1Massachusetts Department of
Elementary and Secondary Education
75 Pleasant Street, Malden, Massachusetts 02148-4096
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
June 12, 2012
Carol Johnson, Superintendent
Boston Public Schools
26 Court Street
Boston, MA 02108
Re: Mid-cycle Report
Dear Superintendent Johnson:
Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based
on the onsite visit conducted in your district in January 2012. During the Mid-Cycle Review the
Department monitored selected special education criteria to determine your district’s compliance
with special education laws and regulations. The review consisted of information gathered from
one or more of the following activities: interviews, review of student records, examination of
documentation, and classroom observation(s).
The Department determined that one or more of the criteria monitored in your district was
“Partially Implemented” or “Not Implemented.” In all instances where noncompliance was
found, the Department has prescribed corrective action for the district. This corrective action
must be implemented as soon as possible, but in no case later than a year from the date of this
report. You will find these requirements for corrective action included in the enclosed report,
along with requirements for submitting progress reports using the enclosed form.
Please provide the Department with your written assurance that all of the required corrective
action will be implemented by your district within the timelines specified in the report. You
must submit your statement of assurance to Darlene Lynch, Director, Program Quality Assurance
Services, by June 28, 2012.
1
Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have questions
about this letter or the enclosed report, please do not hesitate to contact Jane Ewing at 781-3383741.
Sincerely,
Jane L. Ewing, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
cc:
Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education
Dean Paolillo, Supervisor, Program Quality Assurance Services
Rev. Gregory G. Groover, School Committee Chairperson, Boston Public Schools
John Verre, Assistant Superintendent for Special Education & Student Services, Boston
Public Schools
K. C. Grogan, Local Program Review Coordinator, Boston Public Schools
Encs: Mid-cycle Report
Mid-cycle Progress Report Form
2
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE REPORT
BOSTON PUBLIC SCHOOLS
Dates of the Mid-cycle Review Onsite: January 16-19, 2012
Date of this Report: June 12, 2012
PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS.
Required Special Education Criteria Monitored in this Mid-cycle Review
Current special education criteria available by scrolling down to the special education instrument at
http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
SE 7
Transfer of
parental
rights and
student
participation
and consent
at age of
majority
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
PI
Student
Record
Review
Documents
Staff
Interviews
Basis of Determination about
Criterion
According to student records, the
district sends a notice of the
transfer of rights to the student
one year prior to the student
obtaining the age of majority.
District documents and staff
interviews confirmed that the
district also sends out this notice
to all parents of students who
will turn 18 in the year prior.
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
Please review the administrative
advisory 2011-1 that can be found at
http://www.doe.mass.edu/sped/advisor
ies/11_1.html for assistance in
developing the district’s corrective
action.
Please revise the district’s standard
notice to include the continued right
of the parent to have access to the
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 1 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Please provide
a copy of the
revised
notification.
Please ensure
that the revised
notice for Age
of Majority is
provided to IEP
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
The document is available in
several languages.
However, in addition to
explicitly stating that all
educational decision-making
rights transfer from parents to
the 18 year old student, the
notification must also state that
the parent will continue to
receive all the required notices
from the school district and will
have the right to inspect the
student's records. These
additional rights are not outlined
in the district’s notice.
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
student’s record or use the Parent’s
Notice of Procedural Safeguards with
a cover letter to the student and
parent.
Please provide guidance to the high
school IEP Team chairpersons on the
revised notice and its use.
Please conduct an internal review of a
sample of student records drawn from
those students who turned 17
subsequent to the district’s
implementation of all corrective
actions. Please examine the records to
ensure the schools are using the
revised notice. Please review the
student records to ensure notification
was sent.
*Please note that when conducting
internal monitoring the district
must maintain the following
documentation and make it
available to the Department upon
request: a) List of student names
and grade level for the record
review; b) Date of the review; c)
Name of person(s) who conducted
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 2 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Team
chairpersons;
please
document how
the district
made the
revised notice
available to
staff (a
memorandum;
agenda, signed
attendance
sheet with the
name and role
of staff; etc.).
This progress
report is due
October 2,
2012.
Please submit
the results of
the review of
student records.
