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 30, 2006 Anthony Fernandes Superintendent Dedham Public Schools 1106 High Street Dedham, MA 02026 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Fernandes: Enclosed is the Department's Coordinated Program Review Follow-up Monitoring Report together with findings regarding your district’s Coordinated Program Review Mid-cycle Review. This report contains the Department's findings based on the onsite activities conducted in your school district to verify the implementation status and effectiveness of corrective steps taken in response to your Coordinated Program Review Report issued on August 23, 2002. 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 2007/2008 school year, unless the Department determines that there is some reason to schedule this visit earlier. While the Department of Education found certain noncompliance issues to be resolved, others were partially corrected, not addressed at all and/or new issues were identified by the Department’s onsite team. In areas where the district has failed to implement fully its approved Corrective Action Plan, the Department views these findings to be serious. As the Department previously informed you, in cases where a district fails to fully and effectively implement a Corrective Action Plan, which was proposed by your district and approved by the Department, the Department must then prepare a Corrective Action Plan for the district, which must be implemented without further delay. You will find these requirements for corrective action and further progress reporting included in the attached report together with any steps that must be taken by the district to fully implement new special education requirements. Please provide the Department with your written assurance that 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 Department's Onsite Chairperson by February 15, 2006. The district’s continuing failure to implement the required Corrective Action Plan described in this report will result in recommendation to the Commissioner of Education the withholding of state or federal funds and/or other enforcement action by the Department. Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Onsite Team Chairperson at 781-338-3733. Sincerely, Nathan Lemmon, Coordinated Program Review Follow-up Chairperson Program Quality Assurance Services John D. Stager, Administrator Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Dimitria Sullivan, School Committee Chairperson Dan Needham, District Program Review Follow-up Coordinator Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW Dedham Public Schools ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on October 11, 2002 Progress Reports Submitted on May 23, 2003, November 18, 2003, June 28, 2004, December 23, 2004 Onsite Visit CPR Conducted on April 1-5, 2002 / Mid-Cycle Review March 22-23, 2005 Date of this Report January 30, 2006 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Special Education Requirements SE 3 Special requirements for determination of specific learning disabilities Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Implemented Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Student Records, Staff Interviews The district does implement the special requirements for determining eligibility for Specific Learning Disabilities. Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 6 Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Evaluation Team Composition Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Partially Implemented Student Records, Staff Interviews Records and interviews indicate that for students 16 years of age or older, the Team includes in the IEP services that promote movement of the student from school to post school activities. Partial Student records indicate that for students 14 years of age or older the district does not always document the consideration of the student’s course of study in relation to the student’s future goals and document this in the IEP. Note: Changes in IDEA include a greater focus on older students’ transition to post school activities. Review a sample of student records for evidence of transition plans completed during the 2005-2006 SY that include the consideration of students’ course of study in relation to future goals and submit to the Department by March 31, 2006. Please include any steps taken by the district to correct noncompliance if found and the person responsible for implementing corrective action pertaining to this criteria. Partially Implemented Student Records, Staff Interviews Student records indicate that the district does provide a person knowledgeable of special education services in the district and the general curriculum. Partial Student records and interviews indicate that some evaluation teams do not include a teacher who has recently had or currently has the The Special Education Administrator will need to develop a system of oversight to ensure that Team meetings are comprised of all the required members. Please provide a description of the Determination of transition services (Emphasis on practices in determining needed transition planning and services and consideration of courses of study related to needed transition) SE 8 Comments Regarding Corrective Action Plan Implementation 2 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting student in a classroom or other teaching situation. oversight system including activities, person(s) responsible and date(s) of implementation. Please also document with the Department that a memo has been sent to all Special Education Teachers, Principals and Team Chairpersons on the requirements of 603 CMR 28.02(21) and IDEA 2004 Section 614 (d)(1)(C); 614(f) by March 31, 2006. 