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 June 6, 2008 George Guasconi Superintendent of Schools Bridgewater-Raynham Public Schools 415 Central Street Bridgewater, MA 02324 Re: Mid-cycle Report Dear Superintendent Guasconi: 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 March 24, 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. The onsite team would like to commend the following programs and practices that were brought to its attention and that the team believes have a significant positive impact on the education of students enrolled in the Bridgewater-Raynham Public Schools. These programs and practices are as follows: The district carefully monitors their preschool classes so that the number of students in each class is now well within the requirements for class size. The Department will notify you of your district's next regularly scheduled CPR several months before it is to occur. At this time we anticipate that this CPR will occur sometime during the 2011 school year unless the Department determines that there is some reason to schedule this visit earlier. While the Department of Elementary and Secondary Education found your district to have resolved most noncompliance issues, some 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. 1 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 June 20, 2008. 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 781-338-3714. Sincerely, Nancy Hicks, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Gordon Luciano, School Committee Chairperson Joyce Onischewski and Gay Yelle, District Program Review Follow-up Coordinators Encl.: Mid-cycle Report 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT Bridgewater-Raynham Public Schools Date of Coordinated Program Review (CPR) Final Report: March 24, 2005 Date Coordinated Program Review Corrective Action Approved or Ordered: August 16 2008 Dates of Corrective Action Plan Progress Reports: January 22, 2007 (Special education criteria approved), March 28, 2007, May 30, 2007, June 17, 2007, January 29, 2008 Dates of this Mid-cycle Review Onsite Visit: May 6 and 7, 2008 Date of this Report: June 6, 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 Implement -ed and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 18 A IEP Development and content Partial Record review See SE 8 regarding Team member attendance. 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 The student record review indicates that some IEPs have missing elements. Boxes indicating that the Team considered transportation and schedule changes were sometimes left blank. The By August 1, 2008, the district must submit a plan for an internal monitoring system to ensure compliance with this criterion. By December 15, 2008 the district must submit the following: Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 1 of 11 Criterion Number/Topic Approved Corrective Action Implement -ed 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 IEP goals do not always contain information indicating how the parent would know if the student had reached the goal. The non participation justification statement was sometimes not consistent with the services on the service delivery page and the statement was sometimes generic and did not indicate that the individual student’s needs were considered. SE 22 Implementation and availability SE 35 Assistive Technology Record review and interview Documentation and interviews The record review indicates that there was not a gap in the time when an IEP expired and a new IEP began. The district is aware that they can not extend the period of an IEP beyond one year. Documentation and interviews indicate that assistive technology is considered at the Team meeting. Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 2 of 11 Required Corrective Action, Timelines for Implementation, and Progress Reporting The name of the individual responsible for monitoring at each school. The number of records examined The rate of compliance A description of steps taken when non compliance was identified. Criterion Number/Topic Approved Corrective Action Implement -ed and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 36 IEP Implementation 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 SE 22. SE 40 Instructional grouping Documentation and interviews SE 41 Age Span Documentation and interviews SE 42 Programs for young children Documentation and interviews SE 49 Related services Documentation, record review and interviews SE 51 Appropriate special Documentation Documentation and interviews indicate that the size of instructional groups at the high school meet requirements. Documentation and interviews indicate that the age span of students in instructional groupings at the high school do not exceed 48 months. Documentation and interviews indicate that the number of students in all preschool classes meet the requirements of this criterion. Interviews and documentation indicate that adapted physical education is provided if recommended by the Team. Counseling services are defined on IEPs with specific frequency as required. Documentation indicates that special education teachers at the high school have the required Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 3 of 11 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic Approved Corrective Action Implement -ed 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 certification. education licensure 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 Number and Topic SE 3 Special requirements for determination of specific learning disability Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Interviews and documentation Documentation and records indicate that the district is in the process of training staff members in the requirements for the determination of specific learning disabilities. Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 4 of 11 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic SE 6 ##1 - 3 Determination of Transition Services SE 8 IEP Team composition and attendance Criterion Implemented Partial Method(s) of Verification Basis of Determination that Criterion was Implemented Interviews, documentation and record review Documentation and interviews indicate that transitioning needs are discussed annually at the Team meeting and the Transitional Planning Form is used as required. Interviews, documentation and record review The record review indicated that IEP teams had the required members in attendance. Teams had an individual in attendance with the authority to commit district resources. Interviews indicated that staff members 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 The record review indicates that not all age appropriate student records reviewed had a Transitional Planning Form in their record that was reviewed annually and updated if needed. By August 1, 2008, the district must submit a plan for an internal monitoring system to ensure compliance with this criterion. By December 15, 2008 the district must submit the following: The name of the individual responsible for monitoring at the high school. The number of records examined The rate of compliance A description of steps taken when non compliance was identified. Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 5 of 11 Criterion Number and Topic SE 12 Frequency of re-evaluation SE 13 Progress Reports and content SE 14 Review and revision of IEPs SE 25B Resolution of Criterion Implemented Method(s) of Verification Record review Partial Record review and interviews Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented were aware of procedures for Team member excusal. The record review indicated that the district meets the requirements concerning the frequency of re-evaluation. Interviews indicated that progress reports contain the required information and are issued with the required frequency. Partial Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Not all student records reviewed contained progress reports for each IEP goal for each period. By August 1, 2008, the district must submit a plan for an internal monitoring system to ensure compliance with this criterion. By December 15, 2008 the district must submit the following: The name of the individual responsible for monitoring at each school. The number of records examined. The rate of compliance. A description of steps taken when non compliance was identified. Interviews indicate that the district would depend By December 15, 2008 the district must submit a Interviews and student records indicate that the district meets at least annually to review, revise or develop a new IEP. Record review and interviews Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 6 of 11 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented disputes SE 33 Involvement in the General Curriculum SE 39A Procedures for services to eligible private school students whose parents reside in the district Record review and interviews Interviews and documentation Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting on the advice of counsel whenever a BSEA hearing was requested. It does not have procedures in place to meet this criterion. description of the steps taken in response to a request for a hearing with the Bureau of the Special Education Appeals, a copy of any agreements to waive a resolution session, or a copy of any legally binding agreement reached. Student records indicate that IEP Teams have at least one member familiar with the general curriculum. Student schedules and IEPs indicate that students with disabilities participate in the general curriculum. Documentation and interviews indicate that the district provides special education services to eligible students enrolled in private schools at private expense and they complete the required documentation to document the proportionate share of federal funds expended. Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 7 of 11 Criterion Number and Topic SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state 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 only with respect to providers of interpreting services) Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Interviews and documentation The district had no eligible students in private schools whose parents reside out of state. Student records, documentation and interviews Documentation, interviews and student records indicate that the district follows required procedures when suspending students with disabilities. Interviews and documentation Documentation indicates the district would require those who provide interpreting services to be registered with the MA Commission for the Deaf and Hard of Hearing. Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 8 of 11 Required Corrective Action, Timelines for Implementation, and Progress Reporting Special Education Criteria Monitored because of Issues Identified since the CPR Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number and Topic SE 22 Implementation and availability Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Partial Interviews and documentation Interviews and documentation indicate that speech services were not provided to students this school year at Williams Middle School as indicated on the students’ IEPs due to lack of personnel. The district did inform the parents in writing and did advertise to fill the position. In February, arrangements were made to offer compensatory services for eligible students during vacations or weekends. On May 9, 2008, the Department was informed that the district had hired a speech therapist and the position at the Williams School was now filled. 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 Interviews and documentation indicate that the district did not immediately implement in September 2007 alternative methods of providing direct speech services or consistent consultant services that were specified on student’s IEPs at the Williams Middle School. In February 2008, when offers were made in a letter to parents to provide compensatory services, the district did not make it clear if transportation would be arranged or parents would be compensated so that all eligible students would have access to these services. By August 1, 2008, the district must submit a description of district’s procedures that will ensure that alternative methods of providing IEP services are put in place immediately when students’ IEPs can not be implemented because of a lack of personnel. Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 9 of 11 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 ELE 11 Equal Access to Academic Programs and Services 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 Based on documentation and an interview, LEP students are not segregated from their non English-speaking peers and that they are taught to the same academic standards. Documentation and interviews indicate that the district has a number of teachers trained in SEI and they have plans to expand the number of trained teachers and the areas of their competency. Procedures are in place to access interpreters and translated documents so that students could have the Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 10 of 11 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements 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 opportunity to receive counseling in their primary language. Bridgewater-Raynham Coordinated Program Review Mid-cycle Report June 5, 2008 Page 11 of 11 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements