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
July 24, 2006
Regina Nash, Superintendent
Frontier Regional and Union #38 School Districts
219 Christian Lane RFD1
South Deerfield, Massachusetts 01373
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Nash:
Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted to verify the
implementation and effectiveness of corrective action approved by the Department to address
findings of noncompliance included in the Frontier Regional and Union #38 School Districts
Coordinated Program Review Report issued on March 24, 2003. The Mid-cycle Report also
contains findings based on onsite monitoring of special education compliance criteria that have
been newly created or substantially changed in response to IDEA 2004.
As you know, another component of the Department’s Mid-cycle Review is the review of your
school district or charter school's self-assessment in the area of English learner education (ELE).
(In the remainder of this letter, please read “district” as meaning “school district or charter
school.”) The purpose of this review is to determine whether your district is implementing the
significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient
students, that were adopted by voters by means of Question 2 in 2002. The Department has
reviewed your district’s ELE self-assessment documents and, based solely on that selfassessment, is providing you in this report with comments on your ELE program and, where
necessary, corrective action to be implemented. Your district is urged to request technical
assistance in relation to any of these comments or prescribed corrective action. To secure
assistance, you may consult with your Mid-cycle Review Chairperson or call Robyn DowlingGrant in Program Quality Assurance Services at 781-338-3732. You may also consult with staff
in the Department’s Office of Language Acquisition and Achievement at 781-338-3534 and
obtain additional ELE guidance documents through the Department’s web site at
http://www.doe.mass.edu/ell/.
While the Department of Education found your district to have resolved the majority of its
noncompliance issues, others were partially corrected or, as with the majority of the ELE criteria,
not addressed at all. Where the district has failed to implement its approved Corrective Action
Plan, the Department views these findings to be serious.
In all instances where noncompliance has been found, the Department has prescribed corrective
1
action for the district that must be implemented without delay. You will find these requirements
for corrective action included in the attached report, along with requirements for progress
reporting. Please provide the Department with your written assurance that all of the Department's
requirements for corrective action will be implemented by your school district within the
timelines specified. Your statement of assurance must be submitted to the Mid-cycle Review
Chairperson by July 31, 2006.
Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should
you like clarification of any part of our report, please do not hesitate to contact the Mid-cycle
Review Chairperson at 413-858-4591.
Sincerely,
Paul D. Battistoni, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Michael Ponti, District Program Review Follow-up Coordinator
Mary Raymon, Chairperson, Frontier Regional School Committee
Cindie Ouimett, Chairperson, Conway Grammar School Committee
Mark Capuano, Chairperson, Deerfield Elementary School Committee
Cindy Hubbard, Chairperson, Sunderland Elementary School Committee
Nathanael Fortune, Chairperson, Whately Elementary School Committee
Encl.: Mid-cycle Coordinated Program Review Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Frontier Regional and Union #38 School Districts
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): January 13, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: June 18, 2003
Dates of Corrective Action Plan Progress Reports: January 2004
Dates of this Mid-cycle Review Onsite Visit: May 15 and 16, 2006
Date of this Report: July 24, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 1 of 17
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification

Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
Not
Implemented
During the March 2003
Coordinated Program
Review it was determined
that the school union was
not always completing
and filing in student
records the educational
assessments as required in
section 1c of this
criterion.
The school union is to conduct
a faculty training on the use of
Educational Assessments for
initial evaluations and reevaluations to ensure that the
Educational Assessment
reports are complete, address
all required elements, and are
filed in student records.
Special
Education
Criteria
Originally
Cited in CPR
Report and
Monitored in
Mid-cycle
SE 2 Required
and Optional
Assessments
Student record
review
Student record review
during the May 2006
Mid-Cycle Review
indicated continued nonFrontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 2 of 17
By December 1, 2006 the
school union is to submit to the
Department an agenda and
sign-in sheet verifying this
training.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
compliance with this
criterion.
SE 4
Reports of
assessment
results
Yes
Student record
review and
interviews
Student records document
parents’ requests for
evaluation summaries two
days in advance of the Team
meetings, along with the date
of the actual meeting.
Student records and
interviews indicated that
parents receive copies of
evaluations 2 days prior to
IEP Team meetings and that
they may access the results
earlier if requested.
SE 9
Eligibility
determination:
Yes
Documentation
and student
record review
The school union has
developed a tracking system
to accurately oversee and
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 3 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
By December 1, 2006 the
school union must also submit
to the Department a sample of
20 Educational Assessment
reports from initial evaluations
and re-evaluations.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
adhere to the timelines for
determining special
education eligibility.
Timelines for
evaluation,
provision of
IEP and/or
identification
of other
needed
instructional
programs
SE 19
Extended
evaluation
Yes
Student record
review and
interviews
Student record review and
interviews indicated that
extended evaluations were
used appropriately (only after
determining the student’s
eligibility for special
education services).
SE 32
Parent
advisory
council for
special
Yes
Documentation
and interviews
The school union has an
established Parent Advisory
Council that meets the
requirements of this
criterion.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 4 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
education
SE 34
Continuum of
alternative
services and
placements
Yes
Documentation
and interviews
The school union offers a
broad continuum of services
and placements to meet the
needs of students in special
education.
SE 45
Procedures for
suspension up
to 10 days and
after 10 days:
General
requirements
Yes
Documentation
and interviews
The school union has
included in its student
handbooks all of the
requirements of this
criterion.
SE 53
Use of paraprofessionals
Yes
Documentation
and interviews
Throughout the school union
paraprofessionals receive
training that is designed to
assist them in providing
appropriate services.
SE 54
Professional
development
Yes
Documentation
and interviews
The school union considers
the needs of all staff in
developing training
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 5 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
opportunities and provides a
variety of offerings, which
include the required topics.
SE 56
Special
education
programs and
services are
evaluated
Yes
Documentation
and interviews
The school union’s special
education programs,
services, and administrative
areas are evaluated as
required by this criterion.
The school union regularly
gathers information from a
wide variety of sources and
summarizes this information
annually in order to
effectively plan for future
school years.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 6 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Yes
Student record
review,
documentation,
and interviews
The onsite team reviewed
student records that
demonstrated that vision
statements included
information regarding a
student’s future direction and
goals. Additionally the
school union is documenting
transition related activities on
a grid in the student record.
(Refer to full
text of 20052006 CPR
requirements)
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 6
Determination
of Transition
Services
SE 8
IEP Team
composition
and attendance
Documentation
and interviews
Criterion
Determined
to be
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
Partially
implemented
Interviews indicated that
the special education
coordinators often chair
Team meetings but they
do not have authority to
commit the school’s
resources.
The school union must develop
a plan to ensure that someone
with the authority to commit
union resources will be in
attendance at each IEP Team
meeting. Submit this plan to
the Department by December
1, 2006.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 7 of 17
SE 12
Frequency of
re-evaluation
Yes
Student record
review and
documentation
The student record review
and the review of the IEP
logs indicated consistent
implementation of
completing the three-year reevaluation within required
timelines.
SE 13
Progress
Reports and
content
Partial
Student record
review and
documentation
The progress reports give
information on the student’s
progress toward the annual
goal.
Partial
The school union does not
consistently provide
progress reports to parents
at least as often as parents
are informed of the
progress of non-disabled
students. Progress reports
do not always indicate if
the progress is sufficient
for the student to achieve
the goal by the expiration
of the IEP period.
The school union will draft a
memo to all staff who
complete special education
progress reports reiterating the
requirement that progress
reports are to be provided to
parents at least as often as
parents are informed of the
progress of non-disabled
students and they must indicate
if the progress is sufficient for
the student to achieve the goal
by the expiration of the IEP
period.
A copy of the memo and a
sample of 10 progress reports
will be submitted to the
Department by December 1,
2006.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 8 of 17
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Yes
Student record
review and
documentation
Student records and
documentation indicated that
the school union conducts
annual reviews within the
required timelines.
SE 25B
Resolution of
disputes
Yes
Documentation
and interviews
The school union has put into
place procedures and forms
for dispute resolution.
SE 30
Notice of
procedural
safeguards
Yes
Student record
review and
interviews
N1 notices document that the
school union is providing
parents with copies of the
Interim Notice of Procedural
Safeguards.
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days
Yes
Documentation
Documentation review
indicated that the school
union has not had any
students suspended close to
or exceeding 10 days for this
school year; however, the
school union has current
policies and procedures for
the suspension of students
with disabilities in place.