3 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 9 Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Student records indicate that special education progress reports do not always contain a statement predicting if the student will achieve the annual goal(s) set forth in the IEP. Please conduct training with Special Education Team Chairpersons and Special Education Teachers on the requirements to include information on the extent to which progress toward annual goals in the IEP is sufficient to enable the child to achieve the goals by the end of the year. Implemented Student Records, Staff Interviews Student records and interviews indicate that the district determines a student is eligible for special education, provides the parent with a copy of the proposed IEP and placement or written explanation of a finding of no eligibility within 45 school working days of the parent’s signed written consent for an initial evaluation or re-evaluation. Partially Implemented Student Records, Interviews Interviews indicate that district staff are aware of the requirement to send progress reports as often as students receive reports cards. Eligibility Determination SE 13 Progress Reports and content Comments Regarding Corrective Action Plan Implementation 4 Partial Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Provide to the Department of Education by March 31, 2006 evidence of training to include: 1. Attendance; 2. Copies of materials used; 3. Agenda. Please conduct a random review of IEP progress reports to check that this element is fully in compliance at all levels in the district and report the results taken from the 2005/2006 SY. Report to the Department by May 31, 2006. Also report to the Department steps taken by the district if non-compliance is found during the review and the person responsible for ensuring that this criterion is met by May 31, 2006. 5 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation SE 15 Outreach by the School District (Child Find) Implemented Student Records, Interviews Interviews and documentation indicate that the district has annual or more frequent outreach and continuous liaison with groups from which promotion or transfer of students in need of special education may be expected. SE 17 Implemented Student Records, Interviews Documentation and interviews indicate that the district encourages referrals from Early Intervention Services, other agencies and individuals for young children when or before the child turns two-and-one-half years old in order to ensure continuity of services and to ensue the development and implementation of IEPs for eligible children. Initiation of services at age three and Early Intervention transition procedures Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified 6 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 18A IEP development and content Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Student records also indicate however, that IEP goals are not always measurable enough to be useful when reporting on progress because of the inherent subjective nature of the guidance in how the annual goals in the IEP are measured. Please conduct training with Special Education Team Chairpersons and Special Education Teachers on the requirements to include a description of objective benchmarks. Provide to the Department of Education by March 31, 2006, evidence of training to include: 4. Attendance; 5. Copies of materials used; 6. Agenda. Partially Implemented Student Records, Interviews Interviews indicate that when students are eligible for special education, the Team, including the parent(s), develops an IEP at the meeting using the evaluation data to guide the Team. Partially Implemented Please conduct a random review of IEP progress reports to check that this element is fully in compliance at all levels in the district and report the results taken from the 2005/2006 SY. Report to the Department by May 31, 2006. Also report to the Department steps taken by the district if 7 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting non-compliance is found during the review and the person responsible for ensuring that this criterion is met by May 31, 2006. *Please note that for the 2005/2006 SY, Teams are required to continue to use objectives or benchmarks for all students to meet the requirements of a description of how the goals will be measured. 8 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 18B Determination of placement; immediate provision of IEP to parent Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Student records indicate that in some IEP plans, on the service delivery grid, the words “Resource Room” appears as the “Service” and the generic term, “Sped” are written for Service Providers. Conduct training with all staff assigned as IEP chairpersons and those who on any occasion fulfill the chairperson’s role on the requirement to indicate on the service delivery grid the specific type of teacher, (e.g. Special Education Teacher or Regular Education Teacher), on the service delivery grid of the IEP form. (Page 5) Please provide to the Department by March 31, 2006: 1) Agenda; 2) Sign-In Sheet; 3) Copies of Materials Used. Please also conduct a review of records from the 2005/2006 School Year at all levels in the district to determine compliance with this element and report the results to the Department of Education by May 31, Partially Implemented Student Records, Interviews Following IEP development, Teams determine the appropriate placement to deliver the services on the student’s IEP. 9 Partially Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting 2006. Please include any steps taken by the district to correct non-compliance if found and the person responsible for implementing corrective action pertaining to this criteria. 