Indicate the
number of
student records
reviewed, the
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
the review, their roles(s), and their
signature(s).
(b) Progress
Report Due
Date(s) and
Required
Elements
number of
student records
in compliance,
for all records
not in
compliance
with this
criterion,
determine the
root cause(s) of
the
noncompliance
and provide the
school’s plan to
remedy the
noncompliance.
Please submit
these results by
January 14,
2013.
SE 8
IEP Team
composition
and
attendance
PI
Student
Record
Review
Documents
A review of student records
across all levels of the district
demonstrated that when required
members of the IEP Team did
not attend, there was not always
evidence of a signed excusal
Please provide training on the excusal
process of a required IEP Team
member to all IEP Team chairpersons.
Please develop an internal tracking
and monitoring system to ensure that
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 3 of 32
Please provide
evidence of the
training
provided to the
district’s special
education
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Staff
Interviews
Basis of Determination about
Criterion
form in the student record.
Additionally, there was no
evidence that the absent required
IEP Team member provided
written input to the parent and
the IEP Team prior to the IEP
Team meeting.
According to the document
review and staff interviews, the
district has a form and procedure
to excuse required IEP Team
members from attending IEP
meetings.
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
required IEP Team member excusals
and their written feedback are
appropriately documented in the
student record.
Select a sample of student records
across all school levels to review for
the implementation of the IEP Team
excusal process. The sample should be
taken from those IEP Team meetings
that have occurred after all other
corrective actions have been
implemented. Evidence should
demonstrate where appropriate that 1)
the excusal document is signed and
present in the file and 2) the district
documented that the excused IEP
Team member provided written input
to the parent and IEP Team.
*Please note that when conducting
internal monitoring the district
must maintain the following
documentation and make it
available to the Department upon
request: a) List of student names
and grade level for the record
review; b) Date of the review; c)
Name of person(s) who conducted
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 4 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
chairpersons,
including the
agenda, signed
attendance
sheet with the
name and role
of staff and the
training
materials.
Provide this
documentation
for the progress
report due
October 2,
2012.
Please submit a
description of
the district’s
internal
tracking and
monitoring
system. Please
be sure to
include
personnel
responsible for
supervisory
oversight. This
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
the review, their roles(s), and their
signature(s).
(b) Progress
Report Due
Date(s) and
Required
Elements
progress report
is due on
October 2,
2012
Please submit
the results of
the review of
student records.
Indicate the
number of
student records
reviewed, the
number of
student records
in compliance,
for all records
not in
compliance
with this
criterion,
determine the
root cause(s) of
the
noncompliance
and provide the
district’s plan to
remedy the non
compliance.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 5 of 32
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
Please submit
these results by
January 14,
2013.

Student
Record
Review
Documents
SE 18A
IEP
development
and content
Staff
Interviews
Student records demonstrated
that IEP Teams consistently
indicated their consideration of
whether a student's disability
affected social skills
development, or when the
student's disability makes him or
her vulnerable to bullying,
harassment, or teasing on the
IEP Team summary template.
In addition, student records
demonstrated that for students
identified with a disability on the
autism spectrum, the IEP Team
consistently and specifically
addressed the skills and
proficiencies needed to avoid
and respond to bullying,
harassment, or teasing in student
IEPs.
The district’s documentation and
staff interviews verified that
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 6 of 32
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
multiple trainings have been
provided, as well as the training
on the IEP Team’s obligation to
document in the IEP when the
student’s disability affects social
skills development or makes the
student susceptible to bullying,
harassment, or teasing.
District personnel are aware that
IEP Teams must consider and
address the skills and
proficiencies needed to avoid or
respond to bullying, harassment,
or teasing for students identified
with a disability on the autism
spectrum.
SE 25
Parental
consent
PI
Student
Record
Review
Documents
Staff
Interviews
The document review indicated
that written notice and the Parent
Notice of Procedural Safeguards
are sent within two weeks to a
parents’ written request to
revoke consent to special
education services.