(Refer to full
text of 20052006 CPR
requirements)
SE 14
Review and
revision of
IEPs
Criterion
Determined
to be
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 9 of 17
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
MOA 1
Identification
of limitedEnglishproficient
students
Not
Effectively
Implemented
Please See ELE 3 below.
Please See ELE 3 below.
MOA 2
Program
modifications
and support
services for
limitedEnglishproficient
students
Not
Effectively
Implemented
Please See ELE 5 below.
Please See ELE 5 below.
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Civil Rights
(MOA) and
Other General
Education
Requirements
MOA 7
Information to
Yes
Student record
review,
Student record review,
documentation, and
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 10 of 17
be translated
into languages
other than
English
documentation,
and interviews
interviews indicated that
special education
documentation is translated
into the primary home
language when necessary.
MOA 9
Hiring and
employment
practices of
prospective
employers of
students
Partial
Documentation
The school union has created
a new antidiscrimination
statement, for prospective
employers to sign, which
states that the prospective
employer will not
discriminate based on sex,
race, color, ethnicity, sexual
orientation, religion or
disability when recruiting
and/or employing students.
MOA 21
Staff training
regarding civil
rights
responsibilities
Yes
Documentation
and interviews
Documentation and
interviews verify that the
school union provided the
required annual training on
civil rights responsibilities.
Partial
During the documentation
review, no signed
antidiscrimination
statements were present.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 11 of 17
To verify that the school union
is using the antidiscrimination
statement, the school union
will submit 5 signed
antidiscrimination statements
from prospective employers
when recruiting and/or
employing students by
December 1, 2006.
Frontier Regional and Union 38 School District
English Learner Education (ELE) Requirements
Mid-Cycle Review Comments and Corrective Action Based on the Department’s Review Of Local Self-Assessments
(Please refer to full text of 2005-2006 CPR-ELE legal requirements and related implementation guidance at
http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc )
ELE Criterion
Number
and
Topic
ELE 1
Annual
Assessment
Comments Based on the Department’s Review of Local
ELE Self-Assessment
The school union did not address how it annually assesses all
limited English proficient (LEP) students.
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
The school union must submit to the Department a proposed process for the
annual assessment of LEP students and include staff name, title, and role in the
annual assessment process by December 1, 2006.
The school union must also submit a list of staff members who are trained in
MEPA and MELA-O by August 30, 2006.
ELE 2
MCAS
Participation
The school union did not submit adequate documentation for
this criterion.
By August 30, 2006 the school union must submit to the Department its policy
that ensures the participation of all ELE students in MCAS testing.
The school union must also provide the Department with a description of how it
provides accommodations for LEP students during the MCAS by August 30,
2006.
ELE 3
Initial
Identification
The school union did not submit adequate documentation for
this criterion.
By August 30, 2006 the school union must submit to the Department a
description of its procedures for identifying all potential LEP students.
To ensure that all students in the school union have been screened, home
language surveys will be mailed to all students within the school union. By
December 1, 2006, the school union will submit a copy of their tracking form
listing the names of all students to whom the home language survey has been
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 12 of 17
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
mailed to and the return rate of the home language surveys.
ELE 4
Waiver
Procedures
The school union has not developed a waiver process.
The school union must develop waiver procedures consistent with the
requirements of M.G.L/ c. 71A s5 and submit a copy to the Department by
August 30, 2006.
ELE 5
Program
Placement and
Structure
The school union does not currently have a viable ELE
program.
The school union needs to provide professional development to all instructional
staff who have ELE students in their classes to ensure that staff is qualified to
provide Sheltered English Immersion. The school union must submit a copy of
its proposed professional development plan that includes this training by August
30, 2006.
ELE 6
Program Exit
and Readiness
The school union does not have policies and procedures
regarding program exit and readiness.
The school union must develop policies and procedures for limited English
proficient students’ program exit. A description of the policies and procedures
must be submitted to the Department by August 30, 2006.
The school union does not have a description of how they plan
to involve parents of students who are LEP.
The school union must develop policies and procedures for involvement of
parents of limited English proficient students. Policies and procedures must be
submitted to the Department by August 30, 2006.
