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
January 3, 2007
Basan Nembirkow
Superintendent of Schools
Brockton Public Schools
43 Crescent St.
Brockton, MA 02301
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Nembirkow:
Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted to verify the
implementation and effectiveness of corrective action approved by the Department to address
findings of noncompliance included in the Brockton Public Schools and Champion Charter
School Coordinated Program Review Report issued on April 5, 2004. The Mid-cycle Report also
contains findings based on onsite monitoring of special education compliance criteria that have
been newly created or substantially changed in response to IDEA 2004.
As you know, another component of the Department’s Mid-cycle Review is the review of your
school district or charter school's self-assessment in the area of English learner education (ELE).
(In the remainder of this letter, please read “district” as meaning “school district or charter
school.”) The purpose of this review is to determine whether your district 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 district’s ELE self-assessment documents and, based solely on that selfassessment, is providing you in this report with comments on your ELE program and, where
necessary, corrective action to be implemented. Your district is urged to request technical
assistance in relation to any of these comments or prescribed corrective action. To secure
assistance, you may consult with your Mid-cycle Review Chairperson. You may also consult
with staff in the Department’s Office of Language Acquisition and Achievement at 781-338-3534
and obtain additional ELE guidance documents through the Department’s web site at
http://www.doe.mass.edu/ell/ .
The onsite team would like to commend the following areas that were brought to its attention and
that the team believes have a significant and positive impact on the delivery of educational
services for students enrolled in the Brockton Public Schools. These areas are as follows:
 The innovative approaches to teaching exhibited in the school buildings are highly
commendable. Students are receiving high quality instruction that is tied to the
Massachusetts Curriculum Frameworks.
1


The knowledgeable and hard-working staff deserves recognition for their efforts.
The responsiveness and openness of the administration indicates that they are serious
about doing what’s right for students.
The Department will notify you of your district's next regularly scheduled Coordinated Program
Review several months before it is to occur. At this time we anticipate the Department's next
routine monitoring visit to occur sometime during the 2009-2010 school year, unless the
Department determines that there is some reason to schedule this visit earlier.
While the Department of Education found the charter 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 charter 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 district that must be implemented without delay. You will find these requirements
for corrective action included in the attached report, along with requirements for progress
reporting. Please provide the Department with your written assurance that all of the Department's
requirements for corrective action will be implemented by your school district within the
timelines specified. Your statement of assurance must be submitted to the Mid-cycle Review
Chairperson by January 22, 2007.
Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should
you like clarification of any part of our report, please do not hesitate to contact the Mid-cycle
Review Chairperson at 781-338-3704.
Sincerely,
Matthew Deninger, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
James E. Harrington, Mayor of Brockton, School Committee Chairperson
Kay Seale, Director of Special Education
Janice Marino, Coordinator of Special Education Compliance
Virginia Warn, Principal, Champion Charter School
Tina Glidden, Champion Charter Board Chairperson
Encl.: Brockton Public Schools Mid-cycle Coordinated Program Review Report
Champion Charter School Mid-cycle Coordinated Program Review Reportid-cycle Cover
Letter 2006.doc
Rev. 6/5/06
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
BROCKTON PUBLIC SCHOOLS
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): November 3-7, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: July 28, 2004
Dates of Corrective Action Plan Progress Reports: September 23, 2004; October 1, 2004; December 15, 2004; April 29, 2005; November 30, 2005; July 14, 2006
Dates of this Mid-cycle Review Onsite Visit: October 30 – November 3, 2006
Date of this Report: January 3, 2007
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 1 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Special
Education
Criteria
Originally
Cited in CPR
Report and
Monitored in
Mid-cycle
SE 13
Progress
Reports
SE 19
Extended
Evaluations
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Record
Review,
Documentation
Review,
Interviews
Record review indicated that there
was marked improvement in
progress report narratives. Many
of the reports were goal-specific
and relevant.
Record
Review,
Documentation
Review,
Interviews
Record review and interviews
indicated that extended
evaluations are being completed
when appropriate, and district
personnel are knowledgeable
about the use of extended evals.

