Massachusetts Department of
Elementary and Secondary Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
April 14, 2008
Dr. Curtis Bates, Superintendent
Boxborough Public Schools
493 Massachusetts Avenue
Boxborough, MA 01719
Re: Mid-cycle Report
Dear Dr. Bates:
Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report.
This report contains findings based on onsite monitoring the Department conducted to
determine the effectiveness of corrective action it approved or ordered to address
noncompliance identified in your district’s last Coordinated Program Review Report,
dated August 11, 2005. 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.
While the Department of Elementary and Secondary Education found your district to
have resolved most noncompliance issues, others were partially corrected, or the
Department’s onsite team identified new issues of noncompliance, including but not
limited to noncompliance with special education criteria added or substantially changed
in response to IDEA 2004. Where the district has failed to implement its Coordinated
Program Review Corrective Action Plan, the Department views these findings to be
serious. The Office of Special Education Programs of the U.S. Department of Elementary
and Secondary Education requires that all special education noncompliance be corrected
as soon as possible, but in no case later than one year from the time of identification;
where the district has failed to implement its CPR Corrective Action Plan, this one-year
period has long since passed.
In all instances where noncompliance has been found, the Department has prescribed
corrective action for the district that must be implemented without delay. (In the case of
new findings of noncompliance, this corrective action must be corrected 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 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 in the report. You must
submit your statement of assurance to me by April 30, 2008.
1
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 781338-3755.
Sincerely,
Michelle Griffin, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
Jeffrey Nellhaus, Acting Commissioner of Elementary and Secondary Education
Rebecca Neville, School Committee Chairperson
Dr. Sandra Daigneault, District Program Review Follow-up Coordinator
Teresa Watts, Collaborative Director
Encl.: Mid-cycle Report
2
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY
EDUCATION
MID-CYCLE REPORT
BOXBOROUGH PUBLIC SCHOOLS
Date of Coordinated Program Review (CPR) Final Report: August 11, 2005
Date Coordinated Program Review Corrective Action Approved or Ordered: February 17, 2006
Dates of Corrective Action Plan Progress Reports: May 10, 2006, July 3, 2006, October 17, 2006, January 22, 2007, March 5, 2007, June 12, 2007
Dates of this Mid-cycle Review Onsite Visit: February 28 and 29, 2008
Date of this Report: April 14, 2008
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Special Education Criteria Cited in CPR Report and Monitored in Mid-cycle
Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 9
Eligibility
Determination/
Timelines
√
Record review
Interviews
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
Interviews and record review
indicate that within forty-five
school working days after
receipt of the parent's written
consent to an initial evaluation
or a re-evaluation, the school
district determines whether the
student is eligible for special
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 1 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 18B
Placement/
Provision of
IEP
√
Record review
Interviews
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
education and provides to the
parent either a proposed IEP
and (except in cases covered
by 603 CMR 28.06(2)(e))
proposed placement or a
written explanation of the
finding of no eligibility.
Record review indicates that
upon determining that the
student is eligible for special
education, the Team, including
the parent(s), develops an IEP
at the Team meeting.
Record review also indicates
that the IEP is completed
addressing all elements of the
most current IEP format
provided by the Department of
Elementary and Secondary
Education.
Interviews and records indicate
that the school district ensures
that the IEP will not be
changed at a higher
administrative level within the
district.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 2 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 22
IEP
implementation
and availability
√
Documentation
Record review
Interviews
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
Interviews indicate that parents
are provided with a Team
meeting summary sheet, and
that liaisons keep copies of the
summary sheets, but do not file
them in the student’s main
special education file. The
district remedied this while the
Department was on-site by
immediately issuing an e-mail
to all special education liaisons
that the summary sheets must
be kept as part of the student
record, and requiring the
summary sheets to be sent to
the central office for filing.
Interviews and documentation
indicate that where the IEP of a
student in need of special
education has been accepted in
whole or in part by that
student's parent, the school
district provides the mutually
agreed upon services without
delay.
Record review, documentation
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 3 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
and interviews indicate that at
the beginning of each school
year, the district has an IEP in
effect for each eligible student
within its jurisdiction.
Documentation and interviews
indicate that special education
liaisons ensure that each
teacher and provider described
in the IEP is informed of his or
her specific responsibilities
related to the implementation
of the student’s IEP and the
specific accommodations,
modifications, and supports
that must be provided for the
student under it.
SE 24
Notice to
Parent
√
Interviews
Record review
Interviews indicate that the
school district does not delay
implementation of the IEP due
to lack of classroom space or
personnel.
Interviews indicate that when a
student is referred for an
evaluation to determine
eligibility for special
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 4 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
education, the school district
sends written notice to the
child's parent(s) within five
school days of receipt of the
referral, along with the
district’s notice of procedural
safeguards. The written notice
