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 February 8, 2007 Robert Kaufman, Executive Director Christa McAuliffe Regional Charter Public School 25 Clinton Street Framingham, MA 01702 Re: Mid-cycle Coordinated Program Review Report Dear Mr. Kaufman: 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 or ordered by the Department to address findings of noncompliance included in the Christa McAuliffe Regional Charter Public School’s (formerly Framingham Community Charter School) Coordinated Program Review Report issued on February 11, 2004. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. Another component of the Department’s Mid-cycle Review is the review of your school district'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 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 (documentation and any written analysis of compliance) and, based solely on that selfassessment, is providing you in this report with findings 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 findings or this prescribed corrective action from me or from staff in the Department’s Office of Language Acquisition and Achievement at 781-338-3534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/ . While the Department of Education found your district 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 district has failed to implement its approved Corrective Action Plan, the Department views these findings to be serious. 1 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 district within the timelines specified. You must submit your statement of assurance to me by February 23, 2007. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 781-338-3947. Sincerely, Jean E. Jonker, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Edna Smith , Board of Trustees Chairperson Neal Elliott, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Christa McAuliffe Regional Charter Public School Date of Coordinated Program Review (CPR): November 18 - 21, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: April 7, 2004 Dates of Corrective Action Plan Progress Reports: October 12, 2004, January 14, 2005, April 6, 2005, July 12, 2005 and October 4, 2005 Dates of this Mid-cycle Review Onsite Visit: January 18-19, 2007 Date of this Report: January 24, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implement ed Not Effective or New Issues Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance SPECIAL EDUCATION Criteria SE 32 Parent Advisory Council for Special Education Document Review, Student Record Review, Interviews The charter school has met its obligation for this criterion. The Parent Advisory Committee is established, meets regularly, is supported by the charter school, and serves in an advisory capacity to the charter school. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 1 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Corrective Action Implemented and Effective SE 50 Responsibility of the School Principal and Method(s) of Verification Document Review, Interviews The charter school has met its obligation for this criterion. The charter school has a director of special education and has a District Curriculum Accommodation Plan (DCAP) in place. Document Review, Interviews See comment to right. Administrator of Special Education SE 51 Appropriate special education teacher certification Partial Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implement ed Not Effective or New Issues Partial Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Documentation and interviews indicate that not all special education staff who provide direct special education services described in IEPs are appropriately licensed. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 2 Required Corrective Action, Timelines for Implementation, and Progress Reporting By April 20, 2007, submit copies of licenses (or current waivers) and professional credentials for the special education teacher, school psychologist, guidance counselor, and speech pathologist. Develop and implement a tracking system/monitoring plan for ensuring that special education staff are appropriately licensed and/or credentialed. Submit a description of the tracking system/monitoring plan along with a copy of the job description for the staff person responsible for ensuring that all staff who provide special education services hold appropriate Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implement ed Not Effective or New Issues 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 licensure. SE 54 Professional Development Regarding Special Education SE 56 Special Education programs and services are evaluated Document Review, Interviews The charter school has met its obligation for this criterion. All required topics regarding special education are annually covered through the charter school’s professional development plan. Document Review, Interviews The charter school has met its obligation for this criterion. The charter school annually evaluates its special education services and uses the results of the PAC survey to make program improvements. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 3 Criterion Number/Topic 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 Not Effective or New Issues Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Special Education Criteria created or revised in response to IDEA-2004 SE 6 Determination of Transition Services Student Record Review, Document Review, Interviews The charter school has met its obligation for this criterion. The charter school documents transition planning for students at age 15 or older in the students’ IEPs. The charter school also conducts transition meetings for students promoted to high school. * Please note that consistent with the recently enacted IDEA-2004 regulations, the transition planning chart will become a mandated form, which should be maintained with the student’s IEP. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department is currently revising this form, please check the Department’s Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 4 Required Corrective Action, Timelines for Implementation, and Progress Reporting Special Education website for updates. SE 8 IEP Team composition and attendance Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Corrective Action Implemented and Effective Student Record Review, Document Review, Interviews Method(s) of Verification The charter school has met its obligation for this criterion. Team meetings have the required persons in attendance. Basis of Determination that Corrective Action was Implemented and has been Effective SE 12 Frequency of re-evaluation Student Record Review, Interviews The charter school has met its obligation for this criterion. The charter school conducts a re-evaluation every three years. SE 13 Progress Reports and content Student Record Review, Document Review, Interviews The charter school has met its obligation for this criterion. Progress reports are regularly provided to parents. Corrective Action Not Implemented Not Effective or New Issues Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance *Please note that recently enacted IDEA-2004 regulations have now changed the content requirements for IEP progress reports. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department has changed the progress report form, and it is now available on the Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 5 Required Corrective Action, Timelines for Implementation, and Progress Reporting Department’s Special Education website at http://www.doe.mass.edu/sped/ iep/eng_toc.html. SE 14 Review and revision of IEPs SE 25B Resolution of disputes SE 33 Involvement in the General Curriculum SE 39A Procedures for Not Applicable Interviews, The charter school has met its Student Record obligation for this criterion. Review IEPs are reviewed annually. Document Review, Interviews Document Review, Student Record Review, Interviews The charter school has met its obligation for this criterion. The charter school has not had a parent request to the Bureau of Special Education Appeals (BSEA). The charter school knows its obligation to convene a meeting with the parent and relevant Team members within 15 days of receiving notice that the parent has requested an official hearing with BSEA. The charter school has met its obligation for this criterion. Staff understand the MA Curriculum Frameworks and the expectations of the state for student performance, as well as understand the rights of students with disabilities to be full participants in the general curriculum. (SE 39A does not apply to charter schools or vocational Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 6 schools) services to eligible private school students whose parents reside in the district SE 39B Procedures for services to eligible students in private schools whose parents reside out of state SE 46 Procedures for suspension of students with disabilities more than 10 days Criterion Number/Topic (SE 39B does not apply to charter schools or vocational schools) Not Applicable Corrective Action Implemented and Effective Document Review, Student Record Review, Interviews Method(s) of Verification The charter school has met its obligation for this criterion. The school adheres to its procedures for students with disabilities whose suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days. Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented Not Effective or New Issues Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Civil Rights (MOA) and Other General Education Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 7 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements MOA 10A Student Handbooks and Codes of Conduct Partial Document Review The charter school submitted a copy of the Family Handbook and School Policies that contains all but one of the required elements. MOA 14 Counseling/ counseling materials free from bias and stereotypes Document Review, Interviews The charter school has a process in place to ensure that limitedEnglish-proficient students have access to counseling in their native language if requested. MOA 17A Use of physical restraint Document Review, Interviews The charter school has staff who are trained to administer physical restraint, and staff are aware of the requirements of this regulation. Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Criterion Number/Topic MOA 22 Accessibility of district programs and services for students with Corrective Action Implemented and Effective Partial Document Review, Facility Observation, Interviews The charter school has installed a buzzer and video system at the 25 Clinton Street’s accessible entrance to notify the office that a disabled person is waiting to access the building. Partial Corrective Action Not Implemented Not Effective or New Issues Partial The discipline procedures do not include procedures for students on Section 504 Accommodation Plans. Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance The cafeteria and the gymnasium located at 40 Clinton Street do not currently provide for handicap access into the building and for the Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 8 No later than April 20, 2007, submit a copy of the section of the revised draft of the Family Handbook and School Policies that includes disciplinary procedures for students on Section 504 Accommodation Plans. Required Corrective Action, Timelines for Implementation, and Progress Reporting Complete the ADA checklist for the facility located at 40 Clinton Street and formulate a plan that includes a specific timeline to address any identified issues in addition to formulating a plan to address disabilities MOA 25 Institutional selfevaluation Partial Document Review, Interviews The charter school does evaluate its program on an ongoing basis (i.e., through the Team Plus meetings) to ensure that students have equal access to all programs. Partial water fountains and bathrooms. the previously cited noncompliance access issues. Submit the checklist and plan by April 20, 2007. Limited-Englishproficient students are not provided equal access to all programs because the students are not provided with an English learner education program as required by M.G.L. c. 71A. See ELE 5 Other Regulated Programs Monitored During this Mid-cycle Review Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 9 Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report English Learner Education (ELE) Requirements Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) ELE Criterion Number and Topic ELE 1 Annual Assessment Implemented Based on Local ELE SelfAssessment Partial Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting The charter school does not annually assess the English proficiency of all limited English proficient (LEP) students. By April 20, 2007, submit documentation that confirms that identified LEP students are administered required annual assessments: the Massachusetts English Proficiency Assessment (MEPA) and the Massachusetts English Language Assessment – Oral (MELA-O). ELE 2 MCAS Participation Not Implemented The charter school does not have a policy or procedures in place for providing MCAS accommodations for LEP students. By April 20, 2007, submit written policies and procedures to ensure appropriate administration of the MCAS to LEP students. ELE 3 Initial Identification Not Implemented The charter school does not have a policy or procedure in place to ensure the initial identification of LEP students upon enrollment. Documentation provided did not contain a student roster based upon initial screening, list of qualified staff to implement identification procedures and a copy of the screening assessment tool. By April 20, 2007, submit a copy of the home language survey (English and other languages), a list of students who have been screened, a description of the assessments used to determine English language proficiency in all four modalities of reading, writing, speaking, and listening; and a list of qualified staff (name, title, and role) to Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 10 ELE Criterion Number and Topic Implemented Based on Local ELE SelfAssessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting implement identification procedures. ELE 4 Waiver Procedures Not Implemented The charter school does not have procedures or a notice to inform parents of their right to apply for a waiver of ELE. Submit, by April 20, 2007, a notice that informs parent(s) of their right to apply for a waiver that includes all of the required elements. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 11 ELE Criterion Number and Topic Implemented Based on Local ELE SelfAssessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) ELE 5 Program Placement and Structure Not Implemented The charter school does not provide LEP students with instruction based upon the requirements of this criterion. ELE 6 Program Exit And Readiness Not Implemented The charter school’s program exit and readiness procedures do not follow the requirements and the implementation guidance of this criterion. The charter school did not submit documentation regarding the specific procedures (e.g., test scores) in place to re-designate a Required Corrective Action, Timelines for Implementation, and Progress Reporting Submit by April 20, 2007: Explanation of how the charter school intends to deliver an English Language Learner program consistent with the requirements of Chapter 71A. Description of the English language support program in place for students K-12 for the 2006-07 SY. List of ELL students for the 06-07 SY. Indicate the grade level and the classroom placement of each student, as well as the type and amount of English language support that the student needs. Indicate when the student receives instruction that is based on the English Language Proficiency Benchmarks and Outcomes. Include a copy of their most recent annual language proficiency assessments. Qualifications of the ESL/ELD teacher(s), including a copy of current certification and/or waiver Names of teachers participating in sheltered English instruction training for the 06-07 SY. Include the type and amount of training received and scheduled. Submit by April 20, 2007, written procedures for re-designating a student from LEP to FLEP, including the program exit criteria and the multiple measures used to make the determination. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 12 ELE Criterion Number and Topic Implemented Based on Local ELE SelfAssessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting student from LEP to FLEP status. ELE 7 Parent Involvement Partial ELE 8 Declining Entry to a Program Not Implemented The charter school provides some translation services when requested; however, the charter school has not developed a mechanism that provides multiple opportunities and a variety of methods for including parents or guardians of LEP students in matters pertaining to their children’s education. By April 20, 2007, submit the charter school’s mechanism for including parents or guardians of LEP students in matters pertaining to their children’s academic education. Note: The charter school should provide multiple opportunities and a variety of methods for parentteacher communication and document the availability of such opportunities. The charter school does not have policies and procedures for LEP students who have declined entry to a program based upon the requirements of this criterion. Submit by April 20, 2007, policies, procedures, and an implementation plan for providing supports to LEP students whose parents decline entry into an ELE program. ELE 9 Instructional Grouping Not Implemented The charter school does not provide students with ESL/ELD instruction at the appropriate proficiency level and based on the English Language Proficiency Benchmarks and Outcomes. ELE 10 Parental Notification Not Implemented The charter school does not have a parental notification letter. Submit: Process for placing LEP students in instructional groupings; and Description of English language development curriculum. Provide the Department with evidence of the above, and with evidence that these have been shared with appropriate personnel in the charter school, by April 20, 2007. Submit, by April 20, 2007, a parental notification letter that contains the required elements of this criterion. Also submit a translated copy of the letter. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 13 ELE Criterion Number and Topic ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs ELE 13 Follow-up Support ELE 14 Licensure Requirements Implemented Based on Local ELE SelfAssessment Partial Partial Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting LEP students have access to and are integrated into general education classrooms. In addition, LEP students can access all curriculum offerings, such as special education services and Section 504 Plans, provided they meet eligibility requirements; however, the charter school’s implementation practices do not meet all of the requirements of this criterion. The charter school’s DCAP does not provide support services for LEP students. However, the charter school has a process in place to ensure that limited-English-proficient students have access to counseling in their native language. The charter school should revise their implementation practices to meet the requirements of this criterion. The charter school’s undocumented implementation practices indicate that all LEP students have access to nonacademic and extracurricular programs; however, the charter school’s practices do not meet the requirements of this criterion.. The charter school should revise and document the implementation practices to meet the requirements of this criterion. Submit a copy of the updated implementation practices regarding support services for LEP students that will be included in the school’s DCAP to the Department by April 20, 2007. Submit a copy of the implementation practices to the Department by April 20, 2007. Not Implemented Not Implemented The charter school does not have a formal LEP program or a process for determining when LEP students have become proficient and no longer require supports or an ELE program. Develop procedures to provide follow-up support for students who have exited the ELE program. Submit a copy of the plan by April 20, 2007. The charter school did not provide documentation indicating that members of the staff who provide English language instruction hold current ESL teacher licensure or an approved ELL waiver. Submit by April 20, 2007 evidence that LEP students are receiving English language development instruction from an appropriately licensed teacher as required by this criterion. Provide a copy of all ELE student weekly Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 14 ELE Criterion Number and Topic Implemented Based on Local ELE SelfAssessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting instructional schedules that indicate the receipt of services along with the staff person’s name and copy of license. ELE 15 Professional Development Requirements Not Implemented The charter school has not implemented a professional development plan that provides teachers and administrators with high quality training as prescribed by the Department to ensure the progress of LEP students in developing oral comprehension, speaking, reading and writing of English. The charter school must develop a professional development plan that meets the requirements of this criterion for teachers and administrators that provides high quality training in: 1. Second language learning and teaching 2. Sheltering content instruction 3. Assessment of speaking and listening; 4. Teaching reading and writing to limited English proficient students. Submit a copy of the professional development plan to the Department by April 20, 2007, and evidence that the training has taken place by the end of May 2007. Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 15 ELE Criterion Number and Topic Implemented Based on Local ELE SelfAssessment ELE 16 Equitable Facilities ELE 17 Program Evaluation ELE 18 Records of LEP Students- Not Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting At the time of the review, the charter school met the requirements of this criterion. In addition, the charter school has not developed an ongoing evaluation process to ensure the ELE program is effective. The charter school must develop a proposal for evaluating the effectiveness of its ELE program and submit it to the Department by April 20, 2007. (To be reviewed during next CPR visit.) Not Rated Christa McAuliffe Regional Charter Public School Coordinated Program Review Mid-cycle Report Page 16