Partial

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
Record review also indicated
that progress reports are
written for the purpose of
measuring a student’s
progress toward specific
goals. However, some
narratives do not address the
specific goals, as is
described on the IEPs. This
inconsistency was noted
system-wide.
Please conduct training on writing
high quality progress report
narratives that are specific to each
goal. Please provide the
Department with evidence of
this training by April 20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 2 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 21
School day and
School year
requirements
SE 37
Out-of-District
Placements
SE 40
Instructional
Grouping
Requirements
SE 55
Special
Education
Facilities and
Classrooms
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Record
Review,
Documentation
Review,
Interviews
Record
Review,
Documentation
Review,
Interviews
Record review and interviews
indicated that all students are
routinely considered for extended
or shortened school days and
years.
Record review indicated that all
students who are placed out of
district include the appropriate
contracts and paperwork. Students
are regularly monitored by the out
of district coordinator; the
monitoring visits are documented
and placed in the student files.
Documentation review and
observations indicated that all
study labs as well as the life skills
program are appropriately
grouped.





Record
Review,
Documentation
Review,
Interviews,
Observations
Documentation
Review,
Interviews,
Observations
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
The DOE inspected all facilities
issues noted in the 2003 CPR, and
all issues have been since
corrected.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 3 of 24
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Record
Review,
Documentation
Review,
Interviews
The onsite Team found that
transition services are discussed at
meetings for all special education
students over the age of 15. The
district uses the state
recommended transition planning
chart to document the students’
transitional needs.
Record review indicated that in
most cases all Team members that
are required at Team meetings are
in attendance.
(Refer to full
text of 20052006 CPR
requirements)
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 6
Determination
of Transition
Services
SE 8
IEP Team
composition
and attendance
SE 12
Frequency of
re-evaluation

Partial

Record
Review,
Documentation
Review,
Interviews
Record
Review,
Documentation
Review,
Interviews
Criterion
Determined
to be
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 indicated
that, particularly at Brockton
High School, at least one
regular education teacher
was not always in attendance
at Team meetings.
Please inform teaching staff at
Brockton High School, by way of
a memo and verbally at a staff
meeting, of the federal and state
regulations for Team meeting
attendance. Please provide the
Department with evidence of the
memo and staff meeting by
April 20, 2007.
The onsite Team found that most
re-evaluations are done on time,
according to state regulations.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 4 of 24
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Record
Review,
Documentation
Review,
Interviews
Record review indicated that
amendments are completed
appropriately, and interviews
revealed that staff were
knowledgeable about the
appropriate use of amendments.
Record
Review,
Documentation
Review,
Interviews
Record
Review,
Documentation
Review
Record review indicated that
dispute resolution meetings are
always proposed when the district
receives notice of a hearing.
Record
Review,
Documentation
Review,
Interviews
The district has implemented this
criterion, always holding
manifestation determination
meetings on or before the tenth
day of a special education
student’s suspension.
(Refer to full
text of 20052006 CPR
requirements)
SE 14
Review and
revision of
IEPs
SE 25B
Resolution of
disputes
SE 30
Notice of
procedural
safeguards
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days




Criterion
Determined
to be
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
The district distributes the Interim
Notice of Procedural Safeguards
to all parents at least once per
year, and at all initial and
reevaluation meetings.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 5 of 24
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Civil Rights
(MOA) and
Other General
Education
Requirements
MOA 10A
Handbooks
and codes of
conduct
MOA 12A
Annual and
continuous
notification
concerning
nondiscriminat
ion and
coordinators
MOA 17A
Physical
Restraint
Approved
Corrective
Action
Determined
to be
Implemented
and Effective




Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Documentation
Review,
Interviews
All handbooks were provided to
the DOE, and all discipline
procedures for students with
disabilities have been updated
with the existing state and federal
regulations.
Documentation
Review,
Interviews,
Record Review
District letterhead, notices, and
handbooks include all required
elements in the non-discrimination
statement.
Documentation
Review,
Interviews
All schools staff annually receives
awareness-level restraint training.
Each school then has crisis teams
that are fully trained to administer
all varieties of restraint.
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective
Or
Basis of Finding of New
Noncompliance
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 6 of 24
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Requirements
MOA 21
Staff training
regarding civil
rights
responsibilities
MOA 22
Accessibility of
district
programs
MOA 23:
Comparability
of facilities

Documentation
Review,
Interviews
All school staff annually receive
training on civil rights
responsibilities.

Documentation
Review,
Interviews
There is at least one school
building at each level that is
accessible for students with
disabilities.
Observations,
Documentation
The Life Skills classroom at the
High School is now comparable in
quality and size to the rest of the
classrooms at the high school.
Record
Review,
Documentation
Review,
Interviews
Record
Review,
Documentation
Review,
Interviews
Record
Review,
Documentation
Review,
Interviews
The Team found that students are
consistently evaluated and exited
from ELL programs. Students
receive follow-up support and are
monitored closely once exited
Students whose parents have
declined entry to the ELL program
are still eligible for language
support, and are monitored.

Other
Regulated
Programs
Addressed
During this
Mid-cycle
Review
ELE 6
Program Exit
and Readiness
ELE 8
Declining
Entry to a
Program
ELE 11
Equal Access
to Academic
Programs and
Services



SEI training for staff members is
ongoing. The district has devoted
resources to professional
development in ELE, which
occurs almost every day of every
month during the school year.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 7 of 24
ELE 13
Follow-up
Support
ELE 17
DOE Data
Submission
Requirements
and Program
Evaluation


Record
Review,
Documentation
Review,
Interviews
Documentation
Review,
Interviews
Follow-up support is given to all
students who are considered
FLEP. The Language Assessment
Team provides monitoring of
these students.
The district has conducted a highquality program evaluation which
assesses the effectiveness of the
ELE program. The district has
used this evaluation to improve
the quality of the program.
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Additional
Findings
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 18A
IEP
Development
and Content
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Record review,
interviews
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
Record review indicated that
PLEP-B pages were
sometimes used to document
that a conversation had taken
place at a Team meeting,
instead of the intended
purpose of listing
accommodations related to
the student’s disability.
Please conduct training on writing
PLEP-B pages. Please provide
the Department with evidence of
this training by April 20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 8 of 24
SE 59
Transfer of
Student Records
Partial
Record review,
interviews
Partial
The Champion Charter
School is sometimes unable
to implement an IEP upon a
student’s enrollment. Often
this is due to a lack of
communication between the
charter school and the
sending school, which is
normally Brockton High
School. Champion Charter
was also cited for this lack
of communication.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 9 of 24
Please consult with Champion
Charter School and develop a
written set of procedures for the
smooth and prompt transfer of
records when a student moves
from the Brockton Public Schools
to the Champion Charter School.
Please provide the Department
with these written procedures
no later than April 20, 2007.
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
CHAMPION HORACE MANN CHARTER SCHOOL
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): November 3-7, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: July 28, 2004
Dates of Corrective Action Plan Progress Reports: September 23, 2004; October 1, 2004; December 15, 2004; April 29, 2005; November 30, 2005; July 14, 2006
Dates of this Mid-cycle Review Onsite Visit: October 30 – November 3, 2006
Date of this Report: December 21, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 10 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Record review,
interviews
Champion Charter has contracted
with a specialist at a local
institution of higher education to
handle special education testing.
The specialist is available to
consult with the Team regarding
his findings and interpretations.
Partial
Record review,
interviews
Record review showed that in
most cases the required psychoeducational assessments were
completed.

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Record review indicated that
the Educational Assessments
A&B are not consistently
completed by staff members.
Furthermore, interviews
indicated that many school
personnel are not trained in
how to properly complete
the Assessments.
Please provide staff members with
a training session regarding their
responsibilities to properly
complete Educational
Assessments. Please provide
evidence of this training (sign-in
sheets, materials, etc.) to the
Department no later than April
20, 2007.
Special
Education
Criteria
Originally
Cited in CPR
Report and
Monitored in
Mid-cycle
SE 1
Assessments are
appropriately
selected and
interpreted for
students
referred for
evaluation
SE 2
Required and
optional
assessments
Partial
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 11 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 6
Determination
of transition
services
SE 9
Eligibility
determination
SE 12
Frequency of reevaluation
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Record review,
interviews

Record review,
interviews
Record review and interviews
confirm that transition planning
charts are being completed for all
students prior to team meetings,
and transition is discussed at the
meetings. Student input is
documented in the vision
statement, as well as on the
transition planning chart.
Students are always invited to the
meetings.
The charter school is appropriately
documenting a student’s eligibility
determination.
Partial
Record review,
interviews

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

In some cases, re-evaluations were
held on time, before the 3-year
time limit. In other cases, this is
not true.
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 charter school is
inconsistent in its adherence
to the re-evaluation
timelines. This may be due
to a number of factors,
including but not limited to
insufficient staffing
available to manage the
growing number of students
with special needs in the
charter school community.
Please construct and maintain a
timeline tracking sheet in order to
track all state mandated IEP
timelines (e.g. annual review, reevaluation, provision of IEP, etc.).
Please provide a copy of this to
the Department no later than
April 20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 12 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 13
Progress
Reports
SE 14
Review and
revision of IEPs;
Amendments
SE 15
Outreach by the
School District
(Child Find)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Partial
Record review,
interviews
Record review indicated that
progress reports were found in
most records, and that there was
significant improvement in the
quality of progress reports. Many
of the reports were goal-specific
and relevant.
Partial
Record review,
interviews
The charter school has made
efforts to hold meetings annually
and on time.

Record review,
interviews
The charter school has a waiting
list of students, which is likely the
result of effective outreach
activities conducted by the school.

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Partial
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
Record review also indicated
that progress reports are
written for the purpose of
measuring a student’s
progress toward specific
goals. However, some
narratives do not address the
specific goals, as is
described on the IEPs. This
inconsistency was noted
system-wide.
Though the charter school is
holding some annual
meetings on time, there are
times when the meetings are
not held on time and the IEP
is allowed to expire.
Furthermore, record review
indicated that Amendments
were sometimes being used
to extend the IEP
deadlines—a practice that is
inconsistent with state
regulation.
Please conduct training on writing
high quality progress report
narratives that are specific to each
goal. Please provide the
Department with evidence of
this training by April 20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 13 of 24
See SE 12 for tracking sheet
corrective action. Also, please
develop procedures for the
proper use of amendments, and
review these procedures with
Team chairpersons.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 18B
Determination
of placement;
provision of IEP
to parent
SE 22
IEP
implementation
and availability
SE 24
Notice to parent
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Partial
Record review,
interviews
Partial
Record review,
interviews

Record review,
interviews
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Partial
Partial
Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
The charter school is
inconsistent in its immediate
provision of an IEP to
parents or educational
decision makers.
The charter school is
sometimes unable to
implement an IEP upon a
student’s enrollment. Often
this is due to a lack of
communication between the
charter school and the
sending school, which is
normally Brockton High
School. Brockton was also
cited for this lack of
communication.
The onsite team found that notice
forms are normally sent to parents
with all required elements and
information included.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 14 of 24
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Please see SE 12 for tracking
sheet corrective action.
Please consult with the Brockton
Public Schools and develop a
written set of procedures for the
smooth and prompt transfer of
records when a student moves
from the Brockton Public Schools
to the Champion Charter School.
Please provide the Department
with these written procedures
no later than April 20, 2007.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 25
Parental consent
SE 49
Related services
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification

Partial
Record review,
interviews
Partial
Record review,
interviews
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Partial
Partial
Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
The charter school is often
unable to obtain parent
signatures in a timely
manner. Interviews
indicated that special
education services are
normally implemented
despite the fact that the
school has not obtained
consent.
When the onsite Team
reviewed the school, a
School Adjustment
Counselor had been recently
hired to provide services to
students with emotional,
social, and behavioral needs.
However, that individual had
not yet started work at the
time of the review.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 15 of 24
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Please review the student records
and provide the Department with a
list of students whose IEPs have
not yet been signed. Please
indicate what measures have been
taken to obtain consent for each
student. If consent cannot be
obtained with continued efforts,
state regulations compel the
school to send the unsigned IEPs
to the BSEA. Please provide the
Department with this
information no later than April
20, 2007.
Please provide the Department
with the name of the School
Adjustment Counselor, as well as
an IEP that indicates counseling
services on the service delivery
grid that are being provided by the
adjustment counselor. Please
provide the Department with
this information no later than
April 20, 2007.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 50:
Responsibilities
of the School
Principal
SE 55
Special
Education
Facilities and
Classrooms
SE 56
Special
education
programs and
services are
evaluated
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Partial
Record review,
interviews
Observations