meets all of the content
requirements set forth in
M.G.L. c.71B, §3, and in
federal law, seeks the consent
of the parent for the evaluation
to occur, and provides the
parent with the opportunity to
express any concerns or
provide information on the
student’s skills or abilities and
to consult regarding the
evaluators to be used. For all
other actions, the district gives
notice complying with federal
requirements within a
reasonable time.
In addition, record review
indicates that the school district
provides the student's parent(s)
with an opportunity to consult
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 5 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
with the Special Education
Administrator or his/her
designee to discuss the reasons
for the referral and the nature
of the proposed evaluation.
√
SE 25
Parent consent
Record review
Interviews
Interviews and record review
indicate that the school district
does not limit a parent’s right
to refer a student for timely
special education evaluation
because the district has not
fully explored and/or attempted
some or all of the available
instructional support programs
or other interventions available
in general education that may
be described in the district’s
curriculum accommodation
plan, including any pre-referral
program.
Interviews and record review
indicate that in accordance
with state and federal law, the
school district obtains
informed parental consent at all
required junctures.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 6 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 27
√
Record review
Content of
Team meeting
notice to
parents
SE 28
√
Documentation
Parent
provided the
IEP or notice
of no eligibility
together with
notification of
procedural
safeguards and
parents' rights
SE 29
Communications in
English and
Primary
Language
of Home
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
Record review indicates that
parent notices of any Team
meeting state the purposes,
times and locations of the
meetings, as well as who will
be in attendance.
See SE 24 and 18B.
Record review
Interviews
√
Record review
Interviews
Documentation
Record review and interviews
indicate that the district
informs parents that translation
of special education
documentation is available, and
that even where parents have
declined, the district has
translated some
documentation. The district
states that it will continue to
offer parents with limited
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 7 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
English proficiency
translations in the native
language. Record review
indicates that IEPs are in
simple and commonly
understood words and are in
both English and the primary
language of the home if such
primary language is other than
English.
The district reports that it has
not had occasion to use
interpreters in fulfilling these
requirements.
Documentation and interviews
indicate that the district would
ensure that if the parents or the
student are unable to read in
any language or are blind or
deaf, communications required
by these regulations are made
orally in English with the use
of a foreign language
interpreter, in Braille, in sign
language, via TTY, or in
writing, whichever is
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 8 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 32
Parent
advisory
council for
special
education
Partial
Documentation
Interviews
appropriate, and all such
communications would be
documented. Interviews
indicate that the district has not
recently had to provide notices
orally or in some other mode of
communication that is not
written language.
Documentation and interviews
indicate that the school district
has established a district-wide
parent advisory council on
special education, and that
membership on the council is
offered to all parents of
children with disabilities and
other interested parties.
Documentation indicates that
the parent advisory council
duties include but are not
limited to: advising the district
on matters that pertain to the
education and safety of
students with disabilities;
meeting regularly with school
officials to participate in the
planning, development, and
evaluation of the school
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
Partial
The school district did not
conduct, in cooperation
with the parent advisory
council, the annual
workshop on the rights of
students and their parents
and guardians under the
state and federal special
education laws.
Conduct, in cooperation with
the parent advisory council,
the annual workshop within
the district on the rights of
students and their parents and
guardians under the state and
federal special education
laws. Provide evidence of the
above by May 30, 2008.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 9 of 35
Submit written assurance that
the required workshop will be
provided annually hereafter,
as well as the date of the
workshop scheduled for the
2008-2009 school year, by
December 15, 2008.
Criterion
Number/Topic
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
district’s special education
programs. Documentation
indicates that the parent
advisory council has
established by-laws regarding
officers and operational
procedures.
Documentation indicates that
the parent advisory council
receives assistance from the
school committee without
charge, upon reasonable notice,
and subject to the availability
of staff and resources. The
district director of pupil
services is very active in the
PAC, and the PAC has offered
a number of workshops on
various topics for parents of
students with disabilities.
Interviews and documentation
indicate that the district has
created with staff and PAC
parents a “Handbook for
Parents and Guardians of
Children in Special
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 10 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 37
Procedures for
approved and
unapproved
out-of-district
placements
√
Documentation
Record Review
Interviews
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
Education,” that includes
information about the
programs and services
available for special education
students in the district. This
handbook has been sent to all
parents of students on IEPs,
and is provided to parents of
students referred for a special
education evaluation.
Record review, documentation,
and interviews indicate that the
school district monitors the
provision of services to and the
programs of individual
students placed in public and
