Submit
the report to the
Department by
December 29, 2006.
SE 20
Least
Restrictive
Program
Selected
Student
Records and
Interviews
Corrective
Action
Determined
Not to Have
Been
Effective
Student non-participation
statements do not always
contain clear justification
for the Team’s decision
that the student must be
removed from the regular
education environment.
(One example stated:
Student has a learning
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 16 of 44
Provide to the Department by
September 30, 2006, evidence
of training to all ETF staff on:
1) How to appropriately
fill out this section of
the IEP proposal and;
2) The importance of
documenting the
decision making
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
disability that requires
special education
services.)
process around the
question of removal
from the general
education
environment.
It would be appropriate to
incorporate training on this
topic with the district’s training
under SE 18A on IEP content.
Statements must also
include why the removal
is considered critical to
the student’s program and
the basis for its
conclusion that education
of the student in a less
restrictive environment,
with the use of
supplementary aids and
services, could not be
achieved satisfactorily.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 17 of 44
Conduct self-monitoring to
check for compliance with this
criterion by conducting a
random review of student
records across levels and
clusters (approximately 30
files) during the first half of the
2006-2007 school year. Report
the rate of compliance by
building and by cluster.
Describe the additional
activities to be taken to address
continuing noncompliance and
identify the staff responsible
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
for carrying these activities
out. Submit the report to the
Department by December 29,
2006.
SE 21
School
Day/School
Year
Requirements
SE 22
IEP
Implementation
and Availability
Implemented
and Effective
Staff
Interviews
and Student
Records
Student
Records and
Interviews
The Department found that IEP
Teams in the Boston Public
Schools routinely consider the
need for an educational program
that is less than or more than the
regular school day or school
year and indicates on the IEP
why the shorter or longer
program is necessary.
Corrective
Action
Determined
to Not Have
Been
Effective
Interviews and student
records indicate that the
school does not
consistently and
immediately inform
parents in writing of any
delayed services, reasons
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 18 of 44
Provide a memo to all ETF
staff on the requirement to
inform parents, with notice,
whenever the district is unable
to fully implement the
programs and services
described in agreed-to IEPs.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 23
Confidentiality
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

Implemented
Staff
Interviews,
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
for delay, actions that the
school district is taking to
address a lack of space or
personnel and offer
alternative methods to
meet the goals on the
accepted IEP.
Provide the Department with a
copy of this memo and a list of
the names the memo was sent
to by September 30, 2006.
Request a list from each school
detailing any special education
staff shortages, then conduct a
random review of the student
records from which those
shortages occurred to check if
notice was sent in each case.
Report the results by building
and by cluster. Please describe
all additional actions taken by
the school district to remedy
cases of non-compliance found
and identify the staff
responsible for carrying these
activities out. Submit the report
to the Department by
December 29, 2006.
The district demonstrated
though interviews, documents
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 19 of 44
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
of Personally
Identifiable
Information
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
Documents
and Student
Records
and student records that
confidentiality of personally
identifiable information is
stressed. Measures such as
providing district staff training
on the topic have been
documented with the
Department in this Mid-cycle
Review.

SE 24
Notice
Requirements
SE 25
Parental
Consent
Student
Records and
Interviews
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
Corrective
Action
Determined
to Not Have
Been
Effective
See SE 22
See the Requirements for SE
22
Corrective
Action
Determined
to Not Have
Been
Student records indicate
that the district does not
always obtain parent
consent before conducting
re-evaluations. *The
Revise the district’s current
practice in order to generate
from the district’s database, a
list of those students for whom
ETFs will need to obtain
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 20 of 44
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

Effective
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
Department notes that
interviews indicate part of
this problem could be
caused by having
assessors working from a
list of student who are due
for their 3 year reevaluations rather than
working from a list of
parents who have
consented to the testing.
consent for 3 year reevaluations and another list
when consent to evaluate has
been received and those
conducting the assessments
schedule the testing. Develop a
procedure for ETFs around this
process. The set of procedures
should include how to
document the multiple attempts
and variety of methods for
contacting parents to obtain
consent. Submit a copy of the
lists and the procedure to the
Department by September 29,
2006. Distribute the written
procedures to all pertinent staff
and document that this has
occurred by September 29,
2006. Include the names of
persons notified.
Some of the student
records did not contain
documentation of the
district’s multiple
attempts or use of a
variety of methods for
contacting parents to
obtain consent.
Conduct internal monitoring
using the district’s database to
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 21 of 44
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
identify what students in each
building, at each level by
cluster have Consent to
Evaluate forms without
responses, and then provide
oversight to pertinent staff to
ensure that follow-up takes
place and is documented.
Report the results to the
Department by building and by
cluster and identify the staff
responsible for oversight by
December 29, 2006.
Conduct a review of records in
the district (all levels and
clusters) to check that
documentation procedures are
followed in this regard. Report
the rate of compliance by
building and by cluster.
Describe any additional steps
taken to correct noncompliance and identify the
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 22 of 44
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
staff responsible for follow-up
by June 30, 2007.
SE 25A
Sending a Copy
of Notice to
Special
Education
Appeals
Student
Records and
Interviews
Corrective
Action
Determined
to Not Have
Been
Effective
Interviews and
documentation indicate
that the district does not
always send notice to the
BSEA within 5 days of
the receipt of a rejected or
partially rejected IEP
plan.
Develop a tracking system for
internal monitoring to ensure
that notice to the BSEA is
issued and documented for all
partially and fully rejected IEP
plans. Report to the
Department how the tracking
system will work and identify
the staff responsible for its
implementation by September
30, 2006.
Conduct internal monitoring
using the district’s database to
identify what students in each
building, at each level by
cluster have rejected IEPs to
ensure notice has been sent to
the BSEA, and then provide
oversight to pertinent staff to
ensure that follow-up takes
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 23 of 44
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
place and is documented.
Report the rates of compliance
by building and by cluster and
identify the staff responsible
for oversight by December 30,
2006.
Conduct a self-monitoring
activity to include a random
review of student records from
all levels and clusters (30
records) and report to the
Department the results by June
30, 2007. In addition, please
provide the Department with
details of any action taken by
the district if non-compliance
was found during selfmonitoring activities.
SE 26
Implemented
Staff
The district makes reasonable
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 24 of 44
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
Interviews
and Student
Records
efforts to obtain parental
participation in Team meeting
discussions and decisions
including notification in writing
to the parents early enough to
ensure that they have an
opportunity to attend.
Communications with parents in
the district are in simple and
commonly understood words
and are in both English and the
primary language of the home,
if such language is other than
English.
The district assists in identifying
a person willing to serve as an
educational surrogate parent
when a student is without
parental representation and
works to facilitate the
assignment by the Department
of Education.

Parental
Participation in
Team Meetings
SE 29
Communication
English and
Primary
Language of the
Home
Implemented
Staff
Interviews
and Student
Records
SE 31 State and
District
Responsibility
for Educational
Surrogate
Parents
Implemented
Staff
Interviews,
Student
Records and
Documents
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 Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 25 of 44
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 32 Parent
Advisory
Council for
Special
Education
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s)
of
Verification

Student
Records and
Interviews
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

Corrective
Action
Determined
to Not Have
Been
Effective
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
Although the district
notes some additional
staff persons have been
hired to increase the
communication with
parents of students with
disabilities, the Parent
Advisory Council for
Special Education has
been inactive for over a
year.
Please provide the Department
with an up-date of the Parent
Advisory Council’s activities
in the Boston Public Schools
for the 2006-2007 school year
and submit the results by
December 29, 2006. Please
include:
1) Subjects pertaining to
the education and
safety of students with
disabilities that the
Council has advised
the district on.
2) Dates when the
Council has met during
the 2006-2007 school.
Describe the kind of
assistance the council
has received from the
school committee
during the school year.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 26 of 44
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

