The Commonwealth of Massachusetts Department of Education

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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
August 3, 2007
William J. Simmons, Ed.D., J.D.
Superintendent of Schools
Easton Public Schools
50 Oliver Street
P.O. Box 359
North Easton, MA 02356
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Simmons:
Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted to verify the
implementation and effectiveness of corrective action approved or ordered by the Department to
address findings of noncompliance included in the Easton Public Schools Coordinated Program
Review Report issued on September 8, 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 self-assessment, 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 781338-3534. ELE guidance documents are available on the Department’s website at
http://www.doe.mass.edu/ell/ .
While the Department of Education found your district to have resolved certain noncompliance
issues, others were partially corrected or not addressed at all, or the Department’s onsite team
identified new issues of noncompliance, either noncompliance with special education criteria
added or substantially changed in response to IDEA 2004, noncompliance with ELE criteria, or
other new noncompliance. Where the district has failed to implement its approved Corrective
Action Plan, the Department views these findings to be serious.
1
In all instances where noncompliance has been found, the Department has prescribed corrective
action for the district that must be implemented without delay. You will find these requirements
for corrective action included in the attached report, along with requirements for progress
reporting. Please provide the Department with your written assurance that all of the Department's
requirements for corrective action will be implemented by your district within the timelines
specified. You must submit your statement of assurance to me by August 21, 2007.
Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like
clarification of any part of our report, please do not hesitate to contact me at 781-338-3704.
Sincerely,
Matthew Deninger, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Dawn Boynton, School Committee Chairperson; 8 Squantum Ave; No. Easton, MA
Dr. Beverly Conte, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Mid-cycle Cover Letter 2007.doc
Rev. 11/14/06
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
EASTON PUBLIC SCHOOLS
ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS
Date of Coordinated Program Review (CPR): March 29-30 and April 26-29, 2004
Date of Coordinated Program Review Corrective Action Plan Approval: December 14, 2004
Dates of Corrective Action Plan Progress Reports: April 29, 2005; July 15, 2005; and January 27, 2006
Dates of this Mid-cycle Review Onsite Visit: May 28-29, 2007
Date of this Report: August 3, 2007
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 1 of 16
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
Documentation
Based on the documentation review,
interviews, and record review, transition
services are given to all students beginning at
age 15. Records showed student participation
in Team meetings, transition goals on IEPs,
planning charts in the records, and referrals to
other state agencies if needed.

Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Special Ed.
Criteria Cited
in CPR Report
and Monitored
in Mid-cycle
SE 6
Transition

Review,
Interviews,
Record
Review
* Please note that consistent with the recently
enacted IDEA-2004 regulations, the
transition planning chart will become a
mandated form, which should be maintained
with the student’s IEP. Refer to
Administrative Advisory SPED 2007-1 for
guidance. The Department has revised this
form; please check the Department’s Special
Education website at
http://www.doe.mass.edu/news/news.asp?id=
3295..
Please review the new requirements for
transition planning and services with
appropriate staff. No additional progress
report is required.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 2 of 16
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
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
Documentation
Based on the documentation review,
interviews, and record review, the 45-day
timeline for the determination of eligibility is
adhered to.

SE 9
Eligibility
&
Timelines

SE 18A
IEP
Development

Review,
Interviews,
Record
Review
Documentation
Review,
Interviews,
Record
Review
Documentation
SE 18B
Placement

Review,
Interviews,
Record
Review
Documentation
SE 20
Least restrictive
environment

Review,
Interviews,
Record
Review
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Based on the documentation review,
interviews, and record review, the IEPs were
generally well-written and included all
required elements. However, the
measurability of goals was still inconsistent
across the district.
*Please note that the Department has recently
changed the implementation requirements for
providing an IEP “immediately” following its
development in a Team meeting. Refer to the
“best practice guidance” memo on the
Department’s Special Education website at
http://www.doe.mass.edu/news/news.asp?id=
3182
Please review the new guidance for the
“immediately” standard with appropriate
staff. No additional progress report required.
Based on the documentation review,
interviews, and record review, the nonparticipation justification statements provided
clear reasons for a student’s removal from the
regular education setting.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 3 of 16
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
Criterion
Number/Topic
(Refer to full
text of 20062007 CPR
requirements)
SE 22
IEP
implementation
and availability
Approved
Corrective
Action
Implemented
and Effective
Method(s)
of
Verification
Basis of Determination that Corrective
Action was Implemented and has been
Effective
Documentation
Based on the documentation review,
interviews, and record review, all teachers are
informed of their specific responsibilities for
carrying out what is agreed to on an IEP.

Partial
Review,
Interviews,
Record
Review
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Partial
Basis of
Determination that
Implementation of
Corrective Action
was Incomplete or
Ineffective or
Basis of Finding of
New Noncompliance
Required Corrective
Action, Timelines for
Implementation,
and Progress
Reporting
IEPs written during the
year, changed during the
year by way of team
meeting, and amended
during the year, are not
always distributed to all
necessary staff.
Please analyze each
school’s procedure for
distributing IEPs during
the school year, and
change procedures that
do not ensure that all
teachers are informed of
their responsibilities
immediately when there
is a change. Please
provide the Department
with these procedures no
later than November 1,
2007. The district must
develop a plan for
monitoring the
implementation of
these new procedures
and report the findings
to the Department no
later than March 28,
2008.
Documentation
SE 24
Parental
Notice

Review,
Interviews,
Record
Review
Based on the documentation review,
interviews, and record review, notice forms
contain all required elements, and are sent to
parents/guardians appropriately.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 4 of 16
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
Documentation
Based on the documentation review,
interviews, and record review, notice forms
contain all required elements. Therefore,
when parents provide consent, they are doing
so having been fully informed.

SE 25
Parental
Consent

SE 36
IEP
Implementation
and
Accountability

Review,
Interviews,
Record
Review
Documentation
Review,
Interviews,
Record
Review
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Based on the documentation review,
interviews, and record review, the 45-day
timeline for the determination of eligibility is
adhered to, and IEPs are immediately
implemented after parental consent.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 5 of 16
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
Criterion
Number
and
Topic
Criterion
Implemented

Method(s)
of
Verification
Basis of Determination that Criterion
was Implemented
Criterion
Partially
Implemented
or Not
Implemented

Special
Education
Criteria created
or revised in
response to
IDEA-2004
Documentation
SE 6 ##1 - 3
Determination
of Transition
Services

SE 8
IEP Team
composition
and attendance

SE 12
Frequency of
re-evaluation

Review,
Interviews,
Record
Review
Documentation
Review,
Interviews,
Record
Review
Documentation
Review,
Interviews,
Record
Review
See SE 6 above.
Based on the documentation review,
interviews, and record review, district staff
members are aware of the new IDEA 2004
IEP Team member excusal requirements.
Based on the documentation review,
interviews, and record review, re-evaluation
timelines are consistently adhered to.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 6 of 16
Basis of
Determination that
Criterion was
Partially
Implemented or Not
Implemented
Required Corrective
Action, Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemented

Method(s)
of
Verification
Documentation
SE 13
Progress
Reports and
content

Review,
Interviews,
Record
Review
Basis of Determination that Criterion
was Implemented
Criterion
Partially
Implemented
or Not
Implemented

Based on the documentation review,
interviews, and record review, the progress
reports were distributed along with report
cards, and included all required elements.
*Please note that recently enacted IDEA2004 regulations have now changed the
content requirements for IEP progress
reports. Refer to Administrative Advisory
SPED 2007-1 for guidance. The Department
has changed the progress report form and it is
now available on the Department’s Special
Education website at
http://www.doe.mass.edu/sped/iep/eng_toc.ht
ml.
Please review the new requirements with all
appropriate staff. No additional progress
report required.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 7 of 16
Basis of
Determination that
Criterion was
Partially
Implemented or Not
Implemented
Required Corrective
Action, Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemented

Method(s)
of
Verification
Documentation
SE 14
Review and
revision of IEPs
Partial
Review,
Interviews,
Record
Review
Basis of Determination that Criterion
was Implemented
District staff members are aware that
amendments may be completed without
reconvening a Team.
Criterion
Determined
to be Partially
Implemented
or Not
Implemented

Partial
Basis of
Determination that
Criterion was
Partially
Implemented or Not
Implemented
The onsite team found
that amendments were
routinely used to extend
IEP dates.
Required Corrective
Action, Timelines for
Implementation, and
Progress Reporting
Please change procedures
and provide training for
staff members on the
appropriate use of
amendments. No later
than November 1,
2007, please provide the
Department with
evidence of this training
(sign-in sheets, agendas,
materials, etc.) In
addition, the district must
develop a plan for
monitoring the
implementation of
amendment procedures.
Please report on the
following: 1) the number
of records reviewed;
2) the number found to
be in compliance;
3) the date(s) the
monitoring was
conducted; 4) identify the
person(s) responsible;
and 5) any additional
corrective actions taken
if needed to the
Department no later than
March 28, 2008.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 8 of 16
Documentation
SE 25B
Resolution of
disputes

Review,
Interviews
Documentation
SE 33
Involvement in
the General
Curriculum

SE 39A
Procedures for
services to
eligible private
school students
whose parents
reside in the
district

Review,
Interviews,
Record
Review
Documentation
Review,
Interviews,
Record
Review
Based on the documentation review and
interviews, administrative staff are aware of
these regulations, and will use the procedure
as appropriate. To date, the district has not
needed to use this procedure.
Based on the documentation review,
interviews, and record review, a student’s
involvement and progress in the general
curriculum is measured, discussed among the
IEP Team members, and noted on each IEP.
Based on the documentation review,
interviews, and record review, students in
private schools whose parents reside in
district are given evaluations and, if found
eligible, they may access a full range of
services.
 Please note that consistent with recently
enacted IDEA-2004 regulations, the public
school district’s procedures for consultation
with private schools requires the public
school to obtain written affirmation of the
private school representative’s participation.
Refer to Administrative Advisory SPED
2007-1 for guidance.
No additional progress report required.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 9 of 16
Documentation
SE 39B
Procedures for
services to
eligible students
in private
schools in the
district whose
parents reside
out of state

Review,
Interviews
Based on the documentation review and
interviews, students in private schools whose
parents reside out of state have the
opportunity to access special education
services. However, there are currently no
private schools in Easton.

SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 10 of 16
Based on the
documentation review
and interviews, the
district’s codes of
conduct have not yet
been revised to conform
with the new IDEA 2004
regulations.
Please revise discipline
policies and handbooks,
and provide training for
appropriate staff
members on the new
policies. No later than
November 1, 2007,
please provide the
DOE with the revised
policies and evidence
of this training (sign-in
sheets, agendas,
materials, etc.)
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
Documentation
Based on documentation and interviews, the
district’s pregnancy policy allows pregnant
students to remain in school for as long as
possible.
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Civil Rights
(MOA) and
Other General
Education
Requirements
MOA 6
In School
Programs for
Pregnant
Students

Review,
Interviews
Documentation
MOA 18
(formerly part
of SE 50)
Instructional
Support