private out-of-district
programs. Evidence of
monitoring and documentation
of site visits by the
administrator of special
education were seen in the files
of out-of-district students
selected for review.
Documentation and student
records indicate that the school
district retains full
responsibility for ensuring that
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 11 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
the student is receiving the
special education and related
services in the student's IEP, as
well as all procedural
protections of law and
regulation. In addition,
documentation and record
review indicate that the school
district enters into
appropriately written contracts
with all public and private outof-district placements, and
contracts meet the content
requirements of 603 CMR
28.06(3)(f)(1-5).
SE 51
Appropriate
special
√
Documentation
The district does not currently
have any students placed in
placements that are not
approved by the Department;
however, the district is aware
of the requirements of placing
students in unapproved
programs.
The district submitted
documentation of teacher
certification. All individuals
who design and/or provide
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 12 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Professional
development
regarding
special
education
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
Partial
Interviews indicate that
professional and
paraprofessional staff
inconsistently receive all
of the required trainings
listed in this criterion.
Some staff have received
training on special
education laws and
regulations and meeting
the diverse learning needs
of students, which was a
district initiative in years
past. However,
interviews indicate that
these trainings are not
mandatory for all staff.
Conduct a review to
determine which staff in the
district have not received the
training mandated by this
criterion. Provide a report of
this review by May 30, 2008.
direct special education
services described in IEPs are
appropriately licensed.
education
teacher
certification
SE 54
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Partial
Documentation
Interviews
Interviews and documentation
indicate that while the district
conducts a great deal of
professional development, the
district has not ensured that all
staff receive the required
trainings.
Interviews and documentation
indicate that the district
provides or ensures the
provision of in-service training
for all locally hired and
contracted transportation
providers, before they begin
transporting any special
education student receiving
special transportation, on his or
her needs and appropriate
methods of meeting those
needs; for any such student the
district also provides written
information on the nature of
any needs or problems that
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 13 of 35
The district must provide
training to all staff who have
not received training on the
following:
a. state and federal special
education requirements
and related local special
education policies and
procedures;
b. analyzing and
accommodating diverse
learning styles of all
students in order to
achieve an objective of
inclusion in the regular
classroom of students
with diverse learning
Criterion
Number/Topic
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
may cause difficulties, along
with information on
appropriate emergency
measures, where necessary.
Interviews indicate that the
district uses CASE
Collaborative transportation,
and that the collaborative
provides the training to its
transportation providers.
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
styles;
c. methods of
collaboration among
teachers,
paraprofessionals and
teacher assistants to
accommodate diverse
learning styles of all
students in the regular
classroom.
Provide agendas, training
materials, and signed
attendance sheets (including
identification of staff role) by
December 15, 2008.
SE 55
Special
education
facilities and
classrooms
√
Observation
Observation indicates that all
special education instructional
spaces, including those
provided to the CASE
Collaborative classroom
housed in the district,
maximize the inclusion of such
students into the life of the
school, provide accessibility in
order to implement fully each
child’s IEP, and are at least
equal in all physical respects to
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 14 of 35
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 56
Special
education
programs and
services are
evaluated
MOA 1/ELE 3
Identification
of limitedEnglishproficient
students
√
Documentation
Interviews
√
Documentation
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
the average standards of
general education facilities and
classrooms. These
instructional spaces are given
the same priority as general
education programs in the
allocation of instructional and
other space in public schools in
order to minimize the
separation or stigmatization of
eligible students. No special
education instructional spaces
observed were identified by
signs or other means that
stigmatize such students.
Documentation and interviews
indicate that special education
programs and services are
regularly evaluated.
Documentation submitted
concerning criterion ELE 3
(formerly MOA 1) indicates
that the district has appropriate
procedures for identification of
limited English proficient
students. A home language
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 15 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Placement of
female students,
male students,
homeless
students,
students with
disabilities, and
students from
linguistic and
racial/ethnic
groups
MOA 6 / CR 6
Availability of
Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
survey is administered to all
incoming students, and when a
student’s home language
survey indicates a primary
language other than English,
appropriate assessments are
provided to students in reading,
writing, speaking and listening.
See ELE 11 below.
MOA 2/ELE 5
Programs
Modifications
and Support
Services for
LEP students
MOA 4 / CR 4
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Not Monitored
in the Midcycle Review
√
The district remedied the issues
identified in the last
Coordinated Program Review
per the Department’s review of
progress reports dated July 17,
2006.
Documentation
Documentation indicates that
the district has an appropriate
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 16 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

