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
April 4, 2005
Thomas J. Lamey, Superintendent
Fitchburg Public Schools
376 South Street
Fitchburg, MA 01420
Re:
Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action
Plan Verification and Special Education Mid-cycle Review
Dear Superintendent Lamey:
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 April 26, 2002.
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 April
15, 2005.
This Mid-cycle Coordinated Program Review Report includes an extraordinary number of
serious findings of persistent noncompliance particularly with special education law, many of
which were included in the Department’s Coordinated Program Review Report dated April 26,
2002. In consideration of this, we will be holding a meeting in the Department’s Malden offices
to provide you with a more detailed explanation of the basis of the Department’s most recent
findings and the steps the Department is obligated to take to enforce these laws in the Fitchburg
Public Schools. This meeting will take place on May 9, 2005 at 1:30 p.m. Please call John
Stager, Administrator of Program Quality Assurance Services, to confirm your attendance at this
important meeting regarding your school district.
As stated in the enclosed Mid-Cycle Review Report, the Department continues to document
areas of serious noncompliance with state and federal law, particularly in special education. In
2002, the district proposed corrective action to remedy all areas of noncompliance identified by
the Department at that time. The Department approved these corrective action plans, and since
that time the district has provided the Department with written progress reports describing
implementation of these approved plans. However, as a result of the verification activities in
March 2005, which consisted of staff interviews, student record reviews, documentation review
and classroom observations, the Department found that the approved corrective action plans have
either; (1) not been implemented as approved by the Department; (2) been determined to be very
unevenly implemented at the building level; (3) or been documented to be implemented but have
been found to be ineffective in addressing the identified noncompliance. This is in direct
contrast to the written assurances submitted by the district in progress reports and other
statements of assurance filed with the Department as condition for receiving state and federal
funds.
The Department documented 37 findings of special education noncompliance by the district in
2002, and the enclosed Mid-Cycle Report documents 23 findings of noncompliance in the
Fitchburg Public Schools’ special education programs, 20 of which are areas of continuing
noncompliance. This is not acceptable after three years of reported corrective action effort.
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 Follow-up Chairperson at 781-338-3728.
Sincerely,
Vani Rastogi, 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
Dan H. Mylott, School Committee Chairperson
Katherine Martin, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
FITCHBURG PUBLIC SCHOOL DISTRICT
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on June 25, 2002
Progress Reports Submitted on November 12, 2002; March 3, 2003; July 2, 2003;
December 8, 2003; April 20, 2004; September 21, 2004; October 5, 2004
Onsite Visit Conducted on March 1-3, 2005
Date of this Report April 4, 2005
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Special
Education
Requirements
SE 3
Special
Requirements
for
Determination
of Specific
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Student
Records
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
Review of records indicated that
the student records do not
include all of the required
documentation when determining
if a student has a specific
learning disability. For example,
only one person signed the
Submit to the Department, by
September 12, 2005, an
agenda from staff training
conducted prior to the start of
the school year that includes a
review of the required
documentation that must be
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Learning
Disabilities
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

2
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
required written document, and
while the form had checked off
that an observation had been
completed, the records did not
include the relevant behavior
observed or the name of the staff
observing the student.
completed when determining
that a student has a specific
learning disability.
Submit to the Department, by
February 6, 2006, the written
documentation from ten
student records for students
found eligible due to the
presence of a specific learning
disability.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
SE 6
Determination
of Transition
Planning and
Services and
Related Courses
of Study
SE 13
Progress
Reports and
Content
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Student
Records,
Document
Review and
Interviews
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

Documentation indicated
that the district has a list
of vocational training
and integrated
employment resources
for transitioning students
from the high school to
post school activities.
Interviews indicated that
transition services appear
to take place with state
agencies and the ARC.

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
Although the district uses various
transition services, there is a
limited amount of transitional
language incorporated into the
IEP.
Submit to the Department by
September 12, 2005,
documentation from staff
training on incorporating
transition planning into student
IEPs.
Submit to the Department, by
February 6, 2006, IEPs from
five student records for
students over 14 years of age
documenting transition
planning.

Student
Records
3
This is an area of continuing noncompliance, as the district was
cited on this matter in the April
2002 CPR report. The records
indicate that some Team
meetings are held in place of
providing a progress report to the
parent(s) and progress reports do
not always include information
on the progress towards the
annual goals. Some progress
reports just state that the student
“improved” or “worked hard.”
The district must provide indepth training to all staff on
writing special education
progress reports. Submit to the
Department, by September 12,
2005, an agenda from staff
training on writing progress
reports, sending progress
reports to parents as often as
parents are informed of the
progress of regular education
students, and steps to take if
the progress reports indicate
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

4
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
This information does not
provide parents with a sense of
what the student has been
working on in relation to the
objectives and benchmarks. In
addition, there is no evidence of
the Team reconvening when the
progress reports indicate a lack
of progress.
that the student is not making
progress as expected. The
district should also appoint
staff to review the information
included in the progress reports
prior to having them sent to
parents.
Submit to the Department, by
February 6, 2006, copies of
ten progress reports selected
from student records across all
grade levels that have been
written since the start of the
2005-2006 school year.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
SE 15
Outreach by the
School District
(Child Find)
SE 17
Initiation of
Services at Age
Three and Early
Intervention
Transition
Procedures
SE 18A
IEP
Development
and Content
Implementation
Status or
Corrective
Action Plan
Substantially Implemented


Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
Document
Review
Review of
documentation indicates
that the district conducts
appropriate outreach.
Student
Records

This is an area of continuing and
significant noncompliance.
Records indicate that Early
Intervention generally informs
the district of a student six
months prior to turning age three.
Meetings are not held in a timely
manner so that parents have 30
days to respond to the proposed
IEP. Therefore, the district does
not always develop an IEP and
implement services by the child’s
third birthday, as required.
Develop and submit a plan to
the Department, by September
12, 2005, that will ensure that
IEPs are developed and
services are initiated by the
third birthdays. The plan must
include contact with Early
Intervention, assessing
students, and convening the
Team in a timely manner so
that IEPs are developed by the
child’s third birthday.
Interviews,
Student
Records and
Document
Review

Review of records set forth
several issues with the IEPs. For
example, one student’s IEP
included another student’s name
and a few IEPs included the
wrong age of the students. The
goals in many IEPs were vague
All staff require in-depth
training on writing IEPs. On or
before September 12, 2005,
submit a training agenda for
staff training that took place
prior to the start of the school
year, the attendance sheets
5
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
and IEPs were handwritten and
not legible.
The student records included
Team meeting minutes that had
information on the student’s
vision and vocational interests,
but this information was not
incorporated into the IEPs.
from the training, and the
topics that were noted in this
finding on the agenda.
Submit to the Department, by
February 6, 2006, copies of 10
IEPs from student records
selected across all grade levels
and the accompanying Team
meeting minutes.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
SE 18B
Determination
of Placement;
Immediate
Provision of
IEP to Parent
SE 20
Least
Restrictive
Program
Selected
SE 22
Implementation
Status or
Corrective
Action Plan
Substantially Implemented


Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Student
Records
Review of records
indicates that this
criterion is substantially
implemented. In
general, decisions are
made within the least
restrictive environment
and IEPs are provided
immediately following
the Team meetings.
Interviews
and
Classroom
Observations
Interviews and
observations indicate that
staff have focused on the
least restrictive
environment at the high
school. The work done
over the past three years
on inclusion at the
secondary level is
evident.
Corrective
Action Plan
Not Fully
Implemented 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

Interviews indicate that the B.F.
Brown School does not provide
full inclusion for sixth grade
students in math and English.
In addition, the program at South
Street Elementary School is a
Life Skills program (SPIN) for
high school students. These
students do not have an
opportunity to integrate with
peers of similar ages. The district
indicated that this is the last year
of the SPIN program at South
Street Elementary School
Develop a plan to ensure that
B.F. Brown provides full
inclusion for sixth graders in
math and English. Submit this
plan to the Department by
September 12, 2005. Also
provide verification of the
relocation of the SPIN program
to a more appropriate setting,
providing peer access.

Issues with providing services as
Submit to the Department by
Interviews
7
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
IEP Provision
and
Implementation
Without Delay
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

and Student
Records
8
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
agreed upon in the IEP is an area
of continuing non-compliance.
Interviews indicated that there is
a lack of speech and language
therapy services for students at
the B.F. Brown Middle School.
IEPs are not being fully
implemented and parents are not
informed in writing of the lack of
a service provider, actions that
the district is taking to address
the lack of personnel, or
alternative methods proposed to
meet the goals on the accepted
IEPs.
Other than at Fitchburg High
School, there is no indication that
the district monitors the full
implementation of IEPs.
September 12, 2005 written
documentation on what is
being done to ensure that B.F.
Brown Middle School has a
speech and language therapist
and how compensatory
services will be provided to
students.
Submit documentation
indicating that staff have been
trained on the appropriate
procedures to follow, in
accordance with 603 CMR
28.06(2)(d)2 for notifying
parents of the lack of a service
provider.
Submit documentation setting
forth how the district is going
to monitor the implementation
of IEPs for students in the
district. Plans must be
developed for all schools
except the high school.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

SE 26
Parent
Participation in
Meetings
SE 28
Parent Provided
the IEP and
Procedural
Safeguards and
Parents' Rights
SE 29
Communications are in

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
Interviews
and Student
Records
Interviews and review of
records indicate that the
district uses a variety of
methods to involve
parents in Team
meetings, and in some
schools transportation is
offered to parents to
ensure their attendance.

Parent participation in Team
meetings was very low for
English learner education/special
education students. Many of
these records do not include
information indicating that
multiple attempts were made to
involve parents and the records
lack translated Team meeting
invitation notices or translated
IEPs. Therefore, there is a
possibility that parents are not
even aware that a Team meeting
is scheduled.
Submit to the Department, by
September 12, 2005, data on
the number of Team meetings
held since April 2005 for
special education/ELE
students, including the number
of these meetings in which a
parent is in attendance. If
parents are not involved,
indicate the multiple attempts
made to involve parents.
Submit copies of Team
meeting invitation notices that
are translated for ten Team
meetings held since April
2005.
Student
Records
Review of records
indicates that IEPs are
generally sent to parents
immediately following
the Team meetings.

Review of student records
indicates that IEPs, Team
meeting invitations, and progress
Submit to the Department, by
September 12, 2005,
documentation indicating how
Student
Records
9
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
English and
Primary
Language of
Home
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

10
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
reports are not consistently
translated. In addition, while a
translator is generally provided
for Spanish speaking families,
translators and interpreters are
not included in the Team
meetings for families who speak
other languages.
the district will ensure that
IEPs, Team meeting invitation
notices and progress reports are
translated in a timely manner.
Submit a list of interpreters for
the district to use at Team
meetings for parents who
require a translator for
languages other than Spanish.
Criterion
Number
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
SE 32
Parent Advisory
Council for
Special
Education
Document
Review and
Interviews
For the past year the
district has had an active
special education parent
advisory council (PAC).
The district submitted
the officer list, by-laws,
and meeting agendas.
The PAC has been active
in providing training to
parents on various
special education
matters.

While there is now an active
PAC, there is no evidence that
the PAC is active in advising the
school committee on matters that
pertain to the education and
safety of students with
disabilities or meets regularly
with school officials to
participate in the planning,
development, and evaluation of
special education programs.
Submit to the Department, by
September 12, 2005, minutes
and an agenda from school
committee meetings indicating
PAC involvement.
Submit documentation
indicating that the PAC has
been involved in the planning,
development and evaluation of
the special education programs.
SE 50
Responsibilities
of the School
Principal and
Administrator
of Special
Education
Document
Review and
Interviews

This is an area of continued
noncompliance. Interviews
indicate that the special
education department does not
communicate effectively with the
building administrators, except
for the high school, as the
Assistant Special Education
Director has a second office in
the high school. In addition, the
special education department
does not communicate
effectively with parents, as the
department does not return many
Submit to the Department, by
September 12, 2005, a plan to
ensure increased
communication between the
special education department,
parents and building
administrators. Indicate how
the district will ensure that
phone calls and letters are
responded to in a timely
manner.
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

11
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
calls and letters. Interviews
indicate that a lack of a response
has led to a lack of trust, as many
parents feel the need to have
advocates present at Team
meetings.
SE 54
Professional
Development
Regarding
Special
Education

Document
Review and
Interviews
The district submitted
the Professional
Development Plan for
2004-2005. Review of
the plan and interviews
indicate that staff
receive the required
training.
SE 56
Special
Education
Programs and
Services are
Evaluated

This is an area of continued
noncompliance. The district has
not had the program evaluated
yet, although the district has
recently contracted with an
evaluator who will start the
evaluation in April.
Submit to the Department, by
September 12, 2005, a copy of
the evaluation and the steps
that the district is taking to
implement the
recommendations of the
evaluation report.

Review of records indicates that
the assessments are not always
tailored to assess specific area of
Submit to the Department, by
September 12, 2005, an
agenda for staff training on
Other
Requirements
SE1
Assessments
are
Student
Records
12
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Appropriately
Selected and
Interpreted for
Students
Referred for
Evaluation
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

SE 9
Eligibility
Determination
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

Student
Records
SE 4
Reports of
Assessments
SE 8
Evaluation
Team
Composition
Method(s)
of Verification

Student
Record
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
educational need. Students with
different areas of need received
the same assessments.
In addition, there are many
spelling errors in the
assessments.
selecting appropriate
assessments for students
referred for an evaluation. In
addition, the training should
include information on
ensuring that the assessments
are reviewed prior to sending
them to parents.

Many assessment reports do not
include diagnostic impressions,
including defining in detail and
in educationally relevant and
common terms, the student’s
needs, and offering explicit
means of meeting them.
Submit to the Department, by
September 12, 2005,
documentation that appropriate
staff have been trained on the
required elements that must be
included in the assessments.

This is an area of continuing
noncompliance. Review of
student records indicates that the
district is still not responding to
requests for evaluations in a
Submit to the Department, by
September 12, 2005, timeline
logs for all students referred
for an evaluation since April
2005. Include for each student
Review of records
indicates that the IEP
Teams generally include
the required Team
members.
Student
Records
13
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
SE 10
End of School
Year
Evaluations

Student
Records
Review of records
indicates that end of
school year evaluations
are generally conducted
in a timely manner.
SE 12
Frequency of
Re-evaluations

Student
Records
Review of records
indicates that three-year
reevaluations are
completed at all levels.
SE 21
School Day and
School Year
Requirements
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified


Student
Records and
Interviews
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
timely manner, and evaluation
consent forms are not always
sent to parents once a student is
referred for an evaluation. The
district responded to some
referrals by asking the parent to
complete additional information
before the special education
department sent an evaluation
consent form.
the date the referral was
received, the date that the
evaluation consent form was
sent to the parent, the date
evaluations were completed,
the date of the IEP Team
meeting, and the date full IEPs
are sent to parents.
Review of records and interviews
indicate that there is a lack of
extended school year
programming offered in the
district. While the district may
Submit to the Department, by
September 12, 2005,
information on ESY
programming and the list of
student, by initials, that took
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
SE 23
Confidentiality
of Personally
Identifiable
Information
Implementation
Status or
Corrective
Action Plan
Substantially Implemented


Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Student
Records
Review of records
indicates that this
criterion is substantially
implemented.
SE 24
Notice to Parent

Student
Records and
Interviews
Review of records
indicates that the district
sends the required
notification to parents.
SE 27
Content of
Team Meeting
Notice to
Parents

Student
Records
Review of student
records indicates that the
notices include the
required information.
SE 34
Continuum of
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified


Student
Records and
15
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
offer related services in the
summer, as well as programs for
Life Skills students, parents are
told at Team meetings that
programming is not available for
other students even if the Team
feels that it is appropriate.
part in these programs.
Although interviews indicate that
counseling is provided to
Submit to the Department, by
September 12, 2005,
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Alternative
Services and
Placements
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

Interviews
SE 35
Specialized
Materials and
Assistive
Technology

Student
Records and
Interviews
Interviews and student
records indicate that
while there is evidence
of assistive technology
provided to students, the
district should continue
to monitor
implementation of this
requirement, as it is not
clear that the need for
assistive technology is
discussed at all Team
meetings.
SE 37
Procedures for
Approved and
Unapproved
Out-of-District
Placements

Student
Records,
Interviews
and
Document
Review
The district monitors the
provision of services to
students placed out-ofdistrict.
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
students, IEPs do not reflect that
counseling is considered through
the IEP process and included in
the IEPs with related goals.
documentation indicating that
training has been provided to
evaluation team leaders
regarding the need to discuss
counseling services at Team
meetings.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
SE 40
Instructional
Grouping
Requirements
for Students
Aged Five and
Older
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Document
Review
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
This is an area of continuing noncompliance. Review of
documentation indicates that the
following classes are out of
compliance with this criterion:
High School
-Two C Block Reading classes
have 13 students with one
paraprofessional.
-D Block Math has 13 students
with one paraprofessional.
-E Block Math has 13 students
with one paraprofessional.
-F Block Reading has 13 students
with one paraprofessional.
Written notification for
increased class size should be
submitted prior to the start of
the school year whenever
possible. Submit to the
Department by September 12,
2005, copies of all classroom
rosters for all substantially
separate classrooms at the high
school and BF Brown.
As this is an area of continued
noncompliance, provide the
name of the staff or
administrator who will monitor
the class sizes in the
substantially separate
classrooms.
See also SE 41.
BF Brown
-Resource room grade six
reading has over eight students
and there is no indication that
there is a paraprofessional in the
program.
SE 41
Age Span
Requirements

Document
Review
17
The documentation submitted for
the following classes did not
include the dates of birth, just the
ages of the students. There were
When submitting the rosters
for SE 40, include the dates of
birth for the students in the
high school. For the rest of
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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
students aged 15 through 19, but
without the dates of birth it is not
clear whether these classes are
within the required age span.
-E Block Math
-F Block Math
-F Block Social Studies
-F Block Transitional English
these classes, submit the class
rosters with the students’ dates
of birth.
SE 42
Programs for
Young Children
Three and Four
Years of Age
Student
Records

There is continuing
noncompliance with this criterion
as the district does not
consistently develop IEPs and
implement services by the child’s
third birthday.
See SE 17.
SE 43
Behavioral
Interventions
Student
Records

This is an area of continuing
noncompliance. Review of
student records indicates that the
Team meeting minutes note
behavioral issues; however, it is
not clear from the records how
the district is addressing
individual student’s behaviors.
Behavioral Intervention Plans are
not included in the student
records.
Submit copies of ten
Behavioral Intervention Plans
selected from student records
across all grade levels by
September 12, 2005.
18
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
SE 44
Procedures for
Recording
Suspensions
Implementation
Status or
Corrective
Action Plan
Substantially Implemented


Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Interviews
The district has
procedures to record the
number and duration of
suspensions.
SE 45
Procedures for
Suspensions Up
to 10 Days and
After 10 Days

Interviews
and Student
Records
Schools are conducting
manifestation
determinations in a
timely manner.
SE 46
Procedures for
Suspensions of
Students with
Disabilities

Interviews
Interviews indicate that
after the Team conducts
a manifestation
determination at the
secondary level, the
student is not kept out of
school if the Team has
determined that the
behavior is a
manifestation of the
disability.
Student
Records and
Interviews
Interviews indicate that
the district does not
delay enrollment of
SE 48
FAPE
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified


19
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
This is an area of continuing
noncompliance. Interviews
indicate that students attending
Submit to the Department by
September 12, 2005, copies of
updated IEPs for all special
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

special education
students.
SE 49
Related
Services
SE 55
Special
Education
Facilities and

Interviews
and
Document
Review
The district provides a
range of related services
to students, including
bringing in outside
agencies to provide
counseling services.
Interviews
and
Observations
It is noted that there have
been significant
improvements in the
location of the provision

20
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 Alternative High School may
only receive special education
services through the Fitchburg
High School, and many students
waive their right to services and
to an IEP as a requirement for
admission. But there are some
students who still receive
consultation services, counseling,
and tutoring, therefore, this
should be documented in the
IEPs. It should also be noted that
the best practice would be to
provide special education
services at the Alternative High
School.
education students in the
Alternative High School.
B.F. Brown has significant issues
with regard to the lack of space;
related services take place in the
library or in the hallway.
Develop and submit to the
Department, by September 12,
2005, a plan to ensure that the
related services at B.F. Brown
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Classrooms
SE 57
Special
Education Child
Count
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

of related services
throughout the buildings.
The new high school
facility is commendable,
as it has a significant
amount of space for
service providers.
Crocker Elementary and
Reingold Elementary
have also improved the
location of the related
services.

Document
Review

Interviews
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
take place in appropriate
locations, providing safety and
confidentiality
The district submitted
the required Child Count
information.
See ELE findings below.
MOA 2
Program
Modifications
and Support
Services for
LEP Students
MOA 3
Comments Regarding
Corrective Action Plan
Implementation
Interviews indicate that
21
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Access to a Full
Range of
Education
Programs
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
and
Document
Review
the district no longer
delays enrollment of
special education and
limited English
proficient students. In
addition, the high school
has a range of electives
for students to choose
from if they are not
accepted into the
regional vocational high
school.
MOA 5
Placement of
Disabled
Students in
Occupational/
Vocational
Education
Programs

Interviews
The high school has a
number of electives for
students to choose from.
MOA 7
General
Information and
Materials in
Languages

Document
Review
Review of
documentation indicates
that the handbooks have
been published in
languages other than
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

22
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 in 20042005 Special
Education
Information
Package)
Other than
English
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

English.
MOA 9
Hiring and
Employment
Practices of
Prospective
Employers of
Students

Document
Review
The district submitted
documentation indicating
that the statement signed
by prospective
employers includes the
required notice setting
forth that prospective
employers do not
discriminate.
MOA 10A
Notification of
School District
Staff and
General Public

Document
Review
Review of
documentation indicates
that the high school
handbook includes the
required statement of
non-discrimination and
the contact person for
Title IX, Title VI and
Section 504.
MOA 11A
Designation of
Liaison/Coordi
nators;

Document
Review
Review of
documentation indicates
that the district has
grievance procedures
23
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 in 20042005 Special
Education
Information
Package)
Grievance
Procedures
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
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 notice did not include the
required information: Within ten
days from a student’s fifteenth
consecutive unexcused absence,
the school provides written
Submit to the Department, by
September 12, 2005, a copy of
an updated notice that includes
the information as set forth in
this criterion.
that cover the required
areas.
MOA 12A
Notification
Concerning
Nondiscrimination and
Coordinators

Document
Review
Review of
documentation indicates
that the district
publications cover the
required areas regarding
non-discrimination.
MOA 15
Nondiscriminatory
Administration
of Scholarships,
Prizes and
Athletic
Awards

Document
Review
Review of
documentation indicates
that the scholarships and
prizes are given in a
nondiscriminatory
manner.
MOA 16
Notice to
Students
Leaving School
Without a High
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

Document
Review
24
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
School Diploma
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete Implementation of
Approved Corrective Action
Plan or Identification of
Additional Issues of
Noncompliance
notice to students age 16 or over,
and their parents or guardians,
and states that the student and the
parent or guardian may meet
with a representative of the
district within ten days from the
date the notice was sent. At the
request of the parent or guardian,
the district may consent to an
extension of the time for the
meeting of not longer than
fourteen days.
MOA 21
Staff Training
Regarding Civil
Rights
Responsibilities

Document
Review
Review of
documentation indicates
that staff have received
training regarding civil
rights responsibilities.
MOA 22
Accessibility

Observations
and
Interviews
There appears to be at
least one fully accessible
building at each grade
level.
Subject to on-site verification
during Coordinated Program
Review.
25
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
MOA 23
Comparability
of Facilities and
Programs

Observations
The new high school is
fully accessible and
classrooms are
appropriately labeled.
MOA 25
Institutional
Self-Evaluation

Document
Review
The district has a
mechanism in place to
conduct an institutional
self-evaluation.
Document
Review and
Interviews
The district has provided
assistance and resources
to its schools to assist
them in preparing an
assessment of academic
needs and a review of
Title I program impact.
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
TI 4
Needs
Assessment and
Evaluation
TI 6
Student
Selection

Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

Document
Review and
Interviews

26
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
Targeted Assistance program
schools at the elementary level
now have a student selection
process that utilizes multiple,
appropriate measures of
educational need, leading to
rank-ordered lists of Title I
eligible students. The targeted
program at the high school,
Submit student selection
criteria for each grade served
in the high school, showing
multiple, educationally-related,
weighted criteria. Include rankordered lists, by grade, of
students participating in the
Title I program.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
TI 7
Student
Selection
Criteria
Development
TI 8
Equal Access to
Title I Services
Implementation
Status or
Corrective
Action Plan
Substantially Implemented



Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Document
Review and
Interviews
Staff and parent input
was obtained by
administrators when
developing student
selection criteria for
Targeted Assistance
programs.
Document
Review,
Interviews,
and
Observation
The district has modified
ELL programming so
that ELL students have
equal access to Title I
services.
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

TI 10
Parental
Involvement

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
however, needs some refinement
so that selection criteria have
established weighting to
standardize the selection process.
Due: September 12, 2005
Portions of the district’s
corrective action for this criterion
have been implemented. There
remains a lack of parental input,
however, into program planning,
implementation, and program
review.
Submit evidence of parental
input into program planning
and implementation, such as
council agenda items with
parent sign-in sheets. Submit
evidence of parental input into
overall program evaluation.
Due: September 12, 2005
27
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
TI 11A
Parental
Involvement

Document
Review and
Interviews
The district has been
offering parents
opportunities to learn
about program activities
and has provided
materials for parents to
use with their children at
home.
TI 14A
Schoowide
Plans

Document
Review and
Interviews
The district has provided
guidance and resources
to all Schoolwide
program schools with
regard to program
planning. All
Schoolwide program
plans now address all ten
required components.

Document
Review and
Interviews
The district provides
assistance to all
Schoolwide schools with
the Schoolwide planning
process.
Document
Review and
The district appears to be
communicating district
TI 14D
Schoowide
Plans
TI 14E
Schoowide

Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

28
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
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Interviews
and school efforts,
performance measures,
and improvement plans
sufficiently through a
variety of venues and
media so that parents and
the community have
access to this
information in an
understandable format.

Document
Review and
Interviews
The district maintains
communication,
consultation on program
planning, and fiscal
coordination with the
local Neglected or
Delinquent facility
receiving Title I funding.
TI 24
Needs
Assessments

Document
Review and
Interviews
Annual assessment of
student academic needs
and accompanying
analysis of performance
data is occurring at each
Title I-served school.
ELE 2

Document
Limited English
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Plans
TI 16
Student Support
Services (N or
D facility)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

29
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 in 20042005 Special
Education
Information
Package)
MCAS
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

ELE 5
Program
Placement and
Structure
Comments Regarding
Corrective Action Plan
Implementation
Review and
Interviews
proficient students
participate in MCAS in
accordance with
Department guidelines.
Corrective
Action Plan
Not Fully
Implemented 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 does not appear to
have effective procedures in
place to identify students who
may be limited English
proficient. Interviews revealed
that in some schools, children are
referred for English proficiency
testing by the classroom teacher,
based on informal assessment
rather than formal screening
procedures.
Please provide the Department
with revised identification
procedures that ensure that all
LEP students are being
identified. Submit this
information by September 12,
2005.

The district does not educate all
limited English proficient (LEP)
students in sheltered English
instruction (SEI) classrooms as
required under M.G.L. Chapter
71A. The district does not
Provide the Department with
plans to educate all LEP
students in SEI classrooms by
the 2005-06 school year, unless
students are in a 2-way
program, on an approved
Student
Records and
Interviews
ELE 3
Initial
Identification
ELE 4
Waiver
Procedures
Method(s)
of Verification

Document
Review and
Interviews
The district has waiver
policies and procedures
that are consistent with
Department guidelines.
Interviews,
Student
Records and
Document
Review
30
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified


Interviews,
Student
Records and
Document
Review
ELE 6
Program Exit
and Readiness
ELE 7
Parent
Involvement

Interviews
and
Document
Review
The district has effective
procedures to ensure the
involvement of parents
of limited English
proficient students in
their children’s
education.
ELE 8
Declining Entry
to a Program

Interviews,
Student
Records and
The district has notified
parents of their right to
decline to enroll their
31
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 English language
instruction to all of its LEP
students.
waiver, or have opted out of
English learner education.
Provide evidence to the
Department that the district
will provide English language
instruction to LEP students by
the 2005-06 school year.
Submit this documentation by
September 12, 2005.
The district does not currently
have effective exit criteria and
procedures in place.
Provide the Department with
revised exit criteria and lists of
students exited under the
revised policy at each school.
Submit this information by
September 12, 2005.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Document
Review
children in the ELE
program, and has
implemented procedures
that ensure these students
who have “opted-out”
are monitored and
supported.
Corrective
Action Plan
Not Fully
Implemented 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 9
Instructional
Grouping
Interviews,
Student
Records and
Document
Review

The district does not educate all
LEP students in SEI classrooms,
thus the students do not have
access to curricular material
based on the Massachusetts
frameworks. See ELE 5.
Provide detailed plans to
provide SEI classrooms to LEP
students for the 2005-06 school
year. Submit these plans to the
Department by September 12,
2005.
ELE 10
Parent
Notification
Letter
Document
Review

The Parent Notification Letter
does not include the following
information:
-The reasons for identification of
the student as LEP.
-The student’s level of English
proficiency.
-How the program will meet the
educational strengths and needs
of the student.
-Specific exit requirements.
-Parent’s right to apply for a
waiver.
Submit to the Department, by
September 12, 2005, an
updated Parent Notification
Letter.
32
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented 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 does not have
effective policies in place to
ensure that LEP students are
being appropriately referred and
evaluated for special education.
Submit evidence that the
district has provided training
around this topic to staff
members charged with the
identification and evaluation of
students who are LEP and may
require special education
services. Submit
documentation by September
12, 2005.
Student
Records and
Interviews
ELE 11
Equal Access to
Academic
Programs and
Services
ELE 12
Equal Access to
Nonacademic
and
Extracurricular
Programs
Method(s)
of Verification

Interviews
and
Document
Review
The district ensures that
LEP students have
access to nonacademic
and extracurricular
activities.
ELE 13
Follow-up
Support
Interviews,
Document
Review and
Student
Records

The district has no mechanism in
place to ensure that former LEP
students are monitored.
Provide the Department with
updated procedures that ensure
that former LEP students are
being monitored. Submit
procedures to the Department
by September 12, 2005.
ELE 14
Interviews

LEP students are currently being
Provide the Department with
33
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
Licensure and
Fluency
Requirements
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified

and
Document
Review
ELE 15
Professional
Development
Requirements

Interviews
and
Document
Review
The district has provided
teachers and
administrators with
professional
development
opportunities.
ELE 16
Equitable
Facilities

Interviews
and
Document
Review
The district ensures that
the ELE program
receives equitable
resources, materials and
facilities.
ELE 17
DOE Data
Submission
Requirements
and Program
Evaluation

Interviews
and
Document
Review
The district submits ELE
student data to the
Department in
accordance with
guidelines. The district
evaluates the ELE
program as required.
34
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
placed in classrooms with
teachers who do not meet the
qualifications under this
standard.
plans to meet this standard by
the 2005-06 school year.
Submit plans to the
Department by September 12,
2005.
Criterion
Number
and Topic
(Refer to full
text in 20042005 Special
Education
Information
Package)
ELE 18
Records of LEP
Students
Implementation
Status or
Corrective
Action Plan
Substantially Implemented

Method(s)
of Verification
Student
Records
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Not Fully
Implemented or
Additional
Issues
Identified


35
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 of LEP students
do not contain parent notification
letters, logs of access, exiting
information, or evidence of
follow-up in the cases of students
who were formerly limited
English proficient (FLEP).
Provide the Department with
revised policies and evidence
of staff training around this
topic by September 12, 2005.