10 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 20 Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion IEP implementation and availability (Emphasis on provision of IEP services without delay; provision of the IEP at the beginning of the school year; and, alternative methods of service delivery Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Implemented Student Records, Interviews The district selects programs for students in their least restrictive environment with consideration to any potential harmful effect on the student or on the quality of services that he or she needs. Implemented Student Records, Interviews Where the IEP of the student in need of special education has been accepted in whole or in part by that student’s parent, the school district provides the mutually agreed upon services without delay in the district. Least restrictive program selected SE 22 Comments Regarding Corrective Action Plan Implementation 11 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified where there is a lack of space and/or personnel)) 12 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 26 Parent participation in meetings (Emphasis on district’s attempts to ensure parent participation at IEP Team meetings) SE 27 Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Implemented Implemented SE 28 Implemented Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Student Records, Interviews The district notifies parents in writing of any Team meeting early enough to ensure that they have an opportunity to attend. Student Records, Interviews The Consent to Evaluate (N1A) form contains the required elements set forth in M.G.L. c. 71B Section 3 and in federal law. Student Records, Interviews Staff interviews and student records indicate substantial compliance with the requirement for immediate provision of the IEP to Content of Notice Parent provided the IEP or notice of no eligibility Comments Regarding Corrective Action Plan Implementation 13 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) together with notification of procedural safeguards and parents' rights Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified parents with notification of procedural safeguards and parent’s rights. 14 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 29 Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Records and interviews indicate that the district does not provide written translated documents for parents/guardians when needed. The district does not have a consistent procedure for the identification of students or parents /guardians who may require translated information or interpreters. The district must develop procedures and implement them district-wide for identifying the primary language of the home. The district must also develop procedures for securing interpreters and providing translated documents to parents/guardians who are speakers of languages other than English. These procedures must be reviewed with all district administrators and fully implemented by January 1, 2006. Please provide copies of the procedures and evidence of the review with district administrators to the Department by March 31, 2006. Partially Implemented Student Records, Interviews Interviews indicate that some district communications with parents whose primary language is not English have been provided via translators at Team meetings. Implemented Student Records, Interviews The on-site Team found that the district has established a Communications are in English and primary language of home SE 32 Parent advisory Comments Regarding Corrective Action Plan Implementation 15 Partially Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) council for special education Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Parent Advisory Council for Special Education that meets the requirements of Chapter 71B, Section 3; 603 CMR 28.07(4). 16 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 36 Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district has not fully documented that all out-of-district IEP plans are monitored for full implementation of services consented to by parents. Provide to the Department by March 31, 2006, a plan for how the district will document the monitoring of all out-ofdistrict IEP plans to include: 1) Log of visits to school; 2) Dates of other communications with school; 3) Notes on communications with school; 4) Notes/Dates on communications with parent of student. Partially Implemented Student Records, Interviews Documentation and student records indicate that the district ensures IEPs are implemented without delay upon parent consent. Implemented Student Records, Interviews The principal with the assistance of the Administrator of Special Education coordinates the delivery and supervision of special education services within each school building. IEP Implementation, Accountability and Financial Responsibility SE 50 Responsibilities of the School Principal and Administrator of Special Education Comments Regarding Corrective Action Plan Implementation 17 Partially Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Partially Implemented Documentation regarding training in methods of collaboration among staff to accommodate diverse learning needs of all students and training for transportation providers was not provided. Please provide documentation that these trainings occurred during the 2005-2006 school year by May 31, 2006. Partially Although the district The district must provide to the SE 54 Professional development regarding special education Partially Implemented Student Records, Interviews Documentation and interviews indicate the district considers the needs of all staff in developing training opportunities for professional and paraprofessional staff and provides a variety of offerings. SE 56 Implemented Student Records, Interviews The district develops methods for determining the effectiveness of programs in assisting students with disabilities to achieve the goals set forth in their IEPs in the least restrictive environment. Partially Documentation, Interviews and Special education programs and services are evaluated Other Requirements MOA 1 18 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Identification of LEP Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Staff Interviews documentation provided to the Department indicate that the district has a process for identifying LEP (Limited English Proficiency) with students in order to determine language needs. A Home Language Survey is offered in 10 different languages including English. 