The school union does not have policies and procedures
regarding students whose parents have declined entry to an
ELL program.
The school union must develop policies and procedures for LEP students whose
parent have declined entry in the ELL program. Policies and procedures must be
submitted to the Department by August 30, 2006.
The school union does not have policies and procedures
regarding the instructional grouping of LEP students.
The school union must develop policies and procedures regarding the
instructional grouping of LEP students. Policies and procedures must be
submitted to the Department by August 30, 2006.
ELE 7
Parent
Involvement
ELE 8
Declining Entry
to a Program
ELE 9
Instructional
Grouping
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 13 of 17
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
ELE 10
Parental
Notification
The school union does not have policies, procedures, or
supporting documentation regarding the required elements of
parent notices.
The school union must develop policies and procedures regarding notices sent to
parents of LEP students. In addition, the school must develop notice forms that
include all required elements, in the language that the parent has requested on the
home language survey. Policies and procedures, as well as a sample notice form,
must be submitted to the Department by August 30, 2006.
ELE 11
Equal Access to
Academic
Programs and
Services
The school union does not address the requirements of equal
access to academic programs and services for LEP students.
The school union must develop policies and procedures regarding equal access to
academic programs and services for LEP students. Policies and procedures must
be submitted to the Department by August 30, 2006.
ELE 12
Equal Access to
Nonacademic
and Extracurricular
Programs
The school union does not address the requirements of equal
access to nonacademic and extracurricular programs for LEP
students.
The school union must develop policies and procedures regarding equal access to
nonacademic and extracurricular programs for LEP students. Policies and
procedures must be submitted to the Department by August 30, 2006.
ELE 13
Follow-up
Support
The school union does not have policies or procedures
regarding the monitoring activities provided for students who
have exited the ELE program.
The school union must develop policies and procedures regarding the monitoring
activities provided for students who have exited the ELE program. Policies and
procedures must be submitted to the Department by August 30, 2006.
The school union indicated they attempt to assure that all
teachers have the necessary requirements to teach in the
program; however, did not give any details on how they do
this.
Teachers who instruct in SEI classrooms must have a content license and
ESL/ELL license; or have a content license and co-teach with another teacher
who holds an ESL/ELL license; or have a content license and have obtained
intense and sustained professional development in
ELE 14
Licensure and
Fluency
Requirements
(1) Second language learning and teaching
(2) Sheltering content instruction
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 14 of 17
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
(3) Assessment of speaking and listening
(4) Teaching reading and writing to limited English proficient students. (See
http://www.doe.mass.edu/ell/news04/0615qualifications.pdf)
The school union must submit a list of all teachers who have limited English
proficient students in their classrooms. Indicate if they possess the appropriate
license, or are teaching under the professional development qualification, listing
professional development attended, number of participation hours, topics
covered, and name of trainer by August 30, 2006.
The school union must also submit a professional development plan for
providing teachers with the Sheltered English Immersion training that is required.
This plan must be submitted to the Department by August 30, 2006.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 15 of 17
ELE Criterion
Number
and
Topic
ELE 15
Professional
Development
Requirements
ELE 16
Equitable
Facilities (To be reviewed
during next
CPR visit)
ELE 17
DOE Data
Submission
Requirements
and Program
Evaluation
Comments Based on the Department’s Review of Local
ELE Self-Assessment
See ELE 5.
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
See ELE 5.
To be reviewed during the next CPR visit.
The school union did not submit the required data for this
criterion. The school union does not have a formal procedure
to evaluate the effectiveness of its English Learner Education
program.
By August 30, 2006 submit to the Department:
1. The schools in which LEP students are enrolled
2. The grade levels of the students
3. The primary languages of each LEP student
4. The types of English learner programs in which the district has
enrolled LEP students, including sheltered English immersion, twoway bilingual, transitional bilingual education (for students with
waivers only), or students whose parents have declined services.
The school union must also submit to the Department its plan to evaluate the
effectiveness of its English Learner Education program by August 30, 2006.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 16 of 17
ELE Criterion
Number
and
Topic
ELE 18
Records of LEP
Students(To be reviewed
during next
CPR visit.)
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
To be reviewed during the next CPR visit.
Frontier Regional and Union #38 School Districts Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 17 of 17