SE 33
Involvement in
General
Curriculum
Implemented
Staff
Interviews
and Student
Records
District personnel understand
the connection between the
Massachusetts Curriculum
Frameworks and the
expectations of the state for
student performance as well as
understanding the rights of
students with disabilities to be
full participants in the general
curriculum.
SE 37
Procedures for
Approved and
Unapproved
Out-of-District
Placements
Implemented
Staff
Interviews
and Student
Records
Implemented
Staff
The district indicates that no
students with IEPs were
enrolled in unapproved schools
at the time of the Mid-cycle
Review. The Boston Public
Schools monitors the provision
of services to and the programs
of individual students placed in
public and private out-of-district
programs.
The district implements its
responsibilities to students in
SE 38
Educational
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 Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 27 of 44
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
Interviews
and Student
Records
institutional settings by acting
on requests for evaluation,
issuing proposed IEPs in a
timely manner, and providing
special education and/or related
services in accordance with
state and federal law.
Staff
Interviews
and Student
Records
Ages of children in the same
instructional groupings do not
differ by more than 48 months
unless approved by a
Commissioner’s waiver when
justified.
Staff
Interviews
and Student
Records
The district follows the general
requirements for young children
in that such programs are
developmentally appropriate
and specially designed for
children three and four years of
age. The District provides
inclusionary programs as well
as substantially separate

Services in
Institutional
Settings
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
Implemented
SE 41
Age Span
Requirements
SE 42
Programs for
Young Children
Implemented
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 28 of 44
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
New Issue
Identified
Although the district does
provide behavioral
programming within the
context of behaviorally
based classrooms, the
IEPs of students with
identified needs in the
area of behavior
management often did not
include specific strategies,
interventions etc.
Please provide training to all
ETF staff on how to include
complete and accurate
descriptions of behavioral
interventions in IEP proposals.
It may be useful to incorporate
the knowledge of those staff
persons working in
behaviorally based programs to
formally lay out the details of
behaviorally based strategies,
goals and objectives, classroom
accommodations, related
psychological services etc.
Provide evidence of training in
this are to the Department by
September 30, 2006.
programs when appropriate.
SE 43
Behavioral
Interventions
Student
Records and
Interviews
Even if a student is placed
in a behaviorally focused
classroom, (one where
interventions, strategies,
record keeping etc. are
“built into the system,”)
the student’s IEP must
still describe the needed
interventions with a level
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 29 of 44
Conduct a random review of
student records (behaviorally
based classrooms) across the
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 44
Recording
Suspensions
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