19 Implemented Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting states that it uses “objective Assessment Criteria” to measure the degree of limited English proficiency, and although it does list the names of staff providing ESOL (English to Speakers of Other Languages) services, there is no specific information as to what assessments are used to determine LEP (Limited English Proficiency) or who specifically administers the assessments, what the district’s criteria are for determining LEP from the assessments or if the persons assigned to give the assessments have been Department by March 31, 2006 the following: 1) What specific objective assessment criteria is used to determine limited English proficiency for students identified as needing testing as a result of the outcome of the Home Language Survey to include the name(s) of the assessment(s) and the specific criteria; 2) A specific list of the staff in the district who administer the assessments used by the district to determine LEP; 3) Documentation that the staff administering LEP assessments have been trained to do so, to include the location, dates, providers and Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting trained to do so. MOA 2 Support Services for LEP Partially Implemented Documentation, Staff Interviews At the time of the MidCycle review, the district reported having identified 120 students district-wide as being Limited English Proficient. See ELE 5 for the finding and reporting requirements. MOA 6 Availability for Services for Pregnant Students Implemented Student Records, Interviews Documentation indicates that the district permits pregnant students to remain in regular classes and participate in extracurricular activities with non-pregnant students throughout their pregnancy, and after giving birth are permitted to return to the same academic and extracurricular program as before their leave. 20 Partial copies of materials used in the training. See ELE 5 for reporting requirements. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district has not provided evidence that translations for general announcements, extracurricular activities and other opportunities have been completed and disseminated to persons whose primary language is other than English who reside in the community. Provide copies of examples and an explanation of dissemination methods for school and program recruitment and promotional materials that are provided to persons in the community who are speakers of language other than English by March 31, 2006. MOA 7 Translations into Languages other than English Partially Implemented Student Records, Interviews The district has provided the Department with its plans to provide translated documents and handbooks/policies through Catholic Charities and Global Link Translations. Also the district has provided information about a link on the Dedham Website to audio versions of School Committee policies, a short summary of Federal Education Laws and a short summary of State Laws pertaining to education. The audio versions are computer generated. MOA 13 Availability of Information and Counseling on General Implemented Student Records, Interviews Interviews and documentation provided by the district indicates that the district does make available information on general 21 Partially Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district has not documented that it has developed and implemented staff training at least annually on the use of restraint consistent with regulatory requirements. Document with the Department by March 31, 2006 that training has occurred for all staff on the use of restraint consistent with the requirements for the 2005-2006 school year to include: 1) Training for staff who may have been hired after the start of the school year; 2) Copies of materials used during the training on the topic of physical restraint; 3) A copy of the district policies (including reporting procedures) for the implementation Curricular and Occupational Vocational opportunities MOA 17A Use of Physical Restraint Comments Regarding Corrective Action Plan Implementation curricular and occupational vocational opportunities. Partially Implemented Student Records, Staff Interviews Interviews and documentation indicate that the district administers physical restraint on students only when needed to protect a student and/or a member of the school community from imminent, serious, physical harm. 22 Partial Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting of Board of Education Restraint Regulations; 4) Attendance sheet with names of staff in attendance for training in this area. MOA 24 Curriculum Review Implemented Student Records, Staff Interviews Interviews indicate that the district does have an internal process for monitoring and reviewing its curriculum. ELE 1 Annual Assessment Partially Implemented Interviews and Documentation The district has submitted a general statement that English Language Learners are assessed using multiple criteria, “including standardized testing (MEPA and MELA-O), work samples, observation and report cards. An ESOL progress report is sent home, along with the standard report card.” Also, the 23 Partially Implemented District documentation and staff interviews indicate: The district has not provided details as to its implementation policies, formal decision-making process, or guidelines for staff to follow Provide documentation to the Department by March 31, 2006 that appropriate district staff have been trained to administer the required annual assessments for all limited English proficient (LEP) students to include the Massachusetts English Proficiency Assessment (MEPA) in grades 3-12 and the Massachusetts English Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting based on the requirements of Chapter 71A. Language Assessment – Oral (MELA-O) in grades K-12. district has provided copies of the Fall 2004 MEPA test results and other assessment results for individual students and the district. See reporting