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 March 7, 2007 Sue M. Gee, Superintendent Gill-Montague Regional School District 35 Crocker Avenue Turners Falls, Massachusetts 01376 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Gee: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Coordinated Program Review Report (Mid-Cycle Report). This report contains findings based on onsite monitoring conducted to verify the implementation and effectiveness of corrective action approved or ordered by the Department to address findings of noncompliance included in the Gill-Montague Regional School District Coordinated Program Review Report issued on January 7, 2005. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. Another component of the Department’s Mid-cycle Review is the review of your school district or charter school's self-assessment in the area of English learner education (ELE). (In the remainder of this letter, please read “district” as meaning “school district or charter school.”) The purpose of this review is to determine whether your district is implementing the significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient students, that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your district’s ELE self-assessment (documentation and any written analysis of compliance) and, based solely on that self-assessment, is providing you in this report with findings on your ELE program and the corresponding corrective action to be implemented. Your district is urged to request technical assistance in relation to any of these findings or this prescribed corrective action from me or from staff in the Department’s Office of Language Acquisition and Achievement at 781338-3534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/. While the Department of Elementary and Secondary Education found your district to have resolved all previous noncompliance issues with the exception of two (SE 13 and MOA 16), the Department’s onsite team has identified two new issues of noncompliance. In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that must be implemented without delay. You will find these requirements for corrective action included in the attached report, along with requirements for progress 1 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 Darlene Lynch, Director, Program Quality Assurance Services, 350 Main St., Malden, MA 02148, by March 22, 2007. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 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 Elementary and Secondary Education Mary Kociela, School Committee Chairperson Cynthia Joyce, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Gill-Montague Regional School District ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): March 22 - 26, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: August 5, 2005 Dates of Corrective Action Plan Progress Reports: January 15, 2006 Dates of this Mid-cycle Review Onsite Visit: January 22 – 24, 2007 Date of this Report: March 7, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 1 of 21 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle SE 3 SLD Statutory requirements for the determination of specific learning disabilities have been revised under the recently reauthorized IDEA 2004. Therefore, 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 and will consider resolution following the issuance by MA ESE of guidance regarding the implementation of related federal regulations. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 2 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority Student record review The district implements all procedures regarding students turning 18 and transfer of parental rights at age of majority. Evidence of completed activities/notices is maintained in students’ files. SE 9 Timeline for determination of eligibility and provision of documentation to parent Documentation and student record review The district has developed a tracking system to accurately oversee and adhere to the timelines for determining special education eligibility. SE 15 Outreach by the School District (Child Find) Documentation and interviews The district conducts frequent outreach and continuous liaison with various local organizations to 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 Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 3 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance identify students in need of special education. SE 18A IEP Development and Content Student record review and interviews Student record review and interviews indicated that the district is documenting the IEP Team’s discussion of parent and student wishes, evaluation results, and needed specially designed instruction on the current Massachusetts ESE IEP format. SE 19 Extended Evaluation Documentation and interviews Documentation and interviews indicated that the district conducts an extended evaluation if the Team determines that a student is eligible for special education services but does not have enough information to write a full IEP. The district writes an IEP based on the information currently available, obtains parental Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 4 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance consent, conducts the evaluation, and holds a Team meeting within 8 weeks of parent consent. SE 22 IEP implementation and availability Student record review, documentation, and interviews The school district has an IEP in effect for each student at the beginning of the school year. The district has in place policies and procedures to ensure that services are provided without delay. SE 27 Content of Team meeting notice to parents Student record review and documentation The district ensures that parent notices meet all state and federal law content requirements and Team meeting notices state the purpose, time, location and attendees. Documentation, student record review, and interviews The district provides the parent with the fully developed IEP immediately following its development SE 28 Notice Sent to Parent with IEP Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 5 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance and without undue delay. SE 29 Communications are in English and primary language of home Documentation, student record review, and interviews The Department had no compliance concerns with this criterion. SE 30 Parents’ Rights Documentation, student record review, and interviews The district is providing parents with the current Notice of Procedural Safeguards brochure. SE 41 Age Span Documentation, student record review, and interviews The ages of the students in the district’s instructional groupings comply with state requirements. SE 45 Procedures for suspension up to 10 days and after 10 days: General requirements Documentation and interviews The district has included in its student handbooks all of the requirements of this criterion. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 6 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 49 Related Services Student records Student records indicated that IEPs consistently specify the type of modifications and/or specialized equipment and precautions. Related services are routinely considered and consistently identified on IEPs. SE 50 Responsibilities of the School Principal and Administrator of Special Education Documentation and interviews Documentation and interviews demonstrated that the district’s administrator of special education is meeting all statutory requirements. SE 54 Professional Development Documentation and interviews The district considers the needs of all staff in developing training opportunities and provides a variety of offerings, which include the required topics. 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 Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 7 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 55 Special Education Facilities and Classrooms Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting New Issues Identified Observations at the Montague Center School revealed that related services are conducted in a room that is located in an isolated corridor that is removed from the life of the school. By June 1, 2007 submit a written plan to correct all issues of non-compliance related to this criterion. Interviews and observations Observations at the Hillcrest Elementary School revealed that special education classrooms and services are clustered in one wing of the school and are separate and distinct from the general education classrooms. Observations and interviews indicated that students in the Old Mill elementary and middle school programs are located in the central office building and are Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 8 of 21 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance segregated from the general population of the school district. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 9 of 21 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 SE 6 ##1 - 3 Determination of Transition Services Documentation, student records, 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 district is documenting transition related activities on a grid in the student record. SE 8 IEP Team composition and attendance Documentation, student records, and interviews IEP Teams consistently have all required people in attendance. SE 12 Frequency of re-evaluation Student records and interviews The district meets all requirements of this criterion. Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Special Education Criteria created or revised in response to IDEA-2004 Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 10 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting SE 13 Progress Reports and content The district provides parents with progress reports on students’ progress toward reaching the IEP goals; however, they are not issued at least as often as parents are informed of the progress of non-disabled students. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 11 of 21 By June 1, 2007 provide training for special education staff, including related service providers, on this requirement and submit the agenda and attendance sheet to the Department. In addition, submit a random sample of 5 progress reports from each school building to the Department. Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented SE 14 Review and revision of IEPs Student records and interviews The district ensures that IEPs are reviewed on or before the anniversary date of their implementation date to consider the student’s progress and develop a new IEP. SE 25B Resolution of disputes Documentation and interviews The district has put into place procedures and forms for dispute resolution. SE 33 Involvement in the General Curriculum Documentation, student records, and interviews Documentation, student records, and interviews indicated that all students have access to the general curriculum. SE 39A Procedures for services to eligible private school students whose parents reside in the district Documentation and interviews Documentation and interviews indicated that the district has procedures to provide services to eligible students enrolled in private schools at private expense whose parents reside in the district. Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented (SE 39A does Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 12 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting 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 Documentation and interviews Documentation and interviews indicated that the district has procedures to provide services to eligible students enrolled in private schools at private expense whose parents reside out of state. Documentation and interviews The district has appropriate procedures in place for suspension of students with disabilities more than 10 days. (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 13 of 21 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Documentation and interviews Based on documentation and interviews all students have access to the full range of educational programming at all school levels. 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 New Issues Identified The onsite team determined that there is a full continuum of special education programs and services offered at each elementary school within the district, except at the Montague Center School. By June 1, 2007 the district is to submit a description of its screening and identification process for students with special needs. In this description include the numbers of identified students, the schools in which they attend, and their disabilities. Civil Rights (MOA) and Other General Education Requirements MOA 3 Access to all Education Programs MOA 4 Placement of female students, males students, homeless students, students with disabilities, and students from linguistic and racial/ethnic groups While all other elementary schools have a proportionate representation of special needs students and programs, the onsite team determined that there are a disproportionately low Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 14 of 21 The district is to submit a description of its referral process for special education. Include in this description the referral rates from each of the school buildings within the district, the suspected number of students with disabilities at the Montague Center School and that no special education programs or services are offered at the Montague Center School. MOA 7 Translated Information Documentation and interviews The district arranges for the translation of notices and documents where appropriate. MOA 9 Hiring of Students Documentation and interviews Documentation indicated that prospective employers of students are required to sign a statement of nondiscrimination. MOA 10A Student Handbooks and Codes of Conduct Documentation Documentation indicated that student handbooks and codes of conduct contain all of the requirements of this criterion. MOA 11A Grievance Procedures Documentation Documentation indicated that the student handbooks contains grievance procedures for students and for employees providing for prompt and equitable resolution of complaints alleging discrimination based Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 15 of 21 disabilities of each student, and the outcome of the eligibility determination. The district is to submit a description of its exit criteria for students who have been determined no longer eligible for special education services. In this description include the school building the student attended at the time he/she was exited from special education. on sex or disability. MOA 12A Notification of non-discrimination Documentation and interviews Documentation and interviews indicated that the district publicizes statements of nondiscrimination. MOA 14 Counseling materials Documentation and interviews The district has provided documentation that scholarships, prizes or awards administrated or sponsored by the district are free of restrictions and are non-discriminatory. MOA 16 Notice to students leaving school without diploma Documentation and interviews This criterion was Not Implemented during the 2004 CPR and has not been corrected for the Mid-cycle Review. Documentation review indicated that the letter the district sends to parents of students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion does not meet all of the requirements of this criterion. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 16 of 21 By March 30, 2007 the district will submit a revised copy of the notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion that contains all of the requirements of this criterion. MOA 17A Restraint training Documentation and interviews Documentation and interviews indicated that the district provides annual physical restraint training to all district staff. MOA 21 Staff Training Civil Rights Documentation and interviews Documentation and interviews indicated that the district has conducted all required civil rights training for its staff. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 17 of 21 Gill-Montague Regional School District English Learner Education (ELE) Requirements Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc) ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification ELE 4 Waiver Procedures Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 18 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 5 Program Placement and Structure ELE 6 Program Exit and Readiness ELE 7 Parent Involvement ELE 8 Declining Entry to a Program ELE 9 Instructional Grouping ELE 10 Parental Notification Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The parental notification letter does not contain components a, d, e, and f of this criterion. Required Corrective Action, Timelines for Implementation, and Progress Reporting By June 1, 2007 the district is to submit a revised copy of its parental notification letter that contains all of the required components of this criterion. Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 19 of 21 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs ELE 13 Follow-up Support ELE 14 Licensure Requirements Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 20 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 15 Professional Development Requirements ELE 16 Equitable Facilities ELE 17 Program Evaluation ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Gill-Montague Regional School District Coordinated Program Review Mid-cycle Report March 7, 2007 Page 21 of 21 Required Corrective Action, Timelines for Implementation, and Progress Reporting