Partial
Student
Records and
Interviews
The district has a procedure to
record the number and duration
of suspensions, including any
suspensions from any part of the
students IEP program (including
transportation.)
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Corrective
Action
Determined
Not to have
been
Effective
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
of detail sufficient to
stand on its own if the
student were to move to
another district or state.
levels and clusters (30 files) to
check for compliance with this
criterion and report the results
to the Department by
December 29, 2006. Include a
description of an corrective
action taken by the district to
remedy non-compliance
discovered through the selfmonitoring process.
The district continues to
not appropriately count
the in-house suspensions
of students with
disabilities.
The district must notify all
building principals of the
requirement to count in-house
suspensions of students with
disabilities and provide
evidence of this to the
Department by September 30,
2006.
The district must conduct a
review of all buildings by
cluster to ensure that in-house
suspensions of students with
disabilities are being
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 30 of 44
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
appropriately reported. Indicate
the person(s) responsible for
conducting this review, the
rates of compliance and any
additional corrective actions
taken to the Department by
December 29, 2006.
SE 45
Suspension
Procedures Up
to Ten Days
and After 10
Days
Partial
Student
Records and
Interviews
The district has written
procedures for suspension up to
10 days and after 10 days that
meet the general requirements
of the criterion.
SE 47
Procedural
Requirements
Children Not
Yet Found
Eligible
Implemented
Student
Records and
Interviews
The district has written
procedures for students not yet
eligible for Special Education
that meet the requirements of
the criterion.
New Issue
Identified
District documents,
student records and
interviews indicate that
Manifestation
Determinations were not
conducted for some
students with IEPs with
over 10 days of
suspension.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 31 of 44
See the required corrective
action order for SE 46.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 49
Related
Services
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
Corrective
Action
Determined
Not to Have
Been
Effective
Although interviews
indicate that counseling
services are now provided
to some students without
a direct recommendation
from a clinical
psychologist, psychiatrist
or psychiatric nurse, IEP
plans still do not
determine the type
(individual vs. small
group), duration or
frequency of counseling
services.
Provide training to ETF staff
on the importance to include
details as to the type, duration
and frequency of counseling
services on IEP plans from the
district. Report to the
Department by September 30,
2006 the names, dates,
signatures and training
materials from the training on
this topic.
Student records also
indicate that in some
cases, “guardian” is listed
as the service provider for
counseling services.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 32 of 44
Please provide a memo to all
ETF staff indicating that
parents or guardians cannot be
the provider of services which
the district is responsible to
provide. Provide to the
Department by September 30,
2006 a copy of the memo.
Conduct a review of student
records (select only records of
students receiving counseling
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
services) across clusters and
levels (elementary, middle and
high school) approximately 30
files and check to see if
counseling services are
detailed on the service delivery
grid. Report to the Department
the results of the review by
December 29, 2006 and
include a description of any
action(s) taken when
continuing non-compliance is
found and identify the
person(s) responsible.
SE 55
Special
Education
Facilities and
Classrooms
Implemented
and Effective
subject to onsite inspection.
Interviews
Previous non-compliance in this
area was corrected.
SE 56
Special
Education
Implemented
and Effective
Student
Records and
Interviews
The district measures the
success of programs based on
students’ local and statewide
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 33 of 44
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

Programs
Evaluated
SE 57
Child Count
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
Corrective
Action
Determined
Not to Have
Been
Effective
A number of the current
IEP plans reviewed by the
onsite team were
unsigned.
The district’s child count
should represent students
with current, accepted
IEPs who are receiving
special education and/or
related services by the
district or an out-ofdistrict provider through a
contract with the district.
Please conduct the following
activities and provide
documentation to the
Department by September 30,
2006:
1) Use the district’s
database to identify
where there has been a
lack of response to any
IEP proposal beyond
30 days, organize by
cluster, level and
building and copy for
submission to the
Department
2) Develop a standard
follow-up procedure
for all ETF staff to use
that documents (in the
student record) the
assessment results, drop out
rates and graduation rates for
Special Education students.
Student
Records and
Interviews
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 34 of 44
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
multiple attempts and
variety of methods to
notify each parent and
notify the BSEA after
other steps have failed,
(provide copy of
procedure to the
Department).
Using the district’s database,
conduct district-wide internal
monitoring for each building
site and check for rates of
compliance with this standard.
Identify the persons
responsible and report the
results to the Department by
December 29, 2006.
Conduct a random record
review of student records
where there was a lack of
parental response exceeding 30
days from issue of the IEP. The
sample should be selected from
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 35 of 44
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
each cluster and level (thirty
files). Report to the
Department the rates of
compliance with this standard.
Identify persons responsible
and report to the Department
any action taken if noncompliance continues by June
30, 2007.
SE 59
Transfer of
Student
Records
Student
Records and
Interviews
Corrective
Action
Determined
Not to Have
Been
Effective
Interviews indicate that
the district requires a
parent signature from a
Charter school parent
prior to sending student
records from the Boston
Public Schools to the
charter school. The
district’s written and
published policy states
that records are sent
directly to the new school.
without parent permission
or written consent. The
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 36 of 44
The district must revise its
transfer of student records
procedures so that is consistent
with the requirements of 603
CMR 23.07(4)(g). Provide a
copy of these procedures to all
school Principals so that each
individual school’s actions are
consistent. Please provide a
copy of the memo to the
Department by September 30,
2006.
Conduct a random review of
records (thirty files) with
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
district’s procedure for
transferring student
records to Charter schools
is contrary to its policy
for transferring records to
all other schools/districts.
samples from each level and
each cluster where the students
have transferred to charter
schools. Check that a copy of
the entire student record was
sent. Report rates of
compliance to the Department
by December 29, 2006 along
with steps taken by the district
to address any non-compliance
identified and the persons
responsible for carrying out
corrective action.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 37 of 44
Criterion
Number
and
Topic
Criterion
Implemented