requirements under MOA 1 and ELE 5. The district did not provide documentation that appropriate district staff have been trained to administer the required annual assessments for all limited English proficient (LEP) students to include the Massachusetts English Proficiency Assessment (MEPA) in grades 3-12 and the Massachusetts English Language Assessment – Oral (MELA-O) in 24 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting grades K-12. ELE 2 MCAS Not Implemented The district has not documented, or mentioned, that LEP students are receiving MCAS accommodations per se. The district has not provided the Department with a plan to implement the provision of bilingual dictionaries and/or electronic translators to LEP students and has not provided a plan to inform parents/guardians of their option to not take the MCAS English Language Test during the first 25 Provide the Department with a plan to implement the provision of bilingual dictionaries and/or electronic translators to LEP (Limited English Proficient) students for MCAS and provide a plan to inform parents/guardians of their option to not take the MCAS English Language Test during the first year following original LEP identification status by March 31, 2006 . Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting year following original LEP status. ELE 3 Initial Identification Partially Implemented Interviews and Documentation The district has included copies of the Home Language Survey in ten different languages including: Tagalog, Russian, Italian, Creole, Greek, Gujarati, Chinese, Portuguese, and Spanish. ELE 4 Waiver Procedures 26 Partially Implemented The district did not include what is the criterion for entry to their English Learner Education program. (See Requirements MOA 1) Not Implemented District documentation and staff interviews indicate: The district must develop waiver implementation procedures, including a local The district has no 1) description of waiver implementation practices; 2) no copy of a local waiver form; and 3) no class roster of students who have been waiver form by March 31, 2006. Please also provide a log all children who have been waived if applicable. . Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting waived. ELE 5 Program Placement and Structure Not Implemented District documentation and staff interviews indicate: The district has not provided a description of its English Language Learner programs and has not documented evidence of professional development for general education teachers to provide SEI (Structured English Immersion) services. The district has described in its MOA 27 Explain how the district intends to deliver an English Language Learner program consistent with the requirements of Chapter 71A. Provide a list of all LEP students by initials, what grade level and school building, and identify their general education teacher(s) by name for the 2005-2006 SY. Identify specifically what training has been provided or will be provided in this school year for all core academic teachers in sheltered English instruction (SEI) who currently have Limited English Proficient students in their classrooms. Further, identify the staff by Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting 1 and MOA 2 documentation that, “Sheltered English instruction will be provided by the Sheltered Instruction Observation Protocol) method of instruction. (The Department notes that implementation guidance, http://www.doe.mass. edu/ell/sei/ describes in detail, the specific and required effective practices for implementation of Chapter 71A. name and building, who provide English language development instruction. Provide copies of their licenses or waivers. Also, indicate the provisions the district will make to secure qualified staff for providing instruction in English language skills. This information is due to the Department by March 31, 2006. District documentation and staff interviews indicate: Provide a description of the district’s implementation practices for program exit and readiness. ELE 6 Program Exit and Readiness Not Implemented 28 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The district did not respond to this particular criterion during the current mid-cycle review. Describe the district’s exit criteria from ELE (English Language Learner) programs and services by March 31, 2006. The district provided no description of its implementation practices in this area or its program exit criteria. ELE 7 Parent Involvement Not Implemented 29 District documentation and staff interviews indicate that the district has not developed a mechanism for including parents or guardians of LEP students in matters Describe the district’s implementation practices in this area. Develop a mechanism for including parents or guardians of LEP students in matters pertaining to their children’s education. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting pertaining to their children’s education. ELE 8 Declining Entry into a Program Not Implemented 30 District documentation and staff interviews indicate that the district has not developed a plan describing how it will provide English language support to students whose parents have declined entry to a sheltered English immersion, Note: The district should provide multiple opportunities and a variety of methods for parent-teacher communication and document the availability of such opportunities. This information is due to the Department by March 31, 2006. Describe the implementation plan for providing supports to LEP students whose parents decline entry into an ELE program by March 31, 2006. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting two-way bilingual, or other ELE program. ELE 9 Instructional Grouping Not Implemented District documentation and staff interviews indicate that the district has not developed a plan describing how it will group students of different ages and ensure that LEP students receive effective content instruction at appropriate academic levels based on the Massachusetts curriculum frameworks. Describe the implementation plan for appropriate instructional groupings consistent with this criterion by March 31, 2006. ELE 10 Parental Not Implemented District documentation and Describe how the district will meet the requirements for 31 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting staff interviews indicate that the district has not developed a plan describing how it will provide information to parents of LEP students describing the district’s ELE program and informing parents’ of their rights to apply for a waiver (ELE 4) or their rights to decline to enroll in the program (ELE 9). parent notification by March 31, 2006. District documentation and staff interviews indicate that the district has not developed a plan describing how it will provide equal access Describe the district’s plan for ensuring LEP students have equal access to all of the district’s academic program offerings by March 31, 2006. Notification ELE 11 Equal Access to Programs and Services Not Implemented 32 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting to all LEP students to the full range of academic opportunities and supports afforded non-LEP students. ELE 12 Equal Access to Nonacademic and Extracurricular Programs Not Implemented Although the district has provided a bulleted list and definition of equal access, no statement is included as to how the equal access concept is specifically applied in the Dedham Public Schools. District documentation and staff interviews indicate that the district has not developed a plan describing how it will 33 Describe the district’s plan for ensuring LEP students have equal access to non-academic and extra-curricular activities by March 31, 2006. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting provide equal access to all LEP students to the full range of nonacademic and extracurricular programs afforded non-LEP students. ELE 13 Follow-Up Support Not Implemented 34 District documentation and staff interviews indicate that the district has not developed a plan describing how it will monitor and if necessary, provide services for students who have been identified as no longer limited English proficient (FLEP) as well as to the extent possible, provide access to adult basic Describe the district’s plan to provide follow-up support for students who have exited the ELE program by March 31, 2006. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting education in English language and literacy skill instruction for LEP students who were previously enrolled in a public secondary school in the Commonwealth. ELE 14 Licensure and Fluency Requirements Not Implemented 35 Although the district has provided information with regard to staff who hold ESOL Professional Licensure in Massachusetts as well as the backgrounds and experiences of several of the core academic teachers assigned to teach students with limited English proficiency however as noted in Provide copies of all applicable teacher licenses and waivers. Provide copies of Personnel Data Sheet #7. This information must be provided to the Department by March 31, 2006. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting ELE 5, the District’s current practices do not comport with the program requirements for Chapter 71A. ELE 15 Professional Development Requirements Not Implemented 36 Although the district has provided a reference to an indistrict training provided by C. Mannal, D. Jovin and M. Bradley on Differentiated Instruction in Language Acquisition using the Sheltered Instruction Observation Protocol method, and although the Content Outline for the instruction appears to include some of the required elements for high Describe the district’s implementation plan for ensuring sustained and intense professional development to staff 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. Provide this information to the Department by March 31, Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting quality training, the plan does not include enough specificity. (There is no description of the duration/depth of the training for example.) 2006. District documentation and staff interviews indicate that the district has not documented specifically how it will implement a professional development plan that provides high quality training for teachers to ensure the progress of LEP students in developing oral comprehension, speaking, reading and writing of English and 37 See also ELE 5. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting in meeting academic standards and curriculum frameworks. ELE 16 Equitable Facilities Not Implemented District documentation and staff interviews indicate that the district has not documented specifically how it will ensure that LEP students are provided facilities, materials and services comparable to those provided to the overall student population. The district must describe how it will ensure that LEP students have access to equitable facilities by March 31, 2006. ELE 17 DOE Submission Requirements and Program Evaluation Not Implemented District documentation and staff interviews indicate that the district has not The district must develop a plan to provide the Department with required data and develop a proposal for evaluating the effectiveness of its ELE 38 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirement s or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemen-ted or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting documented an annual report to the Department of all required information pertaining to the implementation of ELE programs. programs by March 31, 2006. District documentation and staff interviews indicate that the district has not documented a plan for maintaining cumulative records of English Language Learners to include all documents required under 603 CMR 23.05, 23.07; and M.G.L. c 69, § 1I; Title VI The district must develop procedures for appropriate maintenance of information regarding LEP students in student records by March 31, 2006. ELE 18 Records of LEP students Not Implemented 39