in-school
programs for
pregnant
students
MOA / CR
10A
Handbooks
and codes of
conduct
√
Documentation
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
policy concerning the
availability of in-school
programs for pregnant
students.
Documentation and interviews
indicate that the district has a
code of conduct for students
and one for teachers. Student
handbooks are distributed
annually to staff, parents and
students. Interviews indicate
that translation of handbooks
has not been necessary,
however, if translation did
become necessary, the district
would ensure that it was
completed.
The student code of conduct
contains appropriate content.
Specifically, the current code
of conduct:
 contains procedures
assuring due process in
disciplinary proceedings;
 contains appropriate
procedures for the
discipline of students with
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 17 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
special needs and students
with Section 504
Accommodation Plans;
references M.G.L. c. 76, s.
5 and contains a
nondiscrimination policy
that is consistent with
M.G.L. c. 76, s. 5, and
affirms the school’s nontolerance for harassment
based on race, color,
national origin, sex,
religion, or sexual
orientation, or
discrimination on those
same bases;
contains the school’s
procedure for accepting,
investigating and
resolving complaints
alleging discrimination or
harassment; and
contains the disciplinary
measures that the school
may impose if it
determines that
harassment or
discrimination has
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 18 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
occurred.
MOA / CR
11A
√
Documentation
Interviews
Designation of
coordinator(s);
grievance
procedures
MOA /CR 12A
Annual and
continuous
notification
concerning
nondiscrimination and
coordinators
√
Documentation
Interviews
Documentation indicates that
the district has designated one
or more staff persons to serve
as coordinator(s) for
compliance with its
responsibilities under Title IX,
Section 504, and Title II, and
that the district has adopted
and published grievance
procedures for students and for
employees providing for
prompt and equitable
resolution of complaints
alleging discrimination based
on sex or disability.
Documentation and interviews
indicate that the district takes
continuing steps to notify
members of its community that
it does not discriminate on the
basis of race, color, national
origin, sex, or disability.
Information is provided about
the person designated to
coordinate compliance under
Title IX and Section 504.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 19 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