Method(s)
of
Verification
Basis of Determination that
Criterion was Implemented
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
Student
Records and
Interviews
Student records and interviews
indicate that
the district continues to
demonstrate efforts in the area
of transition and is now
beginning to implement
transition planning charts
recommended by the DOE.
Partially
Implemented
The district is not
providing goals and
transition services for
students with mild to
moderate disabilities.
Conduct an internal monitoring
across grade levels and across
clusters (again, 30 files at the
secondary level), for
consideration and use of
transition goals. Analyze the
results of that review and
provide to the Department by
December 29, 2006. Check
each file for the required
elements:
1) Preferences
2) Interests
3) Post Secondary
environments
4) Adult living
Following the self-monitoring
activity in this area, identify
which staff may need
additional training and develop
follow-up activities. Describe
(Refer to full
text of 20052006 CPR
requirements)
Special
Education
Criteria created
or revised in
response to
IDEA-2004
SE 6
Determination
of Transition
Services
Vision statements do not
contain all required
elements:
1) Preferences
2) Interests
3) Post secondary
environments
4) Adult living
The team found that in the
student records there were
no age specific transition
plans in the PLEP B
section of student records.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 38 of 44
the activities and provide
documentation to the
Department with details as to
persons involved, the dates of
training and persons
responsible for implementation
by December 29, 2006.
SE 8
IEP Team
composition
and attendance
SE 12
Frequency of
re-evaluation
Partially
Implemented
Partially
Implemented
Student
Records and
Interviews
Student
Records and
Interviews
Student records and interviews
indicate the school district is in
the process of rectifying the low
parental attendance rate for
evaluation meetings and has
begun to include a parent
contact log on the inside of
student files to document
multiple attempts and variety of
methods.
The district conducts full reevaluations consistent with the
requirements of federal law
when the student’s needs
warrant it or when a parent or
teacher requests it.
Partially
Implemented
Partially
Implemented
Records and interviews
indicate that eligibility
decisions are made in the
district without parents in
attendance. In addition,
students who are older
than 14 are not invited on
the attendance sheet.
Interviews indicate that
ETFs (school based and
“city-wide”) do not
always have the authority
to commit the district’s
resources and are required
to check with a higher
administrative authority
before making decisions.
Develop revised procedures
clarifying which persons in the
district (by title and by
function) will have the
authority to commit district
resources and disseminate to
all special education staff with
a copy to the Department by
September 30, 2006.
Evaluation reports were
undated. Assessment
summaries need to
indicate the date(s) of test
administration so that the
district can demonstrate
that it meets state and
federal compliance with
timelines. The
Department would note
Provide a memo to all ETF
staff and all person’s working
directly or on contract to the
Boston Schools, who conduct
assessments, regarding the
necessity for providing dates of
test administration and
summary report(s) dates.
Provide the Department with a
copy of the memo and a list of
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 39 of 44
Provide the Department of
Education with a copy of a
memo by September 30, 2006
reminding all Educational
Team Facilitators to include
students over 14 years of age
on the Meeting Invitation
Notices (N3) sent before IEP
Team meetings.
SE 13
Progress
Reports and
content
Partially
Implemented
Student
Records and
Interviews
The district does report
information to parents including
written information on the
student’s progress toward the
annual goals in the IEP and
information on the extent to
which such progress is
sufficient to enable the student
to achieve the goals by the end
of the year.
Partially
Implemented
that a number of errors of
this nature were identified
by the on-site team during
the student record review.
all the persons who received it
by September 29, 2006.
Conduct a self-monitoring
activity by reviewing a random
sample of records across all
levels and clusters (thirty files
total) for the inclusion of dates
on assessment reports. Submit
to the Department the results of
the review and rates of
compliance by December 29,
2006. Describe any action
