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 20, 2007 Mr. Frederick Foresteire Superintendent of Schools Everett Public Schools 121 Vine Street Everett, MA 02148 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Foresteire: 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 Everett Public Schools Coordinated Program Review Report issued on September 30, 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 Department’s onsite team identified new issues of noncompliance, either noncompliance 1 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 the Department by September 5, 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 Robert J. Alconada, Everett School Committee, Chairperson Dr. Thomas Stella, Assistant Superintendent, District Program Review Follow-up Coordinator Annetta Kelly, Director of Special Education Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Everett Public Schools ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): May 5-14, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: May 16, 2005 Dates of Corrective Action Plan Progress Reports: October 7, 2005, March 3, 2006, August 25, 2006 Dates of this Mid-cycle Review Onsite Visit: May 30 and 31, 2007 Date of this Report: August 20, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 1 of 33 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 Corrective Action Not Effective Student records indicated that the district does not always assess in the areas of suspected disability. Interviews indicated that information from teachers in the general education setting was often incomplete, resulting in the special education staff being unaware of all areas of suspected delay and the general education steps previously taken to address student concerns. In many instances, because there was not enough data from the general education staff members, the student was not assessed in all areas of disability, which in 4 of The district needs to review their procedure/protocol for selecting appropriate assessment tools based on the suspected area(s) of disability when a student has been referred for special education eligibility determination. Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle SE 2 Required and Optional Assessments No Student records and staff interviews Please see the Department’s comments to the right. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 2 of 33 Please provide a copy of the reviewed and revised procedure/protocol that outlines how the district determines the appropriate required and optional assessments for all area(s) of a student’s suspected disability and the person(s) responsible for ensuring that this procedure/protocol is followed. Please submit 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 the reviewed record resulted in extended evaluations and delay in identifying the student and proposing an IEP by six months or more. SE 4 Report of Assessment Results Implemented Student records and staff interviews Staff interviews and a review of student records revealed that assessment reports contain summaries including the procedures, results, diagnostic Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 3 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting this document to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. 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 Corrective Action Not Effective While the district has a written process for monitoring timelines, the student records revealed that the district is not always completing evaluations, convening IEP Teams, determining eligibility, developing an IEP and determining placement within forty- The district needs to review their process and procedures for meeting eligibility process timelines. impressions and recommended type of placement. These assessments appear to be complete well in advance of the Team Meeting and upon request made available to the parents. However it should be noted that while the district is meeting the requirements of this criterion, they are not consistently completing the assessments within the required timelines. See SE 9 below. SE 9 Eligibility and Timelines No Student records and staff interviews Please see the Department’s comments to the right. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 4 of 33 Please provide a copy of the reviewed and revised procedure that outlines how the district will monitor timeline compliance and the person(s) responsible for 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 five school working days after they received consent from the parent for initial evaluations or re-evaluations. ensuring that this procedure/protocol is followed. Please submit this document to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 5 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 18A IEP Development and Content Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective No Staff interviews and student records 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 Student record review demonstrated that the district does not always develop IEPs with all required elements. Some reviewed IEPs lacked vision statements; the Present Level of Educational Performance 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. Also it was noted that the accommodations between PLEP A and State or District wide Assessment pages did not correlated. The district must train all special education staff charged with IEP development at all school levels on how to complete all required elements of the IEP. Please see the Department’s comments to the right. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 6 of 33 Please provide evidence of this training including the name and credentials of the trainer, a copy of the reviewed materials, the agenda and attendance sheet. Please submit this document to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the monitoring activities 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 conducted; including the person(s) responsible, the results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 18B Determination of Placement and Provision of IEP Implemented SE 20 Least Restrictive Program Partial Staff interviews and student records Student records demonstrate that the district is determining the placement and providing the IEP to the parents as required. Staff interviews, district documentation and student records The district is considering the least restrictive environment and indicating why students may need to be removed from the general education setting as required. Partial Because the district has an ineffective TAT process, it is unclear to the Department and to the special education staff whether they are removing students from general education solely because of the need for a modified curriculum. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 7 of 33 See MOA 18 below. 