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 June 11, 2007 Meg Campbell, Head of School Codman Academy Charter School 637 Washington Street Dorchester, MA 02124 Re: Mid-cycle Coordinated Program Review Report Dear Ms. Campbell: Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (Mid-Cycle Report). This report contains findings based on onsite monitoring conducted to verify the implementation and effectiveness of corrective action approved or ordered by the Department to address findings of noncompliance included in the Codman Academy Charter School Coordinated Program Review Report issued on April 1, 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 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 (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 the corresponding 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 1 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. 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 June 29, 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 781338-3729. Sincerely, Elizabeth M. Young, Ed.D. Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education William Walczak, President, Codman Academy Board of Trustees Janet Govindan, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Codman Academy Charter School ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): December 9-11, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: August 9, 2004 Dates of Corrective Action Plan Progress Reports: February 28, 2005, August 7, 2006 Dates of this Mid-cycle Review Onsite Visit: December 18, 2006 Date of this Report: June 11, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 1 of 27 Criterion Number/Topic Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 1 Assessment Selection Student record review and staff interview The student records demonstrated that assessments are appropriately selected based on the suspected disability of the student. SE 2 Required Assessments Student record review and staff interview The student records demonstrated that all required assessments are completed. (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and 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 Corrective Action Not Effective The student record review indicated that student assessments are not always being completed within 30 days, and in some instances, were being completed one to two days prior to the Team Meeting. Therefore, The charter school must submit evidence that it has conducted an internal monitoring to determine the causes(s) for the non-implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle SE 4 Report of Assessments Partial Student record review Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 2 of 27 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective SE 9 Timelines for Eligibility SE 18A IEP Development and Content Method(s) of Verification Partial Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting not affording parents the opportunity to receive summary assessment reports at least two days prior to the Team meeting. person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this by July 14, 2007. Student record review Corrective Action Not Effective The student record review demonstrated that the charter school does not always meet timeline requirements for both initial evaluations to determine eligibility and re-evaluations for eligible students. The charter school needs to submit evidence that it has conducted an internal monitoring to determine the cause(s) for this nonimplementation of this requirement. Please submit a narrative summary of the monitoring activities conducted, including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this by July 14, 2007. Student record review Corrective Action Not Effective Student record review demonstrated that the charter school does not always develop IEPs with all requirements. Some The charter school needs to provide training to all staff members who are responsible for IEP development and writing. Please provide the Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 3 of 27 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting IEPs lacked vision statements, the Present Level of Educational Performance A and B forms were incomplete or incorrectly filled out, age consideration boxes were left incomplete and in some instances, IEP goals were duplicated from one year to the next. It should also be noted that goals appeared to also be duplicated from one student’s IEP to another student’s IEP as well. Department with the dated agenda for the IEP development training, copies of the materials use, a copy of the attendance sheet and the name and credentials of the trainer. Please submit this to the Department by July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 4 of 27 Once the training has been completed the charter school must conduct a review of sample IEPs developed posttraining to identify if the training was effective. Please provide the Department a detailed narrative summary including the number of IEPs reviewed, rate of compliance and a description of any additional steps taken if noncompliance if found. Please submit this to the Department by December 7, 2007. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 32 Parent Advisory Council No SE 34 Continuum of Services & Placements Yes Staff interviews, student record review and documentation The charter school has established a substantially separate classroom for special education student who require such a placement. This placement option has been title “The Learning Institute”. SE 51 Special Education Teacher Certification Yes Department Database All special education teachers at Codman Academy Charter school are appropriately credentialed. 