Please see SE 2 & SE3.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 7 of 32
Please see SE 2
& SE3.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
This notice outlines several
consequences of the revocation,
including that the student will no
longer be afforded the
disciplinary safeguards and due
process rights of a special
education student and that the
parent must promptly re-enroll
the student for a general
education seat.
Staff interviews verified that
when a parent revokes consent
for special education, the district
provides the parent notification
that all special education
services will be discontinued.
Additionally, documentation and
interviews verified that the
district will not use mediation or
request a due process hearing to
obtain agreement or a ruling
requiring the continuation of
services, consistent with federal
regulation.
However, please see SE 2 (ABA
assessments not completed) and
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 8 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and
Timelines for Implementation
SE 3 (observations missing from
files).
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 9 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Additional Special Education Criteria Monitored in this Mid-cycle Review
Current special education criteria available by scrolling down to the special education instrument at
http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
SE 2
Required &
Optional
Assessments
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
PI
Student Record
Review
The student record
review and staff
interviews determined
that Applied Behavioral
Analysis (ABA)
assessments are not
always completed within
30 school days of the
receipt of signed consent,
and ABA assessment
reports are not available
in time for the IEP Team
meetings, though IEP
Teams reconvened once
the assessments are
completed.
Provide a table of the current
ABA assessment backlog by
individual student (use SASID
numbers); include the date of the
signed consent, the date the
assessment was completed, and
the date of the IEP Team meeting.
If the assessment was completed
after the IEP Team met, provide
the date the IEP Team
reconvened.
Provide the table of
data the DESE
requested with
regard to students
currently waiting
for ABA
assessments and
students previously
backlogged.
Staff Interviews
Interviews confirmed
that consented-to ABA
assessments are
considerably backlogged.
According to special
Based on the district’s remaining
backlog, please describe what
additional steps the district has
taken to remedy the issue,
including identifying the person
responsible for oversight and
implementation of the corrective
action.
Select a sample of student records
– particularly sampling from the
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 10 of 32
Provide the
narrative
description of the
additional activities
the district is
prepared to take,
including the
associated timeline,
the name of the
person responsible
for oversight and
implementation of
the corrective action
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
education staff, efforts
have been made by the
BPS to address the need
for ABA assessments,
including:

Developing a
problem-solving
taskforce with
parents and
community
members;

Hiring three new
Board Certified
Behavior Analysts
(two in September
2011 and one in
January 2012), 15
ABA specialists on
staff, and
contracting with
four private
providers;

Meeting with
leading diagnostic
teams at Boston
Medical Center,
Children’s Hospital
and Mass General
Hospital; and

Working with
early education and elementary
population of students on the
spectrum for those evaluations
that were consented to subsequent
to the district’s implementation of
all corrective actions -- to review
for 1) completion of ABA
assessments within 30 days of the
signed parent consent and 2)
availability of ABA assessment
reports in time for the IEP
meeting.
to address any
remaining backlog.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 11 of 32
This progress report
is due October 2,
2012.
Please submit the
results of the review
of student records.
Indicate the number
of student records
reviewed, the
number of student
records in
compliance, for all
records not in
compliance with
this criterion,
determine the root
cause(s) of the
noncompliance and
provide the school’s
plan to remedy the
non-compliance.
Please submit these
results by January
14, 2013.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
Please conduct the observation
and develop the appropriate SLD
documentation for individual
students identified by the
Department in the Student Record
Issues Worksheet and re-convene
the IEP Team to review the results
of the observation and develop the
Provide copies of
the Notice of the
School District
Proposal to Act, and
a Meeting Invitation
for each individual
student identified by
the Department in
private agencies
such as the May
Institute and New
England Center for
Children (NECC)
to improve ABA
program
development in
Boston Public
Schools, including
direct services
consultative
services and
assisting with
program
development.
The district indicated
that these efforts have
reduced the backlog of
assessments.
SE 3
Determination of
Specific Learning
Disability
PI
Student Record
Review
A review of student
records indicated that
required observations of
students in the classroom
for students identified
with a Specific Learning
Disability (SLD) were
not always completed
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 12 of 32
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
and/or kept in the student
record.
SLD documentation for each
student.
Additionally, the IEP
TEAM’s documentation
for students identified as
SLD was not present in
student files.
Please conduct training for IEP
Team chairpersons to review the
Department's technical assistance
regarding the eligibility
requirements for students
suspected of having a specific
learning disability (SLD). The
Department’s technical assistance
can be found at:
http://www.doe.mass.edu/sped/iep
/sld/default.html.
Please develop an internal
tracking and monitoring system to
ensure that the IEP Team
completes the components
required to document the Team's
written determination of a specific
learning disability and to ensure
that all of the forms are placed in
student files. Please identify
personnel responsible for
supervisory oversight and periodic
reviews of this requirement.
Select a sample of student records
from a cross-section of BPS
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 13 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
the Student Record
Issues Worksheet to
document that IEP
Teams reconvened
to develop and
review the SLD
documentation.
Please provide
evidence of training
provided to IEP
Team chairpersons
including the
agenda, signed
attendance sheet
(with the name and
role of staff) and
training materials.
Please submit a
description of the
district’s internal
tracking and
monitoring system.
Please be sure to
include personnel
responsible for
supervisory
oversight. This
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
schools and levels to review for
implementation of the SLD
process. The sample should be
taken from those SLD evaluations
that have occurred after all
corrective actions have been
implemented.
Evidence should demonstrate that
1) SLD documentation is
appropriately developed and
signed by all Team members
during the IEP Team meeting; 2)
observations are provided; and 3)
all SLD documentation is
included in the student record.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 14 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
progress report is
due on October 2,
2012.
Please submit a
narrative description
of the results of the
internal monitoring
conducted. Please
include the numbers
of records reviewed
and the number of
records found to be
in compliance.
For all records not
in compliance with
this criterion,
determine the root
cause(s) of the
noncompliance and
the specific actions
taken to address the
noncompliance.
Please submit these
results by January
14, 2013.
Criterion
SE 4
Reports of
assessment
results
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
PI
Student Record
Review
Student record review
determined that
achievement reports
(Woodcock-Johnson III
assessments) conducted
as part of an initial
evaluation or reevaluation did not
contain the assessor’s
diagnostic impression or
recommendations for
meeting the student’s
educational needs. In
many cases, the
assessment report
consisted of computer
generated scores and a
brief paragraph
reiterating the scores.
Please provide training in the
development of appropriate
achievement assessment reports to
any special education staff
responsible for this testing; please
specify training by group (e.g.,
IEP Team chairpersons, special
education teachers, etc.).
Please provide
evidence of training
provided, including
signed attendance
sheets (with the
name and roll of
staff), agenda, and
the training
materials.
Additionally, some
related service providers’
assessment reports did
not contain
recommendations for
meeting the student’s
educational needs.
In addition, please provide
training to related service
providers regarding the inclusion
of recommendations in assessment
reports.
Please develop an internal
tracking and monitoring system to
ensure that evaluators are
appropriately developing
assessment reports that include the
diagnostic impression and the
evaluators’ recommendations for
meeting the student’s educational
needs. Please identify personnel
responsible for supervisory
oversight and periodic reviews of
this requirement.
Select a sample of student records
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 15 of 32
Please submit a
description of the
district’s internal
tracking and
monitoring system.
Please be sure to
include personnel
responsible for
supervisory
oversight.
This progress report
is due October 2,
2012.
Submit the results
of the review of
student records.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
from a cross-section of BPS
schools and levels of students with
initial evaluations and reevaluations that were conducted
after all corrective actions have
been implemented to review for
completeness of both achievement
and related services assessment
reports. Evidence should
demonstrate that 1) the evaluator’s
diagnostic impression is included
in the report and 2) the evaluator’s
recommendations for meeting
student educational needs are
present in the report.
Indicate the number
of student records
reviewed, the
number of student
records in
compliance, for all
records not in
compliance with
this criterion,
determine the root
cause(s) of the
noncompliance and
provide the school’s
plan to remedy the
non-compliance.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 16 of 32
Please submit these
results by January
14, 2013.
Criterion
Criterion
Implemented

SE 5
Participation in
MCAS

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
Student Record
Review
Student record review
verified that for students
who have not yet taken
or passed the MCAS,
IEP Teams designate in
the student’s IEP how
each student will
participate during
testing.
Document
Review
Staff Interviews
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
Please provide training in the
appropriate development and
completion of progress reports to
special education staff; please
specify training by group (e.g.,
IEP Team chairpersons, special
education teachers, related
services providers, etc.).
Please provide
evidence of training
on the development
and translation of
progress reports,
etc., including
signed attendance
sheets (with the
name and role of the
staff member),
agendas, and the
training materials.
The district revised its
summary IEP meeting
sheet, which contains a
specific check off for this
area of IEP development.
SE 13
Progress reports
and content
PI
Student Record
Review
Student record review
demonstrated that
progress reports were
frequently not found in
files, were incomplete, or
were not translated for
parents who are not
fluent in English.
In addition, provide special
education staff with a review of
the district’s policies requiring
translated progress reports for
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 17 of 32
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
parents who need translated
documents.
Please develop an internal
tracking and monitoring system to
ensure that 1) progress reports are
complete and appropriately
developed; 2) progress reports are
translated for families requiring
translations; and 3) progress
reports are in student records.
Please identify staff responsible
for supervisory oversight and
periodic reviews of this
requirement.
Select a sample of student records
from a cross-section of BPS
schools and levels to review for
implementation of the
requirements for progress
reporting. The sample should be
taken from progress reports that
were written after all other
corrective actions have been
implemented (second quarter
progress reports).
Evidence should demonstrate that
1) where appropriate, the progress
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 18 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Please submit a
description of the
district’s internal
tracking and
monitoring system.
Please be sure to
include personnel
responsible for
supervisory
oversight.
This progress report
is due October 2,
2012.
Please submit the
results of the review
of student records.
Indicate the number
of student records
reviewed, the
number of student
records in
compliance, for all
records not in
compliance with
this criterion,
determine the root
cause(s) of the
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
report is translated; 2) the progress
report includes written
information on the student´s
progress toward the annual goals
in the IEP, and 3) the progress
report is included in the student’s
file.
noncompliance and
provide the school’s
plan to remedy the
non-compliance.
Please submit these
results by January
14, 2013.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
SE 14
Annual review
and amendments
PI
Student Record
Review
Staff Interviews
According to student
records and staff
interviews, IEP reviews
are not consistently held
annually on or before the
anniversary date of the
IEP to review and revise
the IEP as necessary.
Please conduct a root cause
analysis of annual reviews from
October 2011 – February 2012 to
determine why delays occur in
scheduling IEP Team meetings; in
particular, explain why IEP Teams
do not consistently convene on or
before the anniversary date of the
IEP.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 19 of 32
Please provide a
detailed description
of the analysis
conducted, the
outcomes, the
corrective actions
taken and the
associated
timelines.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
Additionally, IEPs
showed that projected
dates for the next annual
review were frequently
scheduled beyond one
year of the current IEP.
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
Additional progress reports may
be specified after the Department
reviews the district’s October 2,
2012 submission.
Conduct an internal review of
student records after all corrective
actions have been implemented.
Select a sample of student records
from a cross-section of BPS
schools and levels drawn from
annual reviews held subsequent to
all of the district’s corrective
actions to verify that the IEP
Team meetings are scheduled and
held on or before the anniversary
date of the previous IEP.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 20 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Please identify any
person(s)
responsible for the
oversight to ensure
that the annual
reviews are
scheduled on time.
This progress report
is due October 2,
2012.
Please submit the
report of the results
of the internal
review of records.
Please include the
number of records
reviewed and the
number of student
records in
compliance. For all
records not in
compliance, please
determine the root
causes(s) of the
noncompliance and
submit the district’s
plan to remedy the
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
signature(s).
SE 17
Initiation of
Services at Three
and EI
transitions
PI
Student Record
Review
Staff Interviews
A review of student
records demonstrated
that young children
referred from Early
Intervention (EI) and/or
other agencies or
individuals did not
typically have IEPs
developed before the
child’s third birthday.
Review of
documentation in the
students’ files and staff
interviews established
that even though the EI
or parent referral
occurred before the child
turned three; families
must establish residency
before BPS staff will
hold a child’s transition
meeting or provide the
Please conduct a root cause
analysis of Early Intervention and
other referrals for young children
from October 2011 – February
2012 sampled from a cross section
of district zones and/or parent
information centers to determine
why delays occur between the
date of the referral to the Boston
Public Schools and the date of the
IEP development Team meeting;
in particular, explain why IEP
Teams do not consistently
convene before the child’s third
birthday. In doing so, please also
identify where and when the noncompliance is occurring.
Following the root cause analysis,
propose to the Department any
adjustments to the district’s
procedures or allocation of
resources based on the outcomes
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 21 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
noncompliance.
This progress report
is due January 14,
2013.
Please provide a
detailed description
of the analysis
conducted, the
outcomes, the
corrective actions
taken and the
associated
timelines.
Describe the
adjustments and/or
revisions made to
the intake system or
procedures,
including associated
timelines and
identify the staff (by
name and role)
responsible.
This progress report
is due October 2,
2012.
Criterion
SE 18B
Placement,
provision of IEP
to parent
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
PI
Method(s) of
Investigation
Student Record
Review
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
consent to evaluate form
to the family. The delays
resulted in scheduling
the initial IEP meeting
after the child’s third
birthday.
of the district’s analysis.
Once parental consent
was obtained, all
evaluations except ABA
assessments were
consistently completed
within 30 days and IEP
meetings held within 45
days of the date of the
receipt of consent. See
SE 2.
Upon completion of the district’s
corrective action activities. The
Department will conduct an onsite
review of student records. This
onsite visit will be scheduled in
school year 2012- 2013.
According to the student
record review, the IEP
Team Determination of
Educational Placement
decisions did not always
reflect the proposed
Please obtain signatures on the
placement page for individual
students identified by the
Department in the Student Record
Issues Worksheet.
(b) Progress
Report Due
Date(s) and
Required
Elements
Additional progress reports may
be specified after the Department
reviews the district’s October 2,
2012 submission.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 22 of 32
Please provide
copies of the signed
placement pages for
the students
identified by the
Department.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
services of the IEP.
Please conduct a root cause
analysis for IEPs developed
between October 2011 – February
2012 to determine why the
signature on the IEP placement
page are consistently missing,
why Educational Placement
decisions do not align with
proposed IEP services on the
service delivery grid, and why
IEPs are proposed to parents in
excess of 10 days from the IEP
Team meeting.
In addition, the
placement page was not
always signed by the
educational decisionmaker.
According to some files,
the Notice of Proposed
District Act (N1)
demonstrated that the
IEP was proposed to the
parent well beyond 10
business days following
the IEP development
meeting.
Additional progress reports may
be specified after the Department
reviews the district’s October 2,
2012 submission.
Select a sample of student records
from a cross-section of BPS
schools and levels to review for
the educational decision-makers
signature(s) on the placement
page. The sample should be taken
from those IEP Team meetings
that have occurred after all other
corrective actions have been
implemented. Evidence should
demonstrate that 1) all IEPs have
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 23 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Please provide a
detailed description
of the analysis
conducted, the
outcomes, the
district’s corrective
actions with
associated timelines
and the staff
responsible (by
name and role).
This progress report
is due October 2,
2012.
Please submit the
report of the results
of the internal
review of records.
Please include the
number of records
reviewed and the
number of student
records in
compliance. For all
records not in
compliance, please
determine the root
causes(s) of the
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
the appropriate decision-makers’
signatures on the IEP and on the
placement page; 2) the
Educational Placement aligns with
proposed IEP services on the
service delivery grid; and 3) the
IEP was proposed within 10 days
of the IEP meeting.
noncompliance and
submit the district’s
plan to remedy the
noncompliance.
This progress report
is due January 14,
2013.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
SE 20
Least restrictive
program selected
PI
Student Record
Review
According to student
record review, the Nonparticipation Justification
statements, for why
student removal from the
general education
classroom is considered
Please ensure that IEP Team
chairpersons are trained in the
appropriate development of Nonparticipation Justification
statements that answer why the
students’ removal was considered
critical to the student´s program.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 24 of 32
Provide the training
agenda, signed
attendance sheets
indicating the
title/role of the staff
attending as well as
the name and title of
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
critical to the student’s
program and the basis for
that conclusion,
frequently did not
answer why the removal
was necessary. In some
cases, this statement was
missing altogether.
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
Please develop an internal
periodic review and tracking
system for appropriateness of
Non-participation Justification
statements and identify the
person(s) responsible by name and
title for this internal monitoring.
Please conduct a student record
review after all other corrective
actions have been implemented.
Select a sample of student records
from a cross-section of BPS
schools and levels for the
appropriate development of Nonparticipation Justification
statements in IEPs developed
subsequent to the completion of
the district’s corrective actions.
Evidence should demonstrate
where appropriate that 1) Nonparticipation Justification
statements are present in the IEP,
and 2) the statements answer why
the students’ removal was
considered critical to the student´s
program for those students
removed from the general
education setting for special
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 25 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
the presenter. Please
provide a copy of
the training
materials.
Please describe the
system of internal
monitoring and
periodic review and
identify the staff
responsible.
This progress report
is due
October 2, 2012.
Please submit the
report of the results
of the internal
review of records.
Please include the
number of records
reviewed and the
number of student
records in
compliance. For all
records not in
compliance, please
determine the root
causes(s) of the
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
education services.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
SE 21
School day and
school year
requirements

Student Record
Review
Document
Review
Staff Interviews
The student records
indicated that extended
school day and school
year (ESY) programming
was routinely considered
by IEP Teams. The
district revised its
summary IEP meeting
sheet, which contains a
specific check off for this
area of IEP development.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 26 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
noncompliance and
submit the district’s
plan to remedy the
noncompliance.
This progress report
is due January 14,
2013.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
Please conduct a root cause
analysis for IEPs developed
between October 2011 – February
2012 to determine why parent
notification letters of delayed
ABA services are consistently
missing from student files. In
doing so, please identify the root
cause of the noncompliance
identified in the student records.
Please provide a
description of the
analysis conducted,
the outcomes, the
district’s corrective
actions and
associated
timelines.
Student IEPs
demonstrated that BPS
Teams identified ESY
programming as
appropriate for students
with disabilities.
SE 22
IEP
implementation
and availability
PI
Student Record
Review
Staff Interviews
According to staff
interviews, when a
service is delayed
because of lack of
classroom space or
personnel, the school has
a procedure to
immediately notify
parents of the delayed
services, the reasons for
the delay, actions that the
school is taking to
remedy the delayed
services, and offers
alternative means to
meet the goals on the
IEP.
Please develop an internal
periodic review and tracking
system for the presence of parent
notification letters regarding delay
in service and identify the
person(s) responsible by name and
title for this internal monitoring.
However, record review
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 27 of 32
Please describe the
system of internal
monitoring and
periodic review and
identify the staff
responsible.
This progress report
is due October 2,
2012.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
demonstrated that for
students with delays in
the provision of ABA
services, documentation
of parent notification
was not in the student
record.
Additional progress reports may
be specified after the Department
reviews the district’s October 2,
2012 submission.
Select a sample of student records
from a cross-section of BPS
schools and levels to review for
the use of parent notification
letters regarding delay in service.
The sample should be taken after
all other corrective actions have
been implemented and specifically
from records where a delay in
services was noted by the internal
tracking system. Evidence should
demonstrate that 1) when there
was a delay in consented-to
services, parents were sent a
notification letter and 2) a copy of
the letter is in the student’s file.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 28 of 32
(b) Progress
Report Due
Date(s) and
Required
Elements
Please submit the
report of the results
of the internal
review of records.
Please include the
number of records
reviewed and the
number of student
records in
compliance. For all
records not in
compliance, please
determine the root
causes(s) of the
noncompliance and
submit the district’s
plan to remedy the
noncompliance.
This progress report
is due January 14,
2013.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
SE 24
Notice to parents
PI
Student Record
Review
The student record
review indicated that
Notices of Proposed
School District Action
forms (N1)
accompanying consent to
evaluate forms and
proposed IEPs were
frequently not complete
or missing from the
student record.
Please ensure that IEP Team
chairpersons are trained in the
appropriate development of
Notices of Proposed School
District Action forms and of the
requirement to send notice, to
parents whenever the district
proposes or refuses to take action
regarding the provision of special
education services.
Please develop an internal
periodic review and tracking
system for ensuring the provision
of notices to the parent and
completeness of required
information. Identify the person(s)
responsible by name and title for
this internal monitoring.
Conduct an internal review of
student records after all other
corrective actions have been
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 29 of 32
Provide the training
agenda, signed
attendance sheets
indicating the
title/role of the staff
attending and the
training materials.
Provide a
description of the
internal periodic
review and tracking
system and indicate
the person(s)
responsible for it.
This progress report
is due
October 2, 2012.
Please submit the
report of the results
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
implemented to determine that
notices developed subsequent to
the district’s corrective action
activities are provided and address
all federally required information
whenever the district proposes or
refuses to take action regarding
the provision of special education
services.
of the internal
review of records.
Please include the
number of records
reviewed and the
number of student
records in
compliance. For all
records not in
compliance, please
determine the root
causes(s) of the
noncompliance and
submit the district’s
plan to remedy the
noncompliance.
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
SE 29
Communications
in English and
other languages
PI
Student Record
Review
Staff Interviews
The IEP attendance
sheets (N3A) frequently
did not list whether
interpreters were in
attendance at meetings
when the parents were
Please conduct a root cause
analysis for IEPs developed
between October 2011 – February
2012 to determine why translators
are not made available during IEP
meetings for parents who are
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 30 of 32
This progress report
is due January 14,
2013.
Please provide a
detailed description
of the analysis
conducted, the
outcomes, the
corrective actions of
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
identified as LEP.
identified as limited English
proficient (LEP).
See also SE 13.
The district must conduct an
internal review of records after all
other corrective action have been
implemented. Review the student
records to verify that subsequent
to the district’s implementation of
its correct actions, for families
identified as LEP, evidence of
translators at IEP meetings is
recorded on the IEP attendance
sheet (N3A).
*Please note that when
conducting internal monitoring
the district must maintain the
following documentation and
make it available to the
Department upon request: a)
List of student names and grade
level for the record review; b)
Date of the review; c) Name of
person(s) who conducted the
review, their roles(s), and their
signature(s).
(b) Progress
Report Due
Date(s) and
Required
Elements
the district and the
associated
timelines.
This progress report
is due October 2,
2012.
Please submit the
report of the results
of the internal
review of records.
Please include the
number of records
reviewed and the
number of student
records in
compliance. For all
records not in
compliance, please
determine the root
causes(s) of the
noncompliance and
submit the district’s
plan to remedy the
noncompliance.
This progress report
is due January 14,
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 31 of 32
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or Not
Implemented:
(a) Required Corrective Action
and Timelines for
Implementation
(b) Progress
Report Due
Date(s) and
Required
Elements
2013.
SE 48
FAPE and equal
access
PI
Student Record
Review
Please see SE 2.
Please see SE 2.
Please see SE 2.
SE 49
Related services
PI
Student Record
Review
Please see SE 2.
Please see SE 2.
Please see SE 2.
Boston Public Schools Coordinated Program Review Mid-cycle Report
June 12, 2012
Page 32 of 32
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE REVIEW
BOSTON PUBLIC SCHOOLS
M I D – CY C L E P R O G R E S S R E P O R T
Date Prepared: ____________________________________
Prepared by: __________________________________________________________________
(name and title)
Criterion: _______________________
Topic: ________________________________________________________________________
For each criterion for which you prepare a progress report, please
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

make a copy of this cover page,
fill in the information requested above, and
attach a complete description of the corrective action taken and any accompanying documentation.
(Description of corrective action for each criterion and any accompanying documentation should include all of the
“Progress Report Required Elements” for that criterion in the Mid-cycle Report.)
Send the whole set of completed progress reports to:
Darlene Lynch, Director
Program Quality Assurance Services
Massachusetts Department of Elementary and Secondary Education
75 Pleasant Street
Malden, MA 02148-4906