taken by the district to correct
non-compliance found and
identify the staff responsible
for follow-up.
Progress Reports are not
always issued with the
same frequency as report
cards. Additionally,
progress reports;
1) Are sometimes
not in the student
records;
2) Do not always
address the
benchmarks and
goals;
3) Do not make a
prediction as to if
the student will
meet the goal by
the end of the
year.
Review with special education
teachers and related services
staff the required elements to
be addressed when developing
written progress reports.
Document the materials and
attendance for this review by
September 30, 2006. This
topic could be addressed along
with the activities required
under SE 18A IEP
Development.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 40 of 44
Conduct a self-monitoring
activity by reviewing a random
sample of records across all
levels and clusters (thirty files
total) for provision of
appropriately developed
progress reports. Submit to the
Department the results of the
review and rates of compliance
by December 29, 2006.
Describe any action taken by
the district to correct noncompliance found.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 41 of 44
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
(Refer to full
text of 20052006 CPR
requirements)
Student
Records and
Staff
Interviews
SE 14
Review and
revision of IEPs
Student
Records and
Interviews
SE 25B
Resolution of
disputes
Implemented
District
Documents,
Student
Records and
Staff
Interviews
Documents, student records and
interviews indicate that the
Boston Public Schools
developed forms for staff to use
and a procedure to follow when
parents request hearings with
the BSEA (Bureau of Special
Education Appeals).
SE 30
Notice of
procedural
Implemented
District
Documents,
Student
Documents, student records and
interviews indicate that the
Boston Public School’s Notice
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
Based on student record
review, IEP meetings are
not held on or before the
expiration of the service
dates from the previous
year.
Use the district database to
examine the rate of compliance
for Annual Review meetings
by building and by cluster.
Determine where the district is
failing to fully implement this
criterion and report the rate of
compliance to the Department.
Describe additional corrective
actions that will be taken and
the person(s) responsible by
September 30, 2006. See
additional required corrective
action under SE 57.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 42 of 44
safeguards
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days
Partially
Implemented
Records and
Staff
Interviews
of Procedural Safeguards
contains all required elements
included in the Massachusetts
Interim Notice of Procedural
Safeguards.
District
Documents,
Student
Records and
Staff
Interviews
The district does have written
procedures for suspension of
students with disabilities more
than 10 days.
Partially
Implemented
District documents,
student records and staff
interviews indicate that
the district does not
consistently hold
manifestation
determination meetings
when suspensions exceed
10 consecutive school
days or a pattern has
developed for suspensions
exceeding 10 cumulative
days.
It is especially important
to coordinate the efforts
of both school based ETF
staff and school level
administrators to maintain
procedural compliance
with conducting
manifestation
determination meetings
and ensuring the
provision of specially
designed instruction and
access to the general
curriculum for students
who have been suspended
for more than 10 days.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 43 of 44
Please document with the
Department the provision of an
update to all ETFs and
Principals on the topics of:
discipline of students
w/disabilities under IDEA
2004 by September 30, 2006.
Documentation may include
the provision of any training
previously conducted in this
area with administrators and/or
ETF staff since January of
2006.
Documentation should include
(Names, Sign in log, Copies of
materials used and the dates.)
Conduct a follow-up activity
where each APD conduct a
record review of all those
students who have been
suspended consecutively or
cumulatively beyond 10 days
to see if the appropriate
procedures were followed and
report the results to the
Department by December 29,
2006. The Department
recommends that the district
conduct a review to ensure all
school handbooks are updated
to reflect a consistency with
the district’s overall policy
under IDEA 2004.
Boston Public Schools Coordinated Program Review Mid-cycle Report
August 17, 2006
Page 44 of 44