The Commonwealth of Massachusetts Department of Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338- 3000 July 19, 2005 Steven Johnson Superintendent Franklin County Regional Vocational Technical School 82 Industrial Blvd Turners Falls, MA 01376 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Mr. Johnson: 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 May 28, 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. 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 August 2, 2005. Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Onsite Team Chairperson at 413-284-0386. Sincerely, Sandra K. Hanig, Education Specialist Program Quality Assurance Services John D. Stager, Administrator Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Richard Kuklewicz, School Committee Chairperson Leslie Brown, Pupil Personnel Services Director Paul N. Cohen, Principal Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW FRANKLIN COUNTY TECHNICAL SCHOOL ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on June 19, 2002 Progress Reports Submitted on June 30, 2003 and June 30, 2004 Onsite Visit Conducted on February 17 & 18, 2005 Date of this Report July 19, 2005 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 OSEP Focus Areas -Special Education Requirements SE 3 Special requirements for determination of specific learning Student record review 3 The concern at the time of the 2001 – 2002 Coordinated Program Review was that the district did not have a process in place for determining specific learning Statutory requirements for the determination of specific learning disabilities have been revised under the recently reauthorized IDEA 2004. Therefore, until final Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 disability. The district’s approved Corrective Action Plan indicates that the school would use Department of Education forms to document observations of students by both the child’s teacher and at least one additional IEP Team member within the regular classroom setting. The district also would develop a form to document its determination of eligibility for SLD. implementing regulations have been adopted, the Department is not making findings related to school district practices under Coordinated Program Review Criterion SE 3. For districts seeking to resolve a previous finding in this area, the Department will extend the date required for final actions on the part of the school district to June 2006 and will consider resolution at any time following promulgation of final federal regulations. disabilities Record review in February 2005 indicates that SLD forms are not filed in student records. 4 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 6 Determinatio n of transition services (Emphasis on practices in determining needed transition planning and services and consideration of courses of study related to needed transition) SE 13 Progress Reports and Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 concern at the time of the 2001-2002 Coordinated Program The district must provide evidence that all staff have been trained on writing Student record review, documentatio n, interviews This criterion was implemented at the time of the 2001-2002 Coordinated Program Review. Record review in February 2005 indicates that documentation of discussion of transition needs is recorded on student IEPs. Student desires for post-secondary employment and living are considered when planning student curriculum. 688 referrals are made in a timely fashion for students who may need assistance from other agencies after completion of secondary school. Student record review, 5 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) content Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 was that progress reports did not address the student’s progress toward meeting IEP goals and benchmarks. quality progress reports. This evidence must include agenda for training, any handouts and signatures and titles of all staff in attendance at the training. Record review in February 2005 indicates that progress reports do not address progress toward specific benchmarks nor do they indicate whether a student’s progress will be sufficient to meet the goal by the end of the IEP period. This must be received at the Department of Education by September 15, 2005. interviews 6 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 15 Outreach by the School District (Child Find) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentatio n and interviews This criterion was implemented at the time of the 2001-2002 Coordinated Program Review. Documentation in February 2005 indicates that the school has continuous liaison with groups or individuals within the school to ensure that special education services are provided to all students who may require them. The regional vocational technical school is not required to conduct child find with other community groups. SE 17 Initiation of services at age three and Early Intervention Not Applicable This criterion is not applicable. Franklin County Regional Technical High School provides services to students in 7 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) transition procedures Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified grades 9 – 12. 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 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 18A IEP development and content Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 Student record review, documentatio n and interviews The concern at the time of the 2001-2002 Coordinated Program Review was that general educators did not participate in, or understand their role in, the development of the IEP. Additionally, there was no evidence that specialized instruction was discussed during the development of the IEP. Student record review in February 2005 indicates that a general education teacher is not in attendance at each IEP Team meeting. The special education Team meeting attendance sheet indicates that a general education 9 Submit a copy of the IEP meeting invitation letters and subsequent signature pages from the IEP meetings held between March 1 and May 30 for ten students to give evidence that at least one general educator is both invited to. and attends, each IEP Team meeting. Submit evidence that the school has provided a faculty workshop concerning the role and responsibilities of the IEP Team chair, general educator, special educator, parent, advocate, evaluators, service providers, etc. in the development of the IEP. Include a copy of the agenda, handouts and signatures and titles of staff Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 teacher is not invited to each IEP Team meeting. General education teachers submit a form on which they comment on student performance when they do not attend. Student record review indicated that discussion of specially designed instruction is now documented on the IEP. The approved Corrective Action Plan following the 20012002 CPR, however, indicates that the district will provide on-going workshops for faculty to review their roles and responsibilities in the development of the IEP. Evidence of these 10 members in attendance. This information must be received at the Department of Education by September 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance ongoing trainings was not provided to the Department of Education. 11 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 18B Determinatio n of placement; immediate provision of IEP to parent Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 concern at the time of the 2001-2002 Coordinated Program Review was that appropriate placement was not discussed by all IEP Team members required to be present at the IEP Team meeting. Submit a copy of the Special Education Student Record that indicates the regional vocational technical school has a current IEP in place for each student. Submit evidence of the school’s attempts to convene the IEP meeting and obtain a signed IEP for each student who does not have a signed IEP. This evidence may include letters to parents and sending school districts. Student record review and interview Student record review in February 2005 indicates that, as a general practice, the district is inappropriately writing IEP amendments to expired IEPs to continue services of the expired IEP instead of holding the required annual or re-evaluation IEP Team meeting. 12 This information must be received at the Department of Education by September 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 20 Least restrictive program selected Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 Student record review and interview This criterion was implemented at the time of the 2001-2002 Coordinated Program Review. Interviews in February 2005 indicate that students are educated in the least restrictive environment. The need for nonparticipation in the general education classroom, if needed, is documented in the student’s IEP. SE 22 IEP implementati on and availability (Emphasis on provision of IEP services without delay; provision of Documentatio n and interview 13 The concern at the time of the 2001-2002 Coordinated Program Review was that interviews with parents and teachers indicated that not all teachers were actively implementing all elements of student IEPs. Submit evidence that the school has provided a faculty workshop concerning the implementation of required IEP and 504 accommodations. Include a copy of the agenda, handouts and signatures and titles of staff members Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 IEP at the beginning of the school year; and, alternative methods of service delivery where there is a lack of space and/or personnel.) in attendance. The school’s Corrective Action Plan in response to the Department’s 20012002 Coordinated Program Review indicates that the school will provide ongoing faculty workshops concerning the implementation of required accommodations and that this would be monitored through observation and evaluation of faculty. Evidence of on-going trainings and monitoring of provision of accommodations was not submitted to the Department. Interviews indicate 14 Submit a copy of the evaluation form for staff members that indicates they will be monitored through observation and evaluation for their provision of required accommodations to students. This information must be received at the Department of Education by September 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance that the school has not had a delay in providing IEP services due to a lack of space or personnel. 15 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 26 Parent participation in meetings (Emphasis on district’s attempts to ensure parent participation at IEP Team meetings) SE 28 Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 criterion was implemented at the time of the 2001-2002 Coordinated Program Review. Submit a copy of ten cover letters sent to parents with a draft proposal for IEP services (N1 form) from March 1 – May 30, 2005 to give evidence that parents are supplied with required information on placement options that were considered by the IEP Team and rejected, along Student record review and interview This criterion was implemented at the time of the 2001-2002 Coordinated Program Review. Student record review and interviews in February 2005 indicate that a parent is in attendance at each IEP Team meeting. The parent’s vision for the student is discussed and recorded on the IEP. Student record review, interview The cover letter that is sent to parents with a draft proposal for IEP services (N1 form) does not answer 16 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 rights required questions including information on placement options that were considered by the IEP Team and rejected, along with factors considered as basis for the proposed IEP services and placement. 17 with factors considered as basis for the proposed IEP services and placement. This information must be received at the Department of Education by September 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified SE 29 Communicati ons are in English and primary language of home SE 32 Parent advisory council for special education Documentatio n and interviews This criterion was implemented at the time of the 2001-2002 Coordinated Program Review. In February 2005, the school submitted a policy that details how the district will provide translation services if necessary. Documentatio n and interviews This criterion was implemented at the time of the 2001-2002 Coordinated Program Review. Documentation submitted in February 2005 indicates that the school has held the required annual training on parent rights and responsibilities for its Special Education PAC and has held additional meetings throughout the 18 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified year to support the development of an active Special Education PAC. Interviews indicate that a group of parents has not come forward that is interested in forming an active Special Education PAC; therefore, PAC bylaws have not yet been developed. This is not a concern at this time, but development of Special Education PAC by-laws will be requested for the next Coordinated Program Review. 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 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 50 Responsibiliti es of the School Principal and Administrator of Special Education Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentatio n and interviews The concern at the time of the 2001-2002 Coordinated Program Review was that weekly meetings attended by general and special educators needed to focus more on developing an individual student plan for attempting accommodations and modifications within regular education classrooms to reduce inappropriate referrals of struggling students to special education for evaluation. In addition, home or hospital educational services had been funded through the special education budget and carried out under the responsibility of the special education coordinator rather than the principal. 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 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified In February 2005, the school provided the Department of Education with a copy of its Curriculum Accommodation Plan and its policy on providing services for students who have a home or hospital placement. These documents comply with Department requirements. 21 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 54 Professional development regarding special education Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 The concern at the time of the 2001-2002 Coordinated Program Review was that staff members reported in interviews that they were unclear about their role in the IEP Team meeting, as well as their responsibility to implement accommodations and modifications listed on student IEPs. Interviews in February 2005 indicate that teachers still do not fully understand their obligation to provide students with accommodations and modifications on IEPs. 22 See Corrective Action required under criteria SE 22 Submit evidence that the school has provided a faculty workshop concerning their individual responsibility and legal obligation to implement accommodations and modifications listed on student IEPs. Include a copy of the agenda, handouts and signatures and titles of staff members in attendance. This documentation must be received at the Department of Education by September 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 56 Special education programs and services are evaluated Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 concern at the time of the 2001-2002 Coordinated Program Review was that the district did not indicate how it uses information it collects to assess the effectiveness of special education programs and services offered in the district. The regional vocational technical school’s approved Corrective Action Plan following the 2001-2002 Coordinated Program Review states that the school will provide copies of meeting agendas and spreadsheet analysis as evidence that it is evaluating its special education programs Submit copies of meeting agendas and spreadsheet analysis that give evidence that the school is evaluating its special education programs and services. Documentatio n review 23 This documentation must be received at the Department of Education by September 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementatio n Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be 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 and services. This documentation was not submitted to the Department of Education in February 2005. Additional Special Education Requirements from the 2001 –2002 Coordinated Program Review SE 2 Required and optional assessments Student record review, interviews The concern at the time of the 2001-2002 Coordinated Program Review was that the process by which classroom teachers assess student’s performance did not comply with DOE guidance outlined in the DOE IEP Process Guide. In February 2005, the Department of Education found that the school routinely 24 recommends that psychological testing be waived for the re-evaluation, without respect to the student’s individual needs. Submit a copy of the school’s policy regarding recommending assessments that it conducts for a three- year re-evaluation. This documentation must be received at the Department of Education by September 15, 2005. SE 9 Eligibility and timelines Student record review, interviews The concern at the time of the 2001-2002 Coordinated Program Review was that the district did not adhere to required timelines for completing evaluations, holding IEP Team meetings and providing parents with a copy of the IEP. Student record review and 25 interviews conducted in February 2005 indicate that the district is now meeting timelines for completing assessments, holding IEP Team meetings and providing parents with a copy of the IEP. SE 12 Frequency of re-evaluation Student record review, interviews The concern at the time of the 2001-2002 Coordinated Program Review was that reevaluations were not conducted within 3 years, as is required. Student record review indicates that the district is now meeting required timelines. SE 25 Parental consent Student record review, interviews The concern at the time of the 2001-2002 Coordinated Program Review was that the district sometimes provides special education IEP services before the parent signs the IEP. Student record review and interviews conducted in February 2005 indicate that the district obtains consent before providing IEP services. Additional MOA and Title I Reporting Requirements from the 2001 –2002 Coordinated Program Review MOA 16 Options for students leaving school Documentati on review The district submitted a copy of the revised letter it sends to students age 16-21 who have left or are about to leave school 26 without obtaining a high school diploma or its equivalent. This letter now notifies students that they have the right to meet with a school representative to discuss their reasons for withdrawal and they have the right to reapply to Franklin County Technical School. Documentati on review MOA 25 Self evaluation TI 10 Parental involvement Documentati on review District submitted a copies of the parent involvement policy, Title I parent survey, informational meeting agendas, and sign-in sheets. Documentation showed opportunity for parental input into Title I program planning, review, and improvement. TI 11 Written procedures Documentati on review District submitted copies of signed Parent Teacher Compacts and explanation of 27 The school did not submit copies of documentation that would give evidence that the district developed plans to correct any areas of non-compliance with civil rights after reviewing results of the demographic representation of the student body by shop area and subject. Submit documentation that would give evidence that the district reviews results of the demographic representation of the student body by shop area and subject and then has developed plans to correct any areas of non-compliance with civil rights. This documentation must be received at the Department of Education by September 15, 2005. how to obtain translations of the documents. It is suggested that the district have the student agree to and sign the compact as well. TI 11A Materials and training for Title I parents Documentati on review District submitted information and one workshop opportunity for parents to attend. The extent of materials and training offered is limited. Provide evidence of district provision of more materials, strategies, and training offered to parents to assist them in improving their child’s achievement. This documentation must be received at the Department of Education by September 15, 2005. TI 24 Annual needs assessment and data analysis Documentati on review Documentation provided to the Department of Education did not indicate the summaries of the survey components. Submit documentation that indicates the summaries of survey components. A statement must also be included that Title I program and services will be adjusted to reflect the analysis of the survey results. This documentation must be received at the Department of Education by September 15, 2005. TI 24A Documentati The documentation 28 Submit listing of evaluation Annual evaluation of Title I programs and services on review 29 submitted to the Department of Education is incomplete. No evaluation findings of the Title I services and impact on student achievement were reported. findings related to the impact of Title I programming and description of any changes in the program resulting from evaluation findings. This documentation must be received at the Department of Education by September 15, 2005.