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 Corrective Action Not Effective The charter school does not have a Parent Advisory Council (PAC) in place; there are no officers or bylaws. The charter school told the Department in December 2006 that it did not have a PAC due to a lack of parental interest. The charter school must provide evidence that outreach has been made to parents regarding the PAC. The charter school must provide to the Department a copy of their PAC bylaws and evidence of outreach to parents. Please submit this to the Department by July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 5 of 27 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 56 Evaluation of Program 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting Corrective Action Not Implemented In progress reports submitted to the Department on February 28, 2005 and reviewed on May 18, 2005 it was indicated that the charter school had identified the components of its program evaluation. The charter school was required to provide the results of its program evaluation in September 2005. The progress reports due in September 2005 were provided to the Department on August 7, 2006. The progress report indicated that the results of the program evaluation were attached, however there was no evidence provided, and the charter school also failed to provide them during the on-site visit conducted December 18, 2006. The charter school must provide the summaries from the 2005-2006school year and the 2006-2007 school year special education program evaluations or otherwise demonstrate the program evaluation activities undertaken by the charter school. The corrective action is due to the Department on July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 6 of 27 Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 7 of 27 Criterion Number and Topic Criterion Implemented Method(s) of Verification No Student record review and staff interview Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Corrective Action Not Implemented As noted in the district’s 2004 Coordinated Program Review, the student record review demonstrated that there was no evidence of the student’s transition needs discussed or documented in the student’s record. The charter school is not using the transition planning form. Please note that recently enacted IDEA-2004 regulations have changed the requirements for transition planning. The transitionplanning chart has become a mandated form, which should be maintained with the IEP, Refer to Administrative Advisory SPED 2007-1 for guidance at http://www.doe.mass.edu/sped/ advisories/07_1.html or the Department’s guidance on transition planning at http://www.doe.mass.edu/sped/ links/transition.html. Special Education Criteria created or revised in response to IDEA-2004 SE 6 ##1 - 3 Determination of Transition Services Please review the new requirements for transition planning and services with the appropriate staff. The charter school needs to train staff on the determination of transition Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 8 of 27 services. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by July 14, 2007. Additionally, the charter school needs to submit evidence that it has conducted an internal monitoring to determine implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted, including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this to the Department by December 7, 2007. SE 8 IEP Team composition and attendance Partial Student record review and staff interview Partial Record review demonstrated that parents and general education staff were inconsistently attending Team Meetings. In some instances student records did not even contain a signed attendance sheet. The charter school needs to develop procedures to ensure the participation of general education teacher in Team meeting, as well as be able to demonstrate multiple efforts to secure parent participation. Please provide a copy of the procedures developed to the Department by July 14, 2007. Additionally, the charter school needs to submit evidence that it has conducted an internal monitoring to determine implementation of this Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 9 of 27 requirement. Please submit a narrative summary of the monitoring activities conducted, including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this to the Department by December 7, 2007. SE 12 Frequency of re-evaluation SE 13 Partial Student record review and documentation Partial Student Student record review and documentation demonstrated that the charter school does not always conduct reevaluations in a timely manner. It was noted that in some instances there was a lapse in the ending period of an IEP due to testing exceeding the required timelines. The school needs to develop a tracking system for due dates of three year re-evaluations and the completion of evaluations in a timely manner. Submit by a detailed narrative describing this tracking system to the Department by July 14, 2007. Student record review Please provide a sample of 4 Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 10 of 27 Once the tracking system has been completed the charter school must conduct a review of sample IEPs developed after implementation of the tracking system to identify if the system was effective. Please provide the Department a detailed narrative summary including the number of IEPs reviewed, rate of compliance and a description of any additional steps taken if noncompliance if found. Please submit this to the Department by December 7, 2007. Progress Reports and content Partial record review Partial indicated that for the 2005-2006 school year that the special education teacher was writing and signing off on all progress reports, including progress reports related to speech therapy. progress reports from the 20062007 school year that demonstrate that progress reports are generated by the appropriate service provider. Please submit this sample to the Department by July 14, 2007. Refer to Administrative Advisory SPED 2007-1 for guidance at http://www.doe.mass.edu/sped/ advisories/07_1.html and the revised Progress Report form at http://www.doe.mass.edu/sped/ iep/forms/word/Form_PR.doc. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 11 of 27 Criterion Number and Topic Criterion Implemented Method(s) of Verification SE 14 Review and revision of IEPs Partial Student record review and staff interview SE 25B Resolution of disputes Yes Basis of Determination that Criterion was Implemented Criterion Determined to be Partially Implemented or Not Implemented Partial Documentation and staff interview Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Student record review demonstrated that the charter school does not always reconvene the Team prior to the expiration of the previous IEP. In all cases there was no documented evidence of why this occurred such as parent request to change meeting date. See previous language in SE 12 with regard to developing a tracking mechanism by July 14, 2007. The charter school indicated that there have been no dispute resolution sessions because there have been no rejected IEPs as of December 2006 in the 2006-2007 school year. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 12 of 27 Once the tracking system has been completed the charter school must conduct a review of sample IEPs developed after implementation of the tracking system to identify if the system was effective. Please provide the Department a detailed narrative summary including the number of IEPs reviewed, rate of compliance and a description of any additional steps taken if noncompliance if found. Please submit this to the Department by December 7, 2007. SE 33 Involvement in the General Curriculum SE 39A Procedures for services to eligible private school students whose parents reside in the district (SE 39A does not apply to charter schools or vocational schools) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state (SE 39B does not apply to charter schools or vocational schools) Yes Staff interview and student record review The charter school indicated that all students are fully participating in the general curriculum, that someone familiar with the curriculum is attending team meetings and IEP’s reflect the student’s participation in the general curriculum. Not Applicable Codman Academy is a charter school and this criterion does not apply. Not Applicable Codman Academy is a charter school and this criterion does not apply. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 13 of 27 SE 46 Procedures for suspension of students with disabilities more than 10 days Yes Staff interview and documentation The charter school has procedures in place and has indicated to the Department that no special education student at Codman Academy Charter School has been suspended for more than ten days. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 14 of 27 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification MOA 10A Student Handbook and Code of Conduct Yes Documentation The printed handbook has all required elements. MOA 16 Notice to students 16 or over leaving school Yes Documentation The charter school has an appropriate policy and procedure in place for students 16 or over who wish to leave school. (Refer to full text of 20062007 CPR requirements) 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 Civil Rights (MOA) and Other General Education Requirements Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 15 of 27 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Other Regulated Programs Monitored During this Mid-cycle Review Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 7 Age of Majority Approved Corrective Action Implemented and Effective Method(s) of Verification No Student record review and staff interview Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Corrective Action Not Implemented Student record review and an interview with staff demonstrated that the charter school is not informing the student of their decision making rights one year prior to attaining age 18. Further it was noted that the charter school is not documenting those instances when the student decides to share or designate someone other than himself or herself as the decision-maker. The charter school needs to train staff on the age of majority requirements. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 16 of 27 Additionally, the charter school needs to submit evidence that it has conducted an internal monitoring to determine implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted, including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this to the Department by December 7, 2007. SE 21 Extended Day/Year SE 22 IEP Implementation and Availability Partial Partial Student record review and staff interview Partial Student record review and staff interview Partial Student records demonstrated that IEPs referred to the student attending a summer program, however an interview with a staff member revealed that the only summer programming offered is assistance in finding some work or internships and occasionally assisting a student in identifying counseling available in the community. The staff member indicated there is no programming available to offer special education services in the summer months and Teams do not routinely consider extended or shortened days in relation to special education needs as all students at Codman Academy participate in a longer day and longer year. The charter school needs to train staff on school day and school year requirements as they relate to special education. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by July 14, 2007. Student record review demonstrated that five of the ten-reviewed student records contained expired IEPs and current IEPs that had no parent signature. A staff The charter school needs to train staff on IEP implementation requirements related to parental consent. Please provide a dated training Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 17 of 27 Additionally, the charter school needs to submit evidence that it has conducted an internal monitoring to determine implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted, including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this to the Department by December 7, 2007. member indicated that getting parents to attend Team Meetings and sign proposed IEP’s is extremely difficult. This staff person further indicated that the charter school implements the IEP while trying to secure parent consent. It was also noted that files did not document the efforts of the charter school to obtain parental consent. SE 24 Notice to Parents Partial Student record review Partial The student record review revealed that notices, specifically N1 and N2 forms lack sufficient detail and fail to address the six key questions as required. The Department found that notice narratives were in some instances cut and pasted from year to year. Furthermore, in one file there was no N1 form related to the current IEP present in the file at all. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 18 of 27 agenda, copies of the materials used and signed attendance sheet to the Department by July 14, 2007. The charter school must submit evidence that it has conducted an internal monitoring to determine implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this by December 7, 2007. The charter school needs to train staff on how to write complete N1 and N2 notices. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by July 14, 2007. Additionally, the charter school needs to submit evidence that it has conducted an internal monitoring to determine implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted, including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this to the Department by December 7, 2007. SE 35 Assistive Technology Partial Student record review Partial Student record review and a staff interview indicated that the charter school is not routinely considering assistive technology, has no mechanism for assistive technology assessments and is not appropriately indicating on the IEP PLEP B page when and if assistive technology is made available to the student. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 19 of 27 The charter school needs to train staff on to assess and document assistive technology appropriately. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by July 14, 2007. The charter school must submit evidence that it has conducted an internal monitoring to determine implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the person(s) responsible, the results, and the additional corrective action steps the school has taken. Please submit this by December 7, 2007. Codman Academy Charter School English Learner Education (ELE) Requirements Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 1 Annual Assessment Partial ELE 2 MCAS Participation Partial ELE 3 Initial Identification No 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 indicated that they administer the MELA-O and MEPA to student’s who may be eligible for Limited English Proficient (LEP) services. While the MELA-O and MEPA are appropriate for annual assessment of LEP students’ English language proficiency, they are not appropriate for initial identification purposes. In 2006, neither the MELA-O nor MEPA was administered. The charter school must ensure students are appropriately identified and assessed upon enrollment to determine LEP status. Upon determining the students who are LEP, the charter school must ensure the annual testing of students using the MELA-O and MEPA. This corrective action is due to the Department July 14, 2007. The charter school indicated that they would provide dictionaries in the future if they are available in the student’s native language. However it should be noted that unless students are designated as LEP they are not entitled to this accommodation for MCAS. Please see ELE 1 & ELE 3 regarding the appropriate identification and assessment of LEP students. In the charter schools self assessment they indicated that student’s who were previously identified as Limited English Proficient (LEP) prior to coming to Codman are not identified as LEP at Codman because the parents chose to The charter school should be screening all incoming students who may potentially be limited English proficient using a home language survey in English and the other major languages of the area. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 20 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting have their child mainstreamed. The charter school indicated that while they report having no LEP students, three students have been classified within the school as English Language Learners (ELL) , they do not received Sheltered English Instruction nor do they receive any English language instruction. The charter school needs to develop a home language survey for enrolling students and develop a procedure to assess their level of English proficiency in reading, writing, speaking, and listening. These procedures along with a copy of the home language survey need to be submitted to the Department by July 14, 2007. ELE 4 Waiver Procedures No The charter school indicated that this criterion was not applicable to them, however as a public school with students who may be LEP this is incorrect. The charter school needs to develop waiver policies, procedures and forms. Please submit these to the Department by July 14, 2007. ELE 5 Program Placement and Structure No The charter school indicated that their policy is to mainstream English Language Learners into regular education classrooms and provide support specifically tailored to their needs. The charter school did not indicate what kind of supports they typically provide to their “ELL” students and as of December 2006 there were no teachers who have participated in training related to Sheltered English Instruction and the school was not teaching English language acquisition to those students. The charter school must develop a plan for addressing program placement and structure for LEP students. This plan must include a timeline for program development including provision of language acquisition support and sheltered English instruction. Please provide this detailed narrative plan to the Department by July 14, 2007. Documentation provided by the charter school clearly indicates that they are operating in an opt-out model without informed consent from the parents. Any general education classroom in a public school in which LEP students are placed must conform to standards under M.G.L.c. 71A. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 21 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 6 Program Exit and Readiness No Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Because the charter school has no programming in place, the charter school indicated that this criterion was not applicable. Required Corrective Action, Timelines for Implementation, and Progress Reporting The charter school must put in place procedures to determine when students are ready to exit the English Language Education program. Please provide this detailed narrative procedure to the Department by July 14, 2007. ELE 7 Parent Involvement No The charter school indicated that it has a parent association open to all parents, however they failed to provide any information or description of how parents of LEP students are involved in matters pertaining to their child’s education. Please provide a detailed narrative of how the charter school plans to involve parent’s of LEP students in matters pertaining to their child’s education. Please provide this detailed narrative plan to the Department by July 14, 2007. ELE 8 Declining Entry to a Program The charter school indicated that by parent’s choosing to enroll their child in Codman Academy Charter School that they have chosen to mainstream their child, however in the Department’s review of the schools submission, we do not believe that these parent’s have made a fully informed and documented decision to decline entry into an ELE program. Parents of English language learners may notify the district or charter school of their wish to have their child “opt-out” of an ELE program. The district must then place the student in an English language general education classroom and document the parent’s notice in the student’s file. The school must develop procedures to monitor the student’s progress and keep parents informed of their student’s progress. The charter school must develop a policy and procedure to give the parent a choice and then document that choice in the student record. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 22 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting Please provide the policy and procedure along with any related forms to the Department by July 14, 2007. ELE 9 Instructional Grouping No The charter school has no program and therefore groups students by grade level alone. The charter school stated that classes are heterogeneously grouped as a response to this criterion. The charter school must arrange grouping of students to ensure that LEP students receive effective content instruction at appropriate academic levels and that ESL/ELD instruction is at the appropriate proficiency level and based on the English Language Proficiency Benchmarks and Outcomes. Please develop a plan to address this issue and submit it to the Department by July 14, 2007. ELE 10 Parental Notification No The charter school indicated that this criterion was not applicable and made no submission related to this criterion. Upon placement in an ELE program the charter school must inform the parent of program placement and/or the method of instruction used in the program; how the program will meet the educational strengths and needs of the student; how the program will specifically help the child learn English; the specific exit requirements; and the parents’ right to apply for a waiver (see ELE 4), or to decline to enroll their child in the program. Please provide a detailed narrative of how the charter school plans to address parental notification and submit it to the Department by July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 23 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 11 Equal Access to Academic Programs and Services No ELE 12 Equal Access to Nonacademic and Extracurricular Programs Partial ELE 13 Follow-up Support No Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The charter schools response to this criterion was “Our policy at Codman is to mainstream ELL students into regular classes and provide support specifically tailored to their needs.” Required Corrective Action, Timelines for Implementation, and Progress Reporting The charter school needs to describe in detail how LEP and FLEP students have equal access to academic programs and services. Please provide a detailed narrative of how the charter school plans to address equal access and submit it to the Department by July 14, 2007. The charter school indicated that they offer an extended year and extended day program, which is required of all students. The school also indicated that extracurricular electives are required and all students must participate. The charter school needs to describe in detail what supports are available to LEP students to ensure equal access to nonacademic and extracurricular programs. Please provide a detailed narrative of how the charter school plans to address equal access and submit it to the Department by July 14, 2007. The charter school indicated that this criterion was not applicable and made no submission related to this criterion. The charter school needs to describe in detail how FLEP students are monitored and how follow-up support is provided, if needed. Please provide a detailed narrative of how the charter school plans to address FELP follow-up support and submit it to the Department by July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 24 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 14 Licensure Requirements No 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 indicated that this criterion was not applicable and made no submission related to this criterion. Please provide a response to this criterion as part of the ELE 5 submission. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 25 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 15 Professional Development Requirements No Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The charter school indicated that ELL professional development for staff was schedule for January 17, 2007 and May 23, 2007. No further details were provided. Required Corrective Action, Timelines for Implementation, and Progress Reporting Charter schools and school districts with LEP students must implement a professional development plan that provides teachers and administrators with high quality training, as prescribed by the Department, in (1) second language learning and teaching; (2) sheltering content instruction; (3) assessment of speaking and listening; and (4) teaching reading and writing to limited English proficient students. http://www.doe.mass.edu/ell/profdev/SEIPDguidelines.doc Please a detailed narrative of how the charter school plans to achieve this and submit it to the Department by July 14, 2007. ELE 16 Equitable Facilities Yes All students at Codman Academy Charter school utilize the same facilities. ELE 17 Program Evaluation No The charter school has no program in place. No program evaluation has been conducted. Please provide a detailed narrative of how the charter school plans to evaluate its ELE program. Please provide a detailed narrative of this process to the Department by July 14, 2007. Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 26 of 27 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Not applicable – this criterion will be reviewed during the next CPR visit in 2009. Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Codman Academy Charter School Coordinated Program Review Mid-cycle Report June 11, 2007 Page 27 of 27 Required Corrective Action, Timelines for Implementation, and Progress Reporting