MOA / CR 14
Counseling
and counseling
materials free
from bias and
stereotypes
√
Documentation
Interviews
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
Documentation indicates that
written materials and other
media used to publicize the
school include a notice that the
school does not discriminate on
the basis of race, color,
national origin, sex, disability,
religion, or sexual orientation.
Documentation and interviews
indicate that the district has
appropriate methods of
ensuring that counseling and
counseling materials are free
from bias and stereotypes on
the basis of race, color, sex,
religion, national origin, sexual
orientation, disability, and
homelessness.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 20 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
√
Documentation
MOA / CR 23
√
Observation
Documentation submitted by
the district includes school
committee policies entitled
Equal Educational
Opportunity, and Staff
Recruitment, both of which
contain appropriate content
consistent with this criterion.
The district also submitted
several samples of
advertisements for open
positions, all of which contain
appropriate indications that the
district is an “Equal
Employment Opportunity”
employer.
See SE 55.
Comparability
of facilities
MOA / CR 24
√

MOA / CR
18A
School district
employment
practices
Curriculum
review process
Documentation
Interviews
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
The district submitted
documentation of the school
committee’s “Instructional
Materials” and “Textbook
Selection and Adoption”
policies, which address
elements of this criterion. The
district also submitted
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 21 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

MOA / CR 25
Institutional
SelfEvaluation
√
Documentation
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
completed “review of
curricular materials” forms
indicating that staff regularly
review curriculum for bias and
stereotypes.
The district submitted a
statement that the
administration has completed
an annual institutional selfevaluation, most recently in
July 2007. The evaluation
consisted of a complete review
of the following programs by
administrators to ensure that no
bias or stereotyping existed
within them:
 Assignment to
homeroom classrooms
 Reading support
program
 Mathematics support
program (partially
funded by Title I)
 Counseling services
 Before/after school
academic support
programs
 Extracurricular
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 22 of 35
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
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
activities
Field trips
Extended day
programs
Prereferral/referral
processes
Accommodations
Paraprofessional
support.
Special Education Criteria Created or Revised in Response to IDEA-2004
Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
Criterion
Method(s) of
Basis of Determination that
Criterion
Basis of Determination
Required Corrective Action,
Implemented Verification
Number
Criterion was Implemented
Partially
that Criterion was
Timelines for

and
Implemented Partially Implemented
Implementation, and
Topic
or Not
or Not Implemented
Progress Reporting
Implemented

√
Documentation
Documentation, record review
SE 3
and interviews indicate that the
Special
Record review
district implements appropriate
requirements for
procedures for determination
determination of
Interviews
of specific learning disabilities.
specific learning
When a student suspected of
disability
having a specific learning
disability is evaluated, the
Team creates a written
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 23 of 35
Criterion
Number
and
Topic
SE 6 ##1 - 3
Determination of
Transition
Services
SE 8
IEP Team
composition and
attendance
Criterion
Implemented

Method(s) of
Verification
Not
Applicable
√
Documentation
Interviews
Record review
Basis of Determination that
Criterion was Implemented
Criterion
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
determination as to whether or
not he or she has a specific
learning disability, which is
signed by all members of the
Team, or if there is
disagreement as to the
determination, one or more
Team members document their
disagreement. The district is
aware of the new forms for
determining specific learning
disabilities, which will be
required next year.
The requirements of this
criterion are not applicable in
this preschool through grade
six district.
Record review indicates that
Team membership is consistent
with regulatory requirements.
The district appropriately sends
a form letter to parents, which
informs parents when it is
expected that staff are unable
to attend Team meetings. The
letter contains a line for parents
to sign indicating their
agreement or disagreement.
Record review indicates that
when staff are excused from
meetings and required to
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 24 of 35
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
SE 12
Frequency of reevaluation
Criterion
Implemented

Method(s) of
Verification
Record review
Partial
Interviews
Basis of Determination that
Criterion was Implemented
submit a report, written reports
were not always seen in
student records. Interviews
indicate that these reports have
not consistently been filed in
the permanent special
education files of students, but
rather, were kept by liaisons.
Before the end of the midcycle review, the director of
pupil services sent a memo to
all special education staff
requiring them to implement
immediately a change in
practice so that these reports
are sent to the director for
inclusion in students’
permanent special education
files.
Record review indicates that
re-evaluations are conducted
when the student’s needs
warrant it or a parent or teacher
requests it. Re-evaluations are
generally conducted
periodically, but not exactly
every three years.
See SE 14.
Criterion
Partially
Implemented
or Not
Implemented

Partial
Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Record review indicates
that re-evaluations are not
always completed every
three years. Delays were
generally not more than
one month.
Develop an internal oversight
and tracking system to ensure
timely completion of all reevaluations, and for
completion of the Educational
Assessment Part A for reevaluations. Provide a
description of the internal
oversight and tracking
system, including person(s)
responsible for the oversight,
by May 30, 2008.
Interviews and record
review indicate that the
district does not complete
the Educational
Assessment Part A for reevaluations.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 25 of 35
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
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Review a sample of student
records in which reevaluations were conducted
after the internal oversight
and tracking system was
developed and implemented.
Submit the following
information:
 Total number of
records reviewed;
 Number of records
which contained
timely re-evaluations;
 Number of records
which contained
completed
Educational
Assessments Part A;
 Specific actions taken
by the district to
remedy any
continuing noncompliance.
Submit the above information
to the Department by
December 15, 2008.
SE 13
Progress Reports
Partial
Record review
Interviews
Record review and interviews
indicate that parents receive
reports on the student's
progress towards reaching the
goals set forth in the IEP at
Partial
Interviews and record
review indicate that
progress reports
inconsistently contain
detailed information on
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 26 of 35
Develop an internal tracking
and monitoring system to
ensure that the content of
progress reports is
appropriate. Submit a
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Criterion
Partially
Implemented
or Not
Implemented

least as often as parents are
informed of the progress of
non-disabled students.
Progress reports are completed
for each goal in students’ IEPs.
Record review
SE 14
Partial
Review and
revision of IEPs
Interviews
Staff interviews indicate that
staff are aware of the
requirements to, at least
annually, on or before the
anniversary date of the IEP,
Partial
Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
the student’s progress
towards reaching the
measurable annual goals
in the IEP. Specifically,
where goals are stated in
measurable terms,
progress reports often
contain general statements
about the student, but do
not reflect the progress
under these measurable
terms. Interviews indicate
that the district special
education staff are aware
of this issue.
description of the tracking
and monitoring system,
including person(s)
responsible for the oversight,
by May 30, 2008.
The district does not
always conduct annual
IEP meetings prior to the
expiration date of the IEP.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 27 of 35
Conduct an internal review of
progress reports to determine
compliance with this
criterion. Submit the
following information:
 Total number of
progress reports
reviewed;
 Number of progress
reports that address
the student’s progress
towards reaching the
goals set forth in the
IEP;
 Specific actions taken
by the district to
remedy any
continuing noncompliance.
Submit this report by
December 15, 2008.
Provide training to all special
education staff concerning
appropriate use of
amendments and ensuring
that annual Team meetings
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
hold a Team meeting to
consider the student’s progress
and to review, revise, or
develop a new IEP or refer the
student for a re-evaluation, as
appropriate. Most records
contained evidence of the
timely scheduling of these
meetings.
Record review indicates that if,
in between annual IEP
meetings the district and parent
agree to make changes to a
student’s IEP, at times the
district documents these
agreements in writing, without
convening a meeting of the
Team.
Criterion
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
In some cases,
amendments were issued
to extend IEP periods,
usually because the
district chose to
coordinate annual review
and re-evaluation meeting
dates in order to avoid
multiple meetings. This
is an inappropriate use of
amendments.
are held prior to the
expiration of the IEP. Provide
evidence of the training,
including agenda, training
materials and signed
attendance sheets by May 30,
2008.
Develop an internal oversight
and tracking system to ensure
timely completion of annual
review Team meetings and
the appropriate use of
amendments. Provide a
description of the internal
oversight and tracking
system, including person(s)
responsible for the oversight
by May 30, 2008.
Review a sample of student
records for students whose
annual review occurred after
the district developed the
tracking system. As to each
review, report the following:
 Total number of
records reviewed;
 Number of records
which contained
timely annual
reviews;
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 28 of 35
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
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting

Number of records
which contained
appropriate use of
amendments;
 Specific actions taken
by the district to
remedy any
continuing noncompliance.
Submit the above information
to the Department by
December 15, 2008.
SE 25B
Resolution of
disputes
SE 33
Involvement in
the General
Curriculum
Documentation
√
√
Interviews
Record review
The district has not yet had
occasion to enter into
agreements to waive resolution
sessions or legally binding
agreements for resolving
disputes. However,
appropriate staff are aware of
the procedures under this
criterion.
Interviews indicate that district
personnel understand the
connection between the
Massachusetts Curriculum
Frameworks and the
expectations of the state for
student performance as well as
understanding the rights of
students with disabilities to be
full participants in the general
curriculum.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 29 of 35
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
Interviews and student record
review indicate that the district
has taken steps to provide
students (including all students
with disabilities) with learning
opportunities consistent with
the state graduation standards.
Interviews and record review
indicate that at least one
member of all IEP Teams is
familiar with the general
curriculum and is able to
discuss an eligible student’s
appropriate access to the
general curriculum.
SE 39A
Procedures for
services to
eligible private
school students
whose parents
reside in the
district
(SE 39A does not
√
Documentation
Record review indicates that
the district documents the
student’s participation in the
general curriculum in the IEP.
Documentation indicates that
the district implements
appropriate procedures in order
to provide services to eligible
students enrolled in private
schools at private expense,
when students’ parents reside
in the district. Documentation
included a completed
proportionate share worksheet
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 30 of 35
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
apply to charter
schools or
vocational
schools)
SE 39B
Procedures for
services to
eligible students
in private schools
in the district
whose parents
reside out of
state
(SE 39B does not
apply to charter
schools or
vocational
schools)
SE 46
Procedures for
suspension of
students with
disabilities more
than 10 days
SE 52
Appropriate
certifications/
licenses or other
credentials –
related service
providers
(to be reviewed
Criterion
Implemented

Not
applicable
Method(s) of
Verification
Documentation
Documentation
√
√
Documentation
Basis of Determination that
Criterion was Implemented
Criterion
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
for a prior school year, and a
statement that the district
currently does not serve any
students under this criterion.
The district submitted a
statement that there are no
private schools in the district;
therefore, this criterion is not
applicable at this time.
Documentation indicates that
the district has appropriate
procedures for the suspension
of students with disabilities for
more than ten days. See MOA
10A.
The district submitted
documentation indicating that
all individuals who provide
related services are
appropriately certified,
licensed, board-registered or
otherwise approved to provide
such services by the relevant
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 31 of 35
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
only with respect
to providers of
interpreting
services)
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
professional standards board or
agency for the profession.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 32 of 35
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
SE 18A
Partial
Record review
IEP development
and content
Basis of Determination that
Criterion was Implemented
Record review indicates that in
general, IEPs are developed
appropriately and address all
elements of the most current
IEP format provided by the
Department of Elementary and
Secondary Education.
Criterion
Partially
Implemented
or Not
Implemented

Partial
Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Record review indicates
that in some cases,
placement pages (PL1)
did not correspond with
the amount of IEP
services set forth on the
service delivery grid.
Specifically, the
placement types on the
placement pages that
accompanied IEPs did
not appropriately
correspond with the
percentages of time
during which students
were removed from the
general education
program for IEP
services.
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Provide training to all staff on
appropriate completion of IEP
placement pages. Provide
evidence of this training,
including agenda, training
materials and signed
attendance sheets, by May 30,
2008.
Develop an internal oversight
and tracking system to ensure
appropriate completion of the
placement pages for the IEPs
of all special education
students in the district. Provide
a description of the internal
oversight and tracking system,
including person(s) responsible
for oversight by May 30, 2008.
Review all IEPs in the district
and report on the following:
 Total number of IEPs
reviewed;
 Number of IEPs which
contained PL1 pages
that appropriately
corresponded to the
amount of services on
the IEP service
delivery grids; and
 Specific actions taken
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 33 of 35
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
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
by the district to
remedy any continuing
non-compliance.
Submit the above information
to the Department by
December 15, 2008.
Criteria from Other Regulated Programs Monitored During this Mid-cycle Review
Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
Number/Topic
Approved
Corrective
Action
Implemented
and Effective

ELE 11
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Documentation
The district has, since the CPR,
created an ELL program that is
reportedly assisting students in
the rapid acquisition of English
language skills. The district
has hired a part time ESL
teacher, who is appropriately
certified with a waiver. Some
staff have been trained in
sheltered English immersion,
and the district hopes to offer
additional training to staff
Partial
Equal Access
to Academic
Programs and
Services
Interviews
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Partial
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
The district provides most
English language
development instruction
by an ESL certified
teacher, and a small
amount of English
language development
instruction by a
paraprofessional who is
trained and supervised by
the ESL teacher.
Provision of ESL
Provide the district’s plan for
ensuring that all students
receive English language
development instruction by an
appropriately licensed staff
member immediately. Also,
provide the district’s plan for
implementing a professional
development plan that provides
teachers with training in the
following:
1. Second language
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 34 of 35
Criterion
Number/Topic
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

during the upcoming (20082009) school year.
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
instruction by a
paraprofessional is
inappropriate, despite
training and supervision.
learning and teaching;
2. Sheltering content
instruction;
3. Assessment of
speaking and
listening;
4. Teaching reading and
writing to LEP
students.
Submit these plans to the
Department by May 15, 2008.
The district does not
currently provide
sheltered content
instruction in all content
areas to its ELE students.
While the ESL teacher
does use class content to
provide the ESL
instruction, staff who
have LEP students in the
classes must be trained on
how to shelter content.
Boxborough School District Coordinated Program Review Mid-cycle Report
April 14, 2008
Page 35 of 35