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 No Staff interviews, documentatio n and student records 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 records and related district documentation demonstrated that four out of 19 students had proposed IEPs from the 2006-2007 school year that were unsigned and there was no evidence of follow- up in the student files of efforts to secure consent. The district needs to train staff on IEP implementation requirements related to parental consent. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by October 31, 2007. Please see the Department’s comments to the right. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 8 of 33 The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. 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 24 Notice to Parents Implemented Student records and staff interviews Record review demonstrated that the district provides notice to parents as required. SE 25 Parental Consent No Student records and staff interviews Please see the Department’s comments to the right. Corrective Action Not Implemented or Not Effective or New Issues Identified Corrective Action Not Effective Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance As indicated in the CPR report issued in September 2004, student records demonstrated that the district does not consistently obtain parental consent before conducting the evaluations or implementing the IEP. Required Corrective Action, Timelines for Implementation, and Progress Reporting The district needs to train staff on 603 CMR 28.07(1)(a-c) the regulations pertaining to parental consent. Please provide a dated training agenda, copies of the materials used and signed attendance sheet to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 9 of 33 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 person(s) responsible, the results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 29 Implemented Student records Student records demonstrated that the district is ensuring that written communication such as the IEP and evaluation reports are translated and that translation/interpretation is available for meetings for families whose primary language is other than English. Implemented Documentatio n and staff interviews The district has a functioning Parent Advisory Council (PAC) in place with bylaws, officers and mandatory training in place. Communication in Primary Language of Home SE 32 Parent Advisory Council Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 10 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 37 Procedures for Approved and Unapproved Programs Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Partial Student records and staff interviews 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 Partial The district has no evidence of its monitoring of the student placements and in one instance it was written on the N1 form that the out- of- district program would be developing the IEP for acceptance by the parent. The district must provide training to the person(s) responsible for chairing, coordinating and monitoring out of district placements on the regulations related to this criterion. 603 CMR 28.02(14), 28.06(3) and 34 CFR 300.2(c). Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district has written procedures in place and there are contracts with each out of district placement. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 11 of 33 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 40 Instructional Grouping Implemented SE 41 Age Span Requirements Implemented Documentation and staff interviews A review of class rosters demonstrated that the instructional groupings for eligible students receiving services outside the general education classroom are compatible with the methods and goals stated in each student's IEP and meet the regulatory requirements. A review of student rosters demonstrated that the ages of the youngest and oldest child in any instructional grouping do not differ by more than forty-eight months as required. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 12 of 33 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 49 Related Services Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Partial Student records and staff interviews 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 Partial The review of student records and staff interviews indicated that the district is not including counseling services on the service delivery grid. While students appear to be receiving counseling, and references to counseling appear in parts of the IEP, the district is failing to include the relevant information on counseling services on the service delivery grid. The district must provide training to the person(s) responsible for chairing and IEP development on the regulations related to this criterion. . 603 CMR 28.02(19), IDEA 2004: Section 602(26). Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. Student record review and interviews demonstrated that the district provides related services as required, however all services do not appear on the service delivery grid. Please see the Department’s comments to the right. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 13 of 33 The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were 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 needed. Please submit this to the Department by February 14, 2008. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 14 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Partial Documentation, student record review The district has a written procedure but does not consistently complete the required transition form. 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 Record review indicated that district personnel are inconsistently discussing and documenting transition goals, plans and services. The district must provide training the person(s) responsible for chairing Team meetings and IEP development on the regulations related to this criterion, http://www.doe.mass.edu/sped/ IDEA2004/spr_meetings/, and information on the new transition forms found at http://www.doe.mass.edu/news /news.asp?id=3295. Special Education Criteria created or revised in response to IDEA-2004 SE 6 ##1 - 3 Determination of Transition Services Partial Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 15 of 33 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 8 IEP Team composition and attendance No Documentation, student records, staff interviews Please see the Department’s comments to the right. Corrective Action Not Effective The district has a comprehensive procedure for Team composition, however in some instance general education staff were not present, teams do not appear to be using the district’s excusal form and there were no notations when a Team member, even a parent, was not present at the meeting. The district must provide training the person(s) responsible for chairing Team meetings and IEP development on the regulations related to this criterion, 603 CMR 28.02(21) and IDEA 2004: Section 614(d)(1)(C); 614(f). Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the person(s) responsible, the Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 16 of 33 results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 12 Frequency of re-evaluation Partial Student records, documentation and staff interviews Please see the Department’s comments to the right. Partial The district has good written procedures in place; however school personnel are not consistently meeting the requirements of conducting reevaluations every three years, unless the parent and district agree that it is unnecessary. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 17 of 33 Please review your policies for reevaluation with all Team chairpersons. Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 13 Progress Reports and content Partial Student record review, documentation and staff interviews Please see the Department’s comments to the right. Partial While the district has a comprehensive written procedure in place, the record review demonstrated that in one third of the files reviewed, progress reports were verbatim copied from one period to the next without new text or information, only the date had been changed. Please review you written procedures and the requirements of this criterion, 603 CMR 28.07(3) and IDEA 2004: Section 614(c)(5)(B)(ii) with all special education staff and related service providers. *Please note recently 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.html Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 18 of 33 person(s) responsible, the results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 19 of 33 Criterion Number and Topic SE 14 Review and revision of IEPs Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Determined to be Partially Implemented or Not Implemented Partial Student record review, documentation and staff interviews Please see the Department’s comments to the right. Partial Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting The district is not consistently meeting on or before the anniversary date of student IEPs, additionally interviews indicated that it was common practice to use amendments to extend the IEP period when a Team could not or did not reconvene on or before the expiration date of an IEP. Please review you written procedures and the requirements of this criterion, 603 CMR 28.04(3), IDEA-97: 34 CFR 300.343(c), IDEA 2004: Section 614(d)(3)(D) and (F) with all special education Team chairpersons. Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 20 of 33 needed. Please submit this to the Department by February 14, 2008. SE 25B Resolution of disputes Implemented Student record review, documentation and staff interviews The district has procedures in place that meet the requirements set forth in this criterion. The review of student records demonstrated that the procedures are being followed in practice. SE 33 Involvement in the General Curriculum Implemented Student record review, documentation and staff interviews The district has procedures in place that meet the requirements set forth in this criterion. The review of student records demonstrated that the procedures are being followed in practice. SE 39A Procedures for services to eligible private school students whose parents reside in the district Partial Student record review, documentation and staff interviews Please see the Department’s comments to the right. (SE 39A does not apply to charter schools or vocational schools) Partial The district is not adhering to the regulatory requirement or its own written procedures. The student record review revealed that one student’s IEP and accompanying notice stated that the district’s preference is removing the student form the parochial school and placing the student in the district so he could receive services. Interviews also revealed that while Teams Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 21 of 33 Please review you written procedures and the requirements of this criterion, http://www.doe.mass.edu/sped/ advisories/06_3.html and the related regulatory requirements with all special education Team chairpersons. Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted recommended services for eligible private school students who reside in the district, the district doesn’t always provide the services. SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state SE 46 Procedures for suspension of students with disabilities more than 10 days Implemented Implemented Document and student record review The district has procedures in place that meet the requirements set forth in this criterion. Document and student record review The district has procedures in place that meet the requirements set forth in this criterion. The review of student records demonstrated that the procedures are being followed in practice. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 22 of 33 an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification MOA 10 A Handbooks and Code of Conduct Implemented Document review The district’s handbooks were reviewed and they meet all required elements of this criterion. MOA 11A Designation of Coordinators and Grievance Procedures Implemented Document review The district’s handbooks were reviewed and they meet all required elements of this criterion. (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 Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 23 of 33 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 Partial Student record review, documentation and staff interviews 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 Partial Student record review revealed that the district does not always inform the student of their rights one year prior to their eighteenth birthday and document it in the Addition Information section of IEP 8. Please review you written procedures and the requirements of this criterion, 603 CMR 28.07(5) and 34 CFR 300.347(c), 300.517, with all high school level special education Team chairpersons. Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 24 of 33 monitoring activities conducted; including the person(s) responsible, the results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 17 Early Intervention /Age Three Services Partial Student record review, documentation and staff interviews Please see the Department’s comments to the right. Partial While the district had appropriate policies and procedures in place and have been receiving Early Intervention referrals six months prior to children’s third birthday, the student records demonstrated that IEP meetings for those children were often held months after the child’s third birthday. According to student records reviewed, the district fails to have services in place for eligible preschoolers by their third birthday. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 25 of 33 Please review you written procedures and the requirements of this criterion, 603 CMR 28.06(7)(b), 34 CFR 300.24(b)(3); 300.121 and 300.132; 300.342(c) with all special education Team chairpersons responsible for early childhood programming. Please provide a signed statement of assurance that this training has occurred to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 19 Extended Evaluation Partial Student record review, documentation and staff interviews Please see the Department’s comments to the right. Partial Because the district has inconsistently used their instructional support system, the teacher Assistance Team (TAT), the district has little or no data to appropriately select assessments for referred students. As a result, the district is not fully assessing in all areas of suspected delay and then using the extended evaluation period and in some case then exceeding the extended evaluation time line to conduct additional testing. In one instance an extended evaluation was conducted but no meeting or follow up was evident in the file. The district needs to review and revise their procedures, policies and the regulatory requirements for conducting extended evaluations and revised the polices and procedures consistent with the requirements set forth in this criterion and 603 CMR 28.05(2)(b). Please provide a copy of the reviewed and revised procedure/protocol for conducting extended evaluations and the person(s) responsible for ensuring that this procedure/protocol is followed. Please submit this document to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the monitoring activities conducted; including the person(s) responsible, the Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 26 of 33 results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. SE 25A Notice to BSEA Partial Student record review, documentation and staff interviews Please see the Department’s comments to the right. Partial It was noted in the student record review that IEP were left unsigned with no follow up or in some cases rejected or partially rejected also with no follow up. (See SE 22 above) Staff indicated that in some instance they were unaware of the unsigned, partially rejected or rejected IEPs and it was unclear who was responsible for follow up including notifying the BSEA. The district needs to review and revise their procedures, policies and the regulatory requirements for notifying the BSEA of rejected, partially rejected IEPs and revised the polices and procedures to be in line with the requirements set forth in this criterion and 603 CMR 28.08(3)(b). Please provide a copy of the reviewed and revised procedure/protocol for BSEA notification and the person(s) responsible for ensuring that this procedure/protocol is followed. Please submit this document to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring from October 2007 through January 2008 to ensure the implementation of this requirement. Please submit a narrative summary of the monitoring activities Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 27 of 33 conducted; including the person(s) responsible, the results, and the additional corrective action steps the district has taken, if any were needed. Please submit this to the Department by February 14, 2008. MOA 18 Responsibilities of School Principal Partial Student record review, documentation and staff interviews Partial The district has a written instructional support process called Teacher Assistance Teams (TAT), however, district wide the process and procedures are being inconsistently followed. Interviews with principals demonstrated that there are no set meeting structures at the individual schools. Staff interviews indicated people were unclear about the process, and how to use the district’s curriculum accommodation plan. In some instance it was noted that staff indicated that the instructional support process was confusing which was leading to an over referral by teachers of student to special education for eligibility determination. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 28 of 33 The district must review their instructional support process, procedures and policies along with the requirements of this criterion, M.G.L. c. 71, s. 38Q ½ and CMR 28.03(3). Please submit to the Department your revised process, policies and procedures indicating the person(s) responsible for implementation and monitoring and please include a time line for training and implementation. Please submit this document to the Department by October 31, 2007. The district must also submit evidence that it has conducted an internal monitoring at each school level from October 2007 through January 2008 to ensure the 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 district has taken, if any were needed. Please submit this to the Department by February 14, 2008. Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 29 of 33 Everett 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 Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Implemented ELE 2 MCAS Participation Implemented ELE 3 Initial Identification Implemented ELE 4 Waiver Procedures Implemented Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 30 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 5 Program Placement and Structure Implemented ELE 6 Program Exit and Readiness Implemented ELE 7 Parent Involvement Implemented ELE 8 Declining Entry to a Program Implemented ELE 9 Instructional Grouping Implemented ELE 10 Parental Notification Partial Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The district’s parent notification letter does not contain all the required elements which include; reason for identification of the student as Limited English Proficient (LEP), the child’s level of Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 31 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Upon placement in an ELE program the district must provide the student’s parent or guardian a notice that contains all of the required elements as 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) proficiency, program placement and or method of instruction, how the program will meet the educational strengths and needs of the student, how the program will specifically help the student learn English, the specific exit requirements and the parent’s right to apply for a waiver (see ELE 4) or decline enrollment in the program. ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs ELE 13 Follow-up Support Implemented Implemented Implemented Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 32 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting noted to the left. Please provide a detailed narrative of how the district plans to address parental notification and include copies of any revised forms. Please submit the narrative and revised notice to the Department by September 14, 2007. ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 14 Licensure Requirements Implemented ELE 15 Professional Development Requirements Implemented ELE 16 Equitable Facilities Implemented ELE 17 Program Evaluation Implemented 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) Everett Public Schools Coordinated Program Review Mid-cycle Report August 20, 2007 Page 33 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting