Massachusetts Department of Elementary and Secondary Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 April 30, 2008 Wayne Ogden, Superintendent Franklin School District 355 East Central Street Franklin, MA 02038 Re: Mid-cycle Report Dear Superintendent Ogden: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report. This report contains findings based on onsite monitoring the Department conducted to determine the effectiveness of corrective action it approved or ordered to address noncompliance identified in your district’s last Coordinated Program Review Report, dated August 9, 2004. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. The onsite team would like to commend the following programs and practices that were brought to its attention and that the team believes have a significant positive impact on the education of students enrolled in the Franklin School District. These programs and practices are as follows: Significant program development has occurred in the last three years including the Pathways program that includes an at-risk program for high school freshmen, a program for emotionally fragile high school students, and an alternative program for students in general and special education. Another new program was developed at the kindergarten through grade two for literacy immersion. The new program development at the middle school included a therapeutic program. The therapeutic program at the elementary school was split so that there is now a program for grades K-2 and one for grades 3-5. The district has also provided program development for students who receive home-based services by hiring their own Board Certified Behavior Specialists to ensure continuity with the school-based curriculum for students on the autism spectrum. The district is commended for the highly individualized information provided on the Present Level of Performance A page of the IEP and for the rich continuum of services available to eligible students. The Parent Advisory Council and the Special Education Administrator convened a meeting for both parents and students to build self-advocacy skills for students. The district is also commended for the extended school year services that provide a variety of 1 options to meet students’ needs, including an integrated program and opportunities for free summer services for students participating in Title I programs and students identified as English Language Learners. The district has been effective in meeting Adequate Yearly Progress (AYP) at the middle school for the special education student subgroup due to the combined approach between special education and regular education math teachers as well as curriculum alignment for math. The district plans to use a similar approach at the elementary level. While the Department of Elementary and Secondary Education found your district to have resolved certain noncompliance issues, others were partially corrected or not addressed at all, or the Department’s onsite team identified new issues of noncompliance, including but not limited to noncompliance with special education criteria added or substantially changed in response to IDEA 2004. Where the district has failed to implement its Corrective Action Plan, the Department views these findings to be serious. In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that must be implemented without delay. You will find these requirements for corrective action included in the enclosed report, along with requirements for progress reporting. Please provide the Department with your written assurance that all of the Department's requirements for corrective action will be implemented by your district within the timelines specified. You must submit your statement of assurance to me by May 16, 2008. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 781-338-3715. Sincerely, Joan Brinckerhoff, Ph.D., Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: Jeffrey Nellhaus, Acting Commissioner of Elementary and Secondary Education Jeffery N. Roy, School Committee Chairperson Linda Waters, District Program Review Follow-up Coordinator Encl.: Mid-cycle Report 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT FRANKLIN SCHOOL DISTRICT Date of Coordinated Program Review (CPR) Final Report: August 9, 2004 Date Coordinated Program Review Corrective Action Approved or Ordered: October 8, 2005 Dates of Corrective Action Plan Progress Reports: January 28, 2005 and June 1, 2005 Dates of this Mid-cycle Review Onsite Visit: February 26-28, 2008 Date of this Report: April 30, 2008 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Special Education Criteria Cited in CPR Report and Monitored in Mid-cycle Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number/Topic Approved Corrective Action Implement ed and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Student Records, Documentation and Staff Interviews Students are consistently invited to the Team meeting at age 14 and most students attend their Team meeting. When agencies are needed for transition activities, they regularly participate in Team meetings. The transition forms are completed and updated annually for students of transition age. IEPs SE 6 Transition Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 1 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic Approved Corrective Action Implement ed and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance contain transition goals and services that are individualized for the student. SE 18A IEP Development Student Records, and Staff Interviews The district is commended for the individualized information provided on the Present Level of Performance A that indicates how a student accesses the general education curriculum. Accommodations were presented for each curriculum area (i.e. written language, math). The Student Strengths and Key Evaluation Results Summary was highly individualized and always reported MCAS results or status. The IEPs reviewed for the mid cycle were current for the school year and all were fully completed. The district manual for procedures is comprehensive and assists staff in completing IEPs . SE 18B Placement and Provision of IEP Student Records, and Staff Interviews The district is using the new placement forms and students are provided services in the least restrictive environment. The district has made great strides is servicing many students that were returned from out-of-district placements through extensive Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 2 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic Approved Corrective Action Implement ed and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance program development. Parents sign off on the receipt of two copies of the IEP acknowledging immediate receipt of the IEP. SE 24 Notice Student Records, Documentation and Staff Interviews All student records contained notices for evaluations, IEPs and amendments. The schools that use a narrative format to answer guiding questions are commended. Some schools use a list format that is not as informative or individualized. SE 29 Student Records, Documentation and Staff Interviews The district has nine resources for translation of materials to address the large number of languages within the district. SE 42 Programs for Young Children Student Records, Documentation and Staff Interviews The district does not have any six year olds in preschool. The preschool program is state-of-theart in providing trans-disciplinary services and in the architectural design of the building and playground to support the preschool children. SE 46 Suspension Student Records, Documentation and Staff Interviews The district has procedures for addressing suspension of students Communications in English and Primary Language of the Home Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 3 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic Approved Corrective Action Implement ed and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance with disabilities that meet the requirements of IDEA 2004. The district has provided training on the new requirements from IDEA 2004 for Principals, Assistant principals, Team Chairs, School Psychologists, and Adjustment Counselors. Students with Disabilities SE 55 Special Education Facilities and Classrooms Corrective Action Not Implemented or Not Effective or New Issues Identified Classroom Observation The room for occupational therapy and physical therapy at the Helen Keller Elementary School was moved to a larger space that accommodates the equipment that students use. The high school substantially separate classroom has been moved to a larger room that is appropriate for the number of students and the instructional materials for academics, independent living and vocational skills. Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 4 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Special Education Criteria Created or Revised in Response to IDEA-2004 Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number and Topic SE 3 Special requirements for determination of specific learning disability SE 6 ##1 - 3 Determination of Transition Services SE 8 IEP Team composition and attendance Criterion Implemented er them in the fall. Method(s) of Verification Basis of Determination that Criterion was Implemented Student Records, Documentation and Staff Interviews Student records and staff interviews indicated that the district uses appropriate assessments and a form documenting the determination of a specific learning disability. The district is aware of the new SLD forms and plans to utilize them in the fall of 2008. See SE 6 above. Student Records, Documentation and Staff Interviews Partial Student Records, Documentation and Staff Interviews Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Partial Some of the Team meetings did not have a regular educator teacher where one should have attended the Team meeting. Refine procedures for ensuring regular education teacher attendance at Team meetings when required Submit a copy of the procedures by June 5, 2008. Conduct an internal review of records and submit a report to the Department indicating the number of records reviewed for each school, the rate of compliance for regular educator attendance at the Team meeting and a description of additional corrective actions taken by the district to correct any identified non-compliance by November 14, 2008. The district has persons with authority to commit the district resources at every Team meeting. Team meetings always include a Team Chair, parents, evaluators when eligibility is being determined, and a special education teacher. Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 5 of 10 Criterion Number and Topic Criterion Implemented er them in the fall. Method(s) of Verification Basis of Determination that Criterion was Implemented SE 12 Frequency of re-evaluation Student Records, Documentation and Staff Interviews Student records and staff interviews indicated the district is proactive in conducting re-evaluations. For example, if a re-evaluation is due in September, the district will complete it in June so that the student begins the year with a current IEP. Partial Student Records, and Staff Interviews The progress reports for preschool, elementary, middle school and high school students are sent as often as those sent to nondisabled students. Student Records, Documentation and Staff Interviews The district has an effective tracking system that allows for annual reviews to be consistently done on or before the anniversary date of the IEP. Student Records, Documentation The district documentation indicated that the resolution session SE 13 Progress Reports and content SE 14 Review and revision of IEPs SE 25B Resolution of disputes Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Partial The content for high school progress reports did not always address progress towards reaching the goal. Train high school special education and related services staff in documenting progress for IEP goals. Provide the training agenda, handouts and sign-in sheets by April 30, 2008. Six months after the training conduct an internal review and report on the number of progress reports reviewed and the rate of compliance. Also, describe the additional corrective actions that the district has taken for any continuing non-compliance by November 14, 2008. Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 6 of 10 Criterion Number and Topic SE 33 Involvement in the General Curriculum SE 39A Procedures for services to eligible private school students whose parents reside in the district Criterion Implemented er them in the fall. Method(s) of Verification Basis of Determination that Criterion was Implemented and Staff Interviews was effective in reaching an agreement. The district is very proactive in the communication with parents and provision of a problem solving approach to individually meet the needs of students and communicate with their parents. Student Records, Documentation and Staff Interviews The district is commended for addressing the Adequate Yearly Progress in math at the middle school level for the special education subgroup. They tailored the curriculum level to MCAS and combining math and special education teachers for instruction in order to achieve the AYP. The district is also commended for the aggressive approach to program development. In three years they have created six new programs to meet the needs of students and maintain students within the district. Student Records, Documentation and Staff Interviews The district submitted the calculation for proportionate share of Federal Special Education entitlement funds. The district conducts child find activities for all age groups. The district staff provide consultation to many private preschools. Currently the district does not have any students Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 7 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (SE 39A does not apply to charter schools or vocational schools) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days SE 52 Appropriate certifications/ licenses or Criterion Implemented er them in the fall. Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented placed at private expense. Documentation and Staff Interviews The district is aware of the procedures but does not have any students with parents out-of-state. Student Records, Documentation and Staff Interviews See above SE 46 Documentation and Staff Interviews The district provided certification for an interpreter for a family with young children. The district also utilizes interpreters from the Commission for Deaf and Hard of Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 8 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented er them in the fall. Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Hearing. Recently the district hired a paraprofessional that is certified in Virginia and is seeking Massachusetts certification as an interpreter. other credentials – related service providers (to be reviewed only with respect to providers of interpreting services) Special Education Criteria Monitored because of Issues Identified since the CPR Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented None Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 9 of 10 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criteria from Other Regulated Programs Monitored During this Mid-cycle Review Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective MOA 7 Information Translated into Languages Other than English Student Records, Documentation and Staff Interviews The district has seven resources to translate documents and several for oral translation. Interpreters are provided for Team meetings and parent conferences. MOA 10A Code of Conduct Student Handbooks Partial Documentatio n and Staff Interviews The district provides a code of conduct and appropriate procedures for the discipline of students with disabilities on IEPs. Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Partial The disciplinary procedures for students with disabilities do not include students on 504 Plans. Provide the amended language in the code of conduct to include students with disabilities that are on IEPs and 504 Plans by June 5, 2008. Franklin School District Coordinated Program Review Mid-cycle Report April 30, 2008 Page 10 of 10