Partial
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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 school has not fully
implemented its District
Curriculum Accommodation
Plan. Though the plan calls
for a child study team in
order to address struggling
students, interviews
indicated that most staff
members are unaware that
such a team exists and don’t
believe that the team has
ever met.
Please provide the Department
with a copy of the DCAP, as well
as documentation supporting the
existence and use of a buildingbased child study team (child
study forms, meeting dates and
minutes, etc.). Please provide the
Department with this
information no later than April
20, 2007.
The school does not have a
regular, formalized process
for reviewing and evaluating
their special education
program on an annual basis.
Please provide the Department
with a description of the school’s
procedures for evaluating their
special education program. With
the procedures, please provide the
Department with a timetable
regarding when the next program
evaluation will take place. Please
provide the Department with
this information no later than
April 20, 2007.
Previous noncompliance with this
criterion was remedied when the
Charter School moved to a new
physical plant.
Record review,
interviews
Partial
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 16 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 57
Special
education
child count
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 8
IEP Team
composition
and attendance
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Partial
Record review,
interviews
The school has submitted its child
count data to the Department of
Education.
Partial
Partial
Record review,
Interviews
Record review indicated that in
most cases all Team members that
are required at Team meetings are
in attendance.
Partial

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Due to the significant
number of IEPs that remain
unsigned, the special
education child count data
are likely to be inaccurate.
Please see SE 25 for Parental
Consent corrective action.
Record review indicated that
parents and students were
not always in attendance at
Team meetings.
Furthermore, the school does
not always document their
efforts in attempting to
contact parents and students
to ensure participation.
Please develop policies and
procedures to ensure parent
participation in Team meetings.
Please provide the Department
with these policies or procedures
by April 20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 17 of 24
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 25B
Resolution of
disputes
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Record review,
Interviews
Record review indicated that no
parents have requested hearings at
the BSEA. Therefore, no
resolution meetings have been
necessary.
Record review,
Documentation
Review,
Interviews
The school has a discipline policy
for special education students in
its Student Handbook.

Partial
Partial
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Partial
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
Interviews indicated that
administrators were unaware
of this new regulation.
Additionally, the school has
no policy addressing dispute
resolution meetings.
Please develop policies and
procedures that outline when a
dispute resolution meeting will
take place, who would attend, etc.
Please provide the Department
with these policies or procedures
by April 20, 2007.
Please provide the Department
with an updated version of the
special education discipline
policy, consistent with new
regulations (for a model, see
special education criteria 45,46, &
47), by April 20, 2007.
The school has not updated
the discipline policy for
special education students
since the new regulations
were promulgated.
Specifically, the school does
not explain what the
procedure will be when an
action is found to be a
manifestation of a student’s
disability, and when an
action is found not to be a
manifestation of a student’s
disability.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 18 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Civil Rights
(MOA) and
Other General
Education
Requirements
MOA 10A
Handbooks
and codes of
conduct
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification

Partial
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Documentation
Review,
Interviews
Partial
Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
The Student Handbook does
not have an updated policy
reflecting the new special
education discipline
regulations.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 19 of 24
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Please see SE 46 for discipline
policy corrective action.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
MOA 11A
Designation of
liaison/coordin
ator(s);
grievance
procedures
MOA 12A
Annual and
continuous
notification
concerning
nondiscriminat
ion and
coordinators
MOA 16
Notice to
students 16 or
over leaving
school w/out a
H.S. diploma,
certificate of
attainment, or
certificate of
completion
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective



Partial
Documentation
Review,
Interviews
The student handbook addresses
grievance procedures that cover
the filing and resolution of
complaints regarding
discrimination or harassment.
Documentation
Review,
Interviews,
Record Review
Charter school notices and
handbooks include all required
elements in the non-discrimination
statement.
Interviews,
Record Review
The school has a standard form
that is given to students who drop
out or withdraw from school,
informing them of their rights to
re-enter either the Champion
Charter School or the Brockton
Public Schools.
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
While the school has a
standard form that is given
to students who drop out or
withdraw from school,
informing them of their
rights to re-enter either the
Champion Charter School or
the Brockton Public Schools,
the school does not have a
policy that is consistent with
state law c.76 ss.5, 18.
Please provide the Department
with a copy of the school’s revised
policy for handling students upon
their withdrawal (or extended
absence) from the Champion
Charter School by April 20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 20 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
MOA 25
Accessibility of
district
programs
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Documentation
Review,
Interviews
MOA 17A
Physical
Restraint
MOA 21
Staff training
regarding civil
rights
responsibilities
Method(s) of
Verification
Interviews
Partial


The school has provided training
to staff members in previous years
regarding civil rights
responsibilities.
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 school has not
completed the awarenesslevel restraint training. The
school does not have a fullytrained staff member who is
able to administer all
varieties of restraint.
Please provide the Department
with evidence that awarenesslevel restraint training has
occurred for all staff members
(sign-in sheets, materials, etc.).
Please also provide the
Department with a plan for
creating a crisis team, on which
more than one staff member is
fully trained in student restraint.
Please provide the Department
with this information no later
than April 20, 2007.
Please provide the Department
with evidence that civil rights
training has occurred for all staff
members (sign-in sheets,
materials, etc.). Please provide
the Department with this
information no later than April
20, 2007.
The civil rights training
should be an annual
occurrence, and several staff
members indicated that they
had not received such
training this year.
The school has not conducted the
required accessibility evaluation.
However, the school will be
moving to a new building during
2007-2008. The Department will
monitor the new facilities’
accessibility following the move.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 21 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification

Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
According to the
memorandum of
understanding between the
Brockton Public Schools and
the Champion Charter
School, Brockton is charged
with monitoring and
providing technical
assistance to the ELE
program at the charter
school. The Team found
that, though some
informational training has
been given to staff members
at Champion Charter, the
level of collaboration
between the district and the
charter school has been
minimal in this area.
Please collaborate with the district
to develop the necessary
procedures for implementing ELE
services to students and for
training staff members in sheltered
English immersion. Along with
the district, please provide the
Department with a written
description of the results of this
collaboration no later than April
20, 2007.
Other
Regulated
Programs
Addressed
During this
Mid-cycle
Review
ELE 1-17
Partial
Record review,
Interviews,
Documentation
review
Partial
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 22 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Record review,
Interviews
The school’s curriculum is based
on the Massachusetts state
frameworks. The school also fully
include all special education
students into the general education
classroom setting.

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
The school only provides a
full inclusion model for
students. Students entering
the school who require some
kind of special education
services outside of the
general education classroom
are placed in the general
education classroom and
their IEPs are changed to
eliminate any pull-out
service. At its current
staffing level, the school
does not have the capacity to
service children in core
academic subjects outside of
the general education
environment.
Please provide the Department
with a plan to expand the services
available to students with special
needs, to accommodate those who
may need services outside of the
general education classroom no
later than April 20, 2007.
Additional
Findings
SE 34
Continuum of
Alternative
Services and
Placements
Partial
Partial
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 23 of 24
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 54
Professional
Development
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Partial
Record review,
Interviews
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

The school has completed some
training on accommodating
students with different learning
styles.
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 school has not provided
staff members with training
on special education laws
and responsibilities.
Furthermore, the school has
not provided its
paraprofessionals adequate
training in order to more
effectively work with
general education teachers
and provide services to
special education students.
Please conduct training for staff
members regarding special
education laws and their
subsequent responsibilities. Also,
please conduct training for
paraprofessionals on effective
collaboration and the provision of
special education services. Please
provide the Department with
evidence of this training (sign-in
sheets, materials, etc.) by April
20, 2007.
Brockton Public Schools Coordinated Program Review Mid-cycle Report
January 3, 2007
Page 24 of 24