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 14, 2007 Roger Harris, Head of School Boston Renaissance Public Charter School 250 Stuart Street Boston, MA 02116 Re: Mid-cycle Coordinated Program Review Report Dear Director Harris: 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 or ordered by the Department to address findings of noncompliance included in the Boston Renaissance Public Charter School Coordinated Program Review Report issued on January 17, 2004. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. Another component of the Department’s Mid-cycle Review is the review of your charter school's self-assessment in the area of English learner education (ELE). The purpose of this review is to determine whether your school is implementing the significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient students, that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your school’s ELE self-assessment (documentation and any written analysis of compliance) and, based solely on that self-assessment, is providing you in this report with findings on your ELE program and the corresponding corrective action to be implemented. Boston Renaissance Charter School has not developed a program that conforms to M.G.L. Chapter 71A English Language Education program. We have sent a copy of this report to the Department’s Office of Language Acquisition and Academic Achievement (OLAAA) and recommend that the school’s ELE staff seek technical assistance from OLAAA at 781-338-3534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/. The Department will notify you of your next regularly scheduled Coordinated Program Review several months before it is to occur. At this time we anticipate that this CPR will occur sometime during the 2009 school year unless the Department determines that there is some reason to schedule this visit earlier. 1 While the Department of Education found your school to have resolved certain noncompliance issues, others were partially corrected or not addressed at all, or the Department’s onsite team identified new issues of noncompliance, either noncompliance with special education criteria added or substantially changed in response to IDEA 2004, noncompliance with ELE criteria, or other new noncompliance. Where the school 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 school that must be implemented without delay. You will find these requirements for corrective action included in the attached report, along with requirements for progress reporting. Please provide the Department with your written assurance that all of the Department's requirements for corrective action will be implemented by your district within the timelines specified. You must submit your statement of assurance to me by August 30, 2007. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 781-338-3741. Sincerely, Jane L. Ewing, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Jackie Sinclair, Boston Renaissance Charter School Board of Trustees, Chairperson Cleopatra Knight-Wilkins, Program Review Follow-up Coordinator Katherine Riley, Director, Office of Language Acquisition and Academic Achievement Mary Street, Director, Charter School Office Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT BOSTON RENAISSANCE PUBLIC CHARTER SCHOOL ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): October 6, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: June 29, 2004 Dates of Corrective Action Plan Progress Reports: March 12, 2005 and April 15, 2005 Dates of this Mid-cycle Review Onsite Visit: June 4-5, 2007 Date of this Report: August 14, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 1 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting New Issue Identified Student records demonstrated that psychological evaluations are not completed within the 30-day timeline. Please conduct a review of the school’s timeline completion to include the following activities: 1. Conduct a survey with evaluators to determine the factors contributing to the school’s inability to ensure the completion of psychological evaluations within the timelines; Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle MOA 4 Disproportionality (if Cited in the CPR Report) SE 9 Timelines Partially Implemented Student records, staff interviews 2. Implement corrective action in response to incidences of nonBoston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 2 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting compliance found and identify the person(s) responsible for the monitoring and implementation of the school’s corrective action. 3. Report to the Department on these activities by October 18, 2007. In addition, please conduct a review of a sample of student records for assessment report completion within 30 school days. The sample should be drawn from each level. Please review a minimum of five records per school. Report the rate of compliance by building. Identify any additional corrective actions taken and the person(s) responsible for the follow-up to the Department by January 17, 2008. SE 18A Partially Student Not Effective The student record review Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 3 of 33 Please provide documentation Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) IEP Development Approved Corrective Action Implemented and Effective Method(s) of Verification Implemented Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified records 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 demonstrated that service delivery grids still do not document specific counseling services, and IEPs do not reference behavior intervention plans for students, although the charter school is providing these services as part of the special education of eligible students. of training on the following topics. This documentation should include name of the trainer, the date of the training, the signatures of the participants, and copies of the materials used. Paraprofessionals assigned to work with students were not reflected on IEP service delivery grids. Student record review demonstrated that PLEP A and PLEP B forms were not filled out. Additionally, the student records review indicated that student vision statements on IEPs were insufficiently developed. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 4 of 33 1. Review with the appropriate staff the purpose and development of PLEP A and PLEP B forms; 2. Review with staff the development of appropriate student vision statements on IEPs; 3. Review with appropriate staff the purpose and development of the service delivery grid. Provide this documentation to the Department by October 18, 2007. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Following the training, the school must conduct a sample review of five records at each level and check to ensure the charter school is meeting the above requirements. Report the results by program level. Please describe any additional activities taken to address continuing non-compliance and identify the staff responsible for carrying out these activities. Submit this report to the Department by January 17, 2008. SE 19 Extended Evaluations Implemented Student record review, staff interviews Interviews conducted for the Mid-Cycle indicated that staff members are appropriately trained to conduct extended evaluations According to student records, the procedure is implemented only when the IEP Team needs additional assessment information about the student and not to delay the provision of services. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 5 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 21 Extended School Day/Year Approved Corrective Action Implemented and Effective Method(s) of Verification Not Implemented Student record review, staff interviews Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Not Implemented Boston Renaissance Charter School was cited in 2003 for not routinely considering student need for an extended year program for students on IEPs. Please provide documentation of training on the consideration and implementation of extended school year services. This documentation should include name of the trainer, the date of the training, the signatures of the participants, and copies of the materials used. The school may wish to consult the Department’s guidance on this topic at the following link: http://www.doe.mass.edu/pqa/t a/esyp_qa.html. Record review and staff interviews for the 2007 Mid-Cycle indicated that Boston Renaissance still does not make Extended School Year services available to students and does not routinely consider the need for extended year services when developing IEPs. In addition, please provide a statement of assurance that Boston Renaissance Charter School will provide extended school year services to students who require an extended school year as determined by the IEP Team, regardless of financial considerations. Provide documentation of the staff training and statement of Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 6 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting assurance to the Department October 18, 2007. Following the training, the school must conduct a sample review of five records at each level (minimum 15 records) to ensure the charter school is meeting the above requirements. Report the results of the monitoring by program level and describe any additional activities taken to address continuing non-compliance and identify the staff responsible for carrying out these activities Submit this report to the Department by January 17, 2008. SE 24 Notice to Parents Partially Implemented Student record review, document review, staff interviews New Issue Identified According to document review and student records, when a parent requests an evaluation to determine eligibility for special education, the charter school sends the Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 7 of 33 Please provide training to appropriate staff on the requirement to provide a parent with a proposed consent form within 5 school days of receipt of the referral as required by 603 CMR 28.04(1). Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance parent an information form that must be filled out and returned to the school before the parent is sent a consent to evaluate form. The school requires this information form as a means to consult with the parent about the student’s suspected disability. Therefore, the parent does not receive the consent form within 5 school days of receipt of the referral as required by 603 CMR 28.04(1). Required Corrective Action, Timelines for Implementation, and Progress Reporting Please provide documentation of this training should include name of the trainer, the date of the training, the signatures of the participants, and copies of the materials used. Provide this documentation to the Department by October 18, 2007. Please develop an internal tracking and monitoring system to ensure that parents are receiving the consent to evaluate form within five days of the request for an evaluation. Report on the results of monitoring the timelines over a period of three months, reporting by level the number of records reviewed and the number of records found to be in compliance. Following the review, please describe any additional activities taken to address continuing non-compliance, if Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 8 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting found, and identify the staff responsible for carrying out these activities. Submit the report and the results to the Department by January 17, 2008. SE 43 Behavioral Interventions Partially Implemented Document review, staff interviews New Issue Identified According to document review and staff interviews, the school uses a variety of means to assist students whose behavior impede their learning or the learning of others, such as counseling services, functional behavioral assessments, and behavioral plans. However, according to staff interviews, the Kinder Program does not make referrals to the Family and Student Support Team (FASST) to address the needs of Kindergarten students whose behavior interferes with their learning or the Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 9 of 33 Please provide training on the use of the DCAP and the FASST to staff in the Kinder Program, and include the name of the trainer, the date of the training, the signatures of the participants, and copies of the materials used. Following the training, please provide documentation that demonstrates that Kinder Program students have been referred to FASST to address their needs when their behaviors are interfering with learning. Provide the training documentation to the Department by October 18, 2007. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 48 FAPE Implemented Document review, staff interviews The school’s student schedules demonstrate that all students with disabilities, including students in substantially separate classrooms, are provided with opportunities to participate in the general education classroom. SE 49 Related Services Implemented Student records, staff interviews, document review According to documentation and staff interviews, Boston Renaissance has a staff of four to provide counseling services to students, including two social workers and two school psychologists. Student records demonstrated that students with behavioral needs had counseling services on their service delivery grids. Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting learning of others. Provide the documentation demonstrating that Kinder Program students are being referred to the FASST by January 17, 2008. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 10 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 54 Professional Development Implemented Document review, staff interviews Documentation and staff interviews demonstrated that training is provided to regular education staff on special education laws and regulations and on accommodating the diverse learning needs of students within the general education setting. SE 56 Program Evaluation Implemented Document review, staff interviews The school’s documentation demonstrated that the special education administrator has developed various methods for determining the effectiveness of its special education programs. A teacher’s concerns survey, a parent’s informational survey, and an MCAS data analysis for students with IEPs in the school. MOA 1 Identification of Limited English Proficient Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance See comments under ELE 3, below. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 11 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification MOA 2 Program Modification MOA 4 Disproportion ality Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance See comments under ELE 5, below. Implemented Document review, staff interviews To respond to the school’s citation of non-compliance in 2003 regarding its higher disproportionate number of male students in substantially separate classrooms because of behavioral issues, Boston Renaissance provided an analysis of its placement of the 11 students – 9 male, 2 female – currently in the school’s substantially separate classrooms. According to the school’s analysis and staff interviews, 10 of these students have gone through the school’s continuum of resources until it was determined that a substantially separate was the most appropriate setting for the student. One student entered the school with an IEP calling for a Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 12 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Not Effective Boston Renaissance Charter School was cited in 2003 for not translating general information into the various languages spoken by parents in the charter school. The school must develop a paragraph translated into the languages represented by the school’s community to inform families that they have the right to request translated documents. This paragraph must be disseminated in key documents of the school, such as the school’s Code of Conduct and Family and Student Handbook. The school must ensure that it translates such documents when requests are received from members of the school community. substantially separate placement. MOA 7 Translations Partially Implemented Student records, document review Documentation for this criterion demonstrated that only certain English Language Education documents have been translated into the primary languages of the school (e.g., parent information letter, waivers). This criterion also requires that when persons with limited English language skills reside in the community, school recruitment and promotional materials must be disseminated to Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 13 of 33 The school must ensure translations are made available in the languages representing the school ’s community. Please provide samples of recruitment materials translated into languages that represent the school’s community, such Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting them in their primary language(s). as Spanish, Cape Verdean, French Haitian Creole, Vietnamese, Chinese, and Jamaican Creole. Additionally, at the request of a parent or student whose primary language is not English, a student handbook or student code of conduct must be translated into that language. See additional comments under SE 29. Provide the name(s) of the agency or company that the school will use for translating key school documents. Provide a translated paragraph for key school documents and describe a dissemination process to distribute this information. Provide the above to the Department by October 18, 2007. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 14 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Special Education Criteria created or revised in response to IDEA-2004 SE 6 ##1 - 3 Determination of Transition Services Not applicable Boston Renaissance Public Charter School is a K-8 school. SE 8 IEP Team composition and attendance Implemented Student record review, staff interviews The school has a team member excusal process in keeping with the requirements of IDEA 2004. According to the student record review, Teams were appropriately constituted, with key service providers and general education teachers in attendance at the meetings. SE 12 Frequency of re-evaluation Implemented Student record review, staff interviews Student records demonstrated that the school conducts reevaluations every three years unless the parent and school agreed that it was not necessary. The school also re-evaluates before finding a student no Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 15 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting SE 13 Progress Reports and content Implemented Student record review, staff interviews longer eligible for special education and before removing a service. The school is meeting the requirements for issuing progress reports consistent with the school’s report cycle. *Please note that recently enacted IDEA-2004 regulations have now changed the content requirements for IEP progress reports. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department has changed the progress report form and it is now available on the Department’s Special Education website at: http://www.doe.mass.edu/sped/i ep/eng_toc.html. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 16 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification SE 14 Review and revision of IEPs Partially Implemented Student record review 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 According to student record review, the charter school uses the amendment procedure to change student placements. Please review the appropriate use of amendment procedures with staff responsible for the development and issuing of the IEP. Please identify the trainer, date of training and staff in attendance to the Department by October 18, 2007. The amendment procedure may only be used to change a placement if all other aspects of the current IEP remain unchanged. SE 25B Resolution of disputes Not Implemented Document review Not Implemented The school is obliged to develop a means to resolve disputes with parents who have filed a hearing request with the BSEA. Within 15 days of receiving notice that a Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 17 of 33 Please conduct a follow-up review of student records for use of the amendment procedure post–training for a 3-month period and report the results of this review, along with any corrective actions, to the Department by January 17, 2008. Please develop a dispute resolution process for parents who have made a hearing request with the BSEA, or provide the documentation demonstrating the school has such a procedure if needed. Provide this documentation to parent has made an official hearing request to Special Education Appeals, the district or school convenes a meeting with the parent(s) and the relevant member(s) of the IEP Team, including a representative of the district with decisionmaking authority, to try to resolve the dispute. The resolution session may be waived if the district and the parents agree in writing to do so or if they agree to use mediation instead. If the dispute is resolved at the resolution session, the parent(s) and a representative of the district with the authority to do so sign a legally binding agreement, enforceable in state or federal court. Any party may void this agreement within three business days of the signing SE 33 Involvement in the General Curriculum Implemented Document review, staff interviews The school’s student schedules demonstrate that students, including all students with disabilities, are provided with opportunities to participate in the general education classroom Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 18 of 33 the Department by October 18, 2007. and all classes are taught using curricula that is based on the Massachusetts Curriculum Frameworks. In addition, IEP Teams consistently had at least one general education teacher who was familiar with the general curriculum in attendance. SE 39A Procedures for services to eligible private school students whose parents reside in the district Not applicable Boston Renaissance Public Charter School is a charter school and is therefore not required to provide services to eligible private school students whose parents reside in the district. SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Not applicable Boston Renaissance Public Charter School is a charter school and is therefore not required to provide services to eligible students enrolled in private schools whose parents reside out of state. SE 46 Procedures for suspension of students with Partially Implemented Document review, staff interviews New Issue Identified Document review indicated that the Kinder Program has a policy of sending students home Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 19 of 33 Please revise the school’s suspension policies to include the send-home category of student exclusions in the disabilities more than 10 days from school if the student is not responsive to other forms of discipline. This is a form of exclusion and therefore must be coded as a suspension in the school’s disciplinary database. For students who are identified or suspected of having a disability, the student must be provided with due process rights after the 10th send-home. Kinder program as a form of suspension that must be counted toward 10 days for a student identified or suspected of having a disability. Provide training to appropriate staff on this revised policy. Submit the revised policy and evidence of the staff training, including date and time of training and signed attendance sheet, to the Department by October 18, 2007. The Head of School or his/her designee should conduct a review of the school discipline logs to ensure that this type of suspension is being recorded, beginning with suspensions recorded in September 2007 and ending in December 2007. Please provide the results of this review to the Department by January 17, 2008. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 20 of 33 Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemente d and Effective Method(s) of Verification Partially Implemented Document review Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements New Issue Identified Although the charter school has appropriate procedures for the suspension of students with disabilities in their special education manual, the school’s student and family handbook does not contain appropriate procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans. Please include a description of the procedures for the discipline and suspension of students with disabilities and students on 504 plans in the student and family handbook beginning with the 2006-2007 school year. According to staff interviews, kindergarten students’ cases are not presented to the FASST when their behavior interferes with learning. See corrective action under SE 43. Civil Rights (MOA) and Other General Education Requirements MOA 10A Student handbooks and codes of conduct MOA 18 Responsibilities of the school principal Partially Implemented Staff interviews, document review New Issue Identified Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 21 of 33 Provide a copy of this page (or of the 2006-2007 Student Handbook) to the Department by October 18, 2007. Other Regulated Programs Monitored During this Midcycle Review Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) SE 25A Notice to BSEA Approved Corrective Action Implemente d and Effective Method(s) of Verification Partially Implemented Student record review Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements New Issue Identified Student records indicated that when parents fail to sign proposed IEPs, the charter school does not send the IEP to the BSEA as a rejected IEP. Please develop a procedure for documenting the multiple attempts used by the school to obtain parent signatures on proposed IEPs prior to sending the unsigned IEP to the BSEA. Provide training to the appropriate staff on this procedure. Submit the procedure and evidence of the training to the Department by October 18, 2007. Please conduct a follow-up review of student records for evidence of documentation of multiple attempts to secure parent signatures and sending the unsigned IEP to the BSEA, for a three month period following training and report the results of this review, along Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 22 of 33 with any corrective actions, to the Department by January 17, 2008. SE 29 Communications are in English and primary language of home Partially Implemented Student record review See additional comments under MOA 7. Boston Renaissance Charter School was cited in 2003 for not translating general information into the various languages spoken by parents in the charter school. Please provide training to appropriate staff regarding the need for translation of IEP forms, notices and related documents for families whose primary language is not English. According to student records, although the charter school provides an interpreter at IEP meetings, the school does not provide special education documents in the primary language of the parent. Provide evidence of the training, including signed attendance sheets, when the training was held, the name of the presenter, and examples of training materials to the Department by October 18, 2007. Please describe the procedures the school will follow to document the parent/guardian need for translation and how the school will obtain written translations. Provide this description to the Department by October 18, 2007. Randomly select examples of N1s, IEPs, N3s, etc., for up to 10 families who have indicated that they require student documents translated Please provide the above to the Department by January 17, 2008. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 23 of 33 SE 32 Special Education Parent Advisory Council Partially Implemented Staff interviews New Issue Identified According to staff interviews, the school does not currently have an active special education parent advisory council. Please provide other recruiting materials and communications sent to prospective SPED PAC members as part of the active recruitment for the council. The school is obliged to initiate and maintain a special education advisory council, including actively recruiting parents of students on IEPs; providing by-laws regarding officers and operational procedures for parents to consider; providing at least one workshop annually on the rights of students and their parents and guardians under the state and federal special education laws; and providing opportunities for the council to advise the development of special education services, as well as evaluate them. Establish a date for the training on the rights of students and parents under the state and federal special education laws and submit these to the Department by October 18, 2007. If the school has already provided the training, submit evidence of the meeting, including the date and time, name of presenter, examples of materials used in the presentation, and a signed attendance sheet. Please submit the school’s SPED PAC’s responsibilities and model by-laws regarding officers and operational procedures for parents to consider, including the opportunities for this council to advise the development of special education services, as well as evaluate these services. Please provide these materials to the Department October 18, 2007. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 24 of 33 BOSTON RENAISSANCE PUBLIC CHARTER SCHOOL English Learner Education (ELE) Requirements Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 1 Annual Assessment Implemented ELE 2 MCAS Participation Implemented ELE 3 Initial Identification Partially Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Boston Renaissance Charter School did not provide translated Home Language Survey in the major languages represented in the school community other than Spanish. Additionally, the charter school provided a list that pre-dated the 2003 CPR of the names and qualifications of persons implementing procedures and assessments. Required Corrective Action, Timelines for Implementation, and Progress Reporting In addition to Spanish, the school must provide translated Home Language Surveys into major languages represented in the school community, such as Cape Verdean, French Haitian Creole, Vietnamese, Chinese, and Jamaican Creole. Please provide a current list of the names and qualifications of persons implementing procedures and assessments. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 25 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting Provide this documentation to the Department by October 18, 2007. ELE 4 Waiver Procedures Partially Implemented According to documentation provided by the school, Boston Renaissance Charter School does not have written guidelines for waiver and opt-out procedures. The school must provide written guidelines for waiver and opt out procedures to the Department by October 18, 2007. ELE 5 Program Placement and Structure Partially Implemented The charter school stated that it will establish “a modified SEI classroom,” but did not provide a description of what a “modified” SEI program might be. Further, the school has not adapted the content curricula for sheltered content classrooms based on the Massachusetts Curriculum Frameworks. According to documentation, several teachers have received training this year (2006-2007) in sheltering content. The charter school must implement a program structure for Sheltered English Immersion in the school that conforms with the requirements of M.G.L. c. 71A. In addition, regardless of the program model, the school must provide direct English language development (ELD) instruction that is based on the English Language Proficiency Benchmarks and Outcomes. Direct English language instruction is the process by which students identified as LEP are taught English and must be taught by a teacher certified or licensed in ESL or ELL. Special education reading services and DCAP or Title 1 reading services are not ELD. None of the charter school staff are certified in ESL or ELE to teach direct English instruction. Additionally, it is not clear from the school’s description of its services whether students are provided with ELD. Please note that for kindergarten students, either a sheltered English immersion, two-way bilingual, or an English-only language general education classroom with assistance in English language acquisition, including, but not limited to, ESL, can be provided. The charter school must adapt the content curricula based on the Massachusetts Curriculum Frameworks for sheltered content classrooms. Additionally, the school must ensure that an individual certified in direct English instruction or English as a Second Language instruction and a curriculum based on the English Language Proficiency Benchmarks and Outcomes (ELPBO) are available to teach LEP students. The school must describe how this will be achieved, for example through certification of an existing faculty member or hiring a certified ESL teacher. Provide a detailed narrative description of the specific steps taken to comply with these requirements to the Department by October 18, 2007. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 26 of 33 ELE Criterion Number and Topic ELE 6 Program Exit and Readiness ELE 7 Parent Involvement Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting Implemented Partially Implemented Providing a list of parents’ names whose children have been referred to special education is not sufficient to demonstrate that the school has developed a means to involve LEP parents into the school community, particularly when the school has not translated IEPS, handbooks, announcements and other key school documents to encourage LEP parent participation. Please develop and/or document the multiple opportunities and a variety of methods for parentteacher communication of LEP students to the Department by October 18, 2007. Parent involvement may be through the development of a parent advisory council on English language education, through membership on a school-based council, or through other means determined by the district. The school should provide multiple opportunities and a variety of methods for parent-teacher communication. ELE 8 Declining Entry to a Program Partially Implemented According to the charter school’s submitted policies for this criterion, when parents opt out of ELL programming for their LEP students, the school places those students in SEI classrooms anyway because all of the school’s classrooms have regular education and ELL students assigned together. While an opted-out student should be placed in a general education classroom, the school should encourage parents to allow their children in ELE programs for a limited time. According to federal guidance, LEP students need to have their English language and academic needs met by providing them with adequately trained teachers – which a teacher fully trained in sheltering content would meet. Additionally, The charter school must revise its’ policies and procedures to ensure that implementation practices regarding students whose parents have declined entry to an ELL program are in compliance with regulations, particularly in the area of follow-up monitoring and support for opted-out students who are not progressing well without an ELE program. The charter school must submit the revised policies and procedures to the Department by October 18, 2007. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 27 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting the school is obliged to monitor the student’s progress and provide support to the student if s/he is not succeeding without an ELE program. ELE 9 Instructional Grouping Partially Implemented According to documentation provided by the school, ELE students are grouped by grade level/age in general education classes. However, it is not clear from the school schedules of LEP students whether the school provides direct English language instruction. Please describe how students will be grouped instructionally in English language development classes in the narrative description of the ELL program as part of fulfilling the criterion ELE 5 (see above). ELE 10 Parental Notification Partially Implemented With the exception of explaining the parents’ right to apply for a waiver or to decline to enroll their child in the program, the charter school does not have an appropriate notice for parents or guardians written in the primary/home language as well as English. The charter school does not inform parents of: a) The reasons for identification of the student as Limited English Proficient (LEP); b) The child’s level of English proficiency; c) Program placement and/or the method of instruction used in the program; d) How the program will meet the educational strengths and needs of the student; e) How the program will specifically help the child learn English; f) The specific exit requirements The charter school must provide an appropriate notice for parents or guardians written in the primary/home language as well as English. The charter school must inform parents of: a) The reasons for identification of the student as Limited English Proficient (LEP); b) The child’s level of English proficiency; c) Program placement and/or the method of instruction used in the program; d) How the program will meet the educational strengths and needs of the student; e) How the program will specifically help the child learn English; f) The specific exit requirements. The charter school must submit the revised notice and five samples of notices sent to parents to the Department by October 18, 2007. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 28 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting Partially Implemented The charter school did not provide evidence that students have access to support services, such as guidance and counseling, in a language that they understand. Please describe or develop a means to provide students with support services, such as counseling, in languages that student understand, and provide this documentation to the Department by October 18, 2007. ELE 12 Equal Access to Nonacademic and Extracurricular Programs Partially Implemented According to submitted documentation, all Boston Renaissance Charter School students receive the same communications regarding access to programs and services. However, at this time the school does not have any announcements translated into students’ native languages. Provide a narrative detailing the specific means and methods the school will use to provide parents of LEP students with access to translated notices and announcements. ELE 13 Follow-up Support Partially implemented ELE 11 Equal Access to Academic Programs and Services ELE 14 Licensure Requirements In addition, the school’s documentation states that parents have access to the annual report and to the website; however these resources are in English only. Not implemented Provide this documentation to the Department by October 18, 2007. According to documentation provided by the school, students are monitored for at least two years following their designation of FLEP. However, one FLEP student’s monitoring demonstrated that he was struggling with ELA and math but that it was not “language-related.” There was no indication as to how the person monitoring this student had arrived at this conclusion. Further support for this student was not indicated, e.g., additional language assessments, special education evaluation, FASST referral, etc. Please provide a detailed description of how the school provides language support services to those students designated as FLEP who are not successful following their re-designation. No staff members have ESL or ELL certifications or waivers, and nothing in the teacher evaluation process addresses ELE. The charter school must provide evidence of staff with ESL or ELL certifications and/or waivers to the Department by October 18, 2007. Provide this description plus examples of students who have been exited and unsuccessful (such as DG) and how the school has addressed their needs, to the Department by October 18, 2007. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 29 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 15 Professional Development Requirements Partially Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The charter school has initiated professional development for some teachers, but has not outlined a comprehensive professional development plan. Required Corrective Action, Timelines for Implementation, and Progress Reporting Develop a comprehensive professional development plan that provides training opportunities to teachers of LEP students to ensure the progress of LEP students in developing oral comprehension, speaking, reading, and writing of English, and in meeting academic standards. The charter school must provide their plan to the Department by October 18, 2007. ELE 16 Equitable Facilities Implemented ELE 17 Program Evaluation Not implemented For program evaluation, the charter school submitted a table that summarizes the Department’s Coordinated Program Review and the Department’s Review of their Corrective Action Plan. The charter school must conduct periodic evaluations on the effectiveness of its ELE program in developing students’ language skills and increasing their ability to participate meaningfully in the educational program. Where the school documents that the program is not effective, it must take steps to make appropriate program adjustments or changes that are responsive to the program evaluation. One part of the charter school’s evaluation activities should consist of using the English language proficiency data of its ELE students individually and in the aggregate to determine the effectiveness of its various ELE program models. Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 30 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting The Department strongly recommends that the charter school seek technical assistance from OLAAA in developing and implementing an appropriate and effective program evaluation. ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Boston Renaissance Public Charter School Coordinated Program Review Mid-cycle Report August 14, 2007 Page 31 of 33