MOA 23
Comparability
of Facilities

Review,
Interviews,
Record
Review
Observation,
Documentation
Review
Documentation review, interviews, and
record review indicated that school-based
instructional support teams now have a
balanced mixture of special educator and
regular education staff.
The DOE team toured the newly renovated
Oliver Ames High School. The old A-Wing,
which previously housed Project
Opportunity, has been demolished. The
location of the current program is in a much
more central location, in close proximity to
regular education classrooms and students.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 11 of 16
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
Other
Regulated
Programs
Monitored
During this
Mid-cycle
Review
Documentation
SE 5
MCAS
Partial
Review,
Interviews,
Record
Review
Documentation review, interviews, and
record review indicated that on most IEPs,
MCAS accommodations were consistent with
classroom accommodations
Partial
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 12 of 16
Record review showed
that some students are
receiving
accommodations on
MCAS that they are not
receiving in the
classroom. Furthermore,
the phrase “additional
MCAS accommodations
by teacher discretion,” or
similar language, was
found on some IEPs.
MCAS accommodations
are based on Team
decisions, not on teacher
discretion during test
day.
The district must
conduct training for
appropriate personnel
regarding differences
between MCAS and
classroom
accommodations, and
then develop a plan for
monitoring
assessments in each
school. By November
1, 2007, identify by
role, the person(s)
responsible for
conducting the internal
monitoring. Provide
the Department with
the results of
monitoring activities,
including: the number
of records reviewed
and the rate of
compliance, along with
a description of any
additional steps taken
by the district if noncompliance was
identified by local
personnel.
EASTON PUBLIC SCHOOLS
English Learner Education (ELE) Requirements
Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments
(Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at
http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc )
ELE
Criterion
Number
and
Topic
ELE 1
Annual
Assessment
Criterion
Determined to be
Implemented
Based on Review
of Local ELE
Self-Assessment

Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
District’s procedures indicate that “all students take the MCAS
unless the principal determines that the student is unable to do
so, in which case a waiver is applied for from the DOE.”
Contrary to this procedure, the DOE’s MCAS procedures
require all students to take the MCAS test, regardless of English
proficiency status. The only exception is made for the ELA
portion of the MCAS for students who are in their first year of
schooling in the United States.
The district must change its procedures for student
participation in the MCAS and make all administrative
staff members aware of the revised procedures. Please
refer to the Department’s advisory on this topic at:
http://www.doe.mass.edu/mcas/participation/?section=lep.
No later than November 1, 2007, please provide the
Department with the new procedure, as well as assurance
that all administrators have been apprised of it.

ELE 2
MCAS
Participation
ELE 3
Initial
Identification
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)

Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 13 of 16
ELE
Criterion
Number
and
Topic
ELE 4
Waiver
Procedures
Criterion
Determined to be
Implemented
Based on Review
of Local ELE
Self-Assessment

ELE 7
Parent
Involvement
ELE 8
Declining
Entry to a
Program
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
The district has been providing LEP students with English as a
Second Language tutoring from an uncertified teacher.
The district must provide LEP students with ESL
instruction from an ESL-certified instructor, no later than
November 1, 2007, please provide the Department with
the district’s plan for providing LEP students with ESL
instruction.

ELE 5
Program
Placement
and Structure
ELE 6
Program Exit
and
Readiness
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)



ELE 9
Instructional
Grouping

ELE 10
Parental
Notification

Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 14 of 16
ELE
Criterion
Number
and
Topic
ELE 11
Equal Access
to Academic
Programs
and Services
ELE 12
Equal Access
to
Nonacademic
and
Extracurricular
Programs
ELE 13
Follow-up
Support
ELE 14
Licensure
Requirements
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



See ELE 5.
See ELE 5.
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 15 of 16
ELE
Criterion
Number
and
Topic
Criterion
Determined to be
Implemented
Based on Review
of Local ELE
Self-Assessment

ELE 15
Professional
Development
Requirements
ELE 16
Equitable
Facilities
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
Sheltered English Immersion training has not been provided to
any regular education teachers in the district.
No later than November 1, 2007, please provide the
Department with the district’s plan for providing regular
education teachers with Sheltered English Immersion
training—especially those teachers who have LEP
students in their classes.
The district’s most recent ELE program evaluation was from
the 2003-2004 school year. The program will change as a
result of this review, and thus the program will need to be
evaluated to determine its effectiveness.
No later than November 1, 2007, please provide the
Department with the district’s plan for evaluating its ELE
program. In this plan, please include a timeline, the
criteria the district will use to determine the program’s
effectiveness, and the persons responsible for evaluating
the program.

ELE 17
Program
Evaluation
ELE 18
Records of
LEP
Students(To be
reviewed
during next
CPR visit.)
Mid-cycle Report Format 2007.doc
Rev. 1/3/07
Easton Public Schools Coordinated Program Review Mid-cycle Report
August 3, 2007
Page 16 of 16
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