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
August 6, 2008
Christopher Farmer, Superintendent
Gloucester Public Schools
6 Schoolhouse Road
Gloucester, MA 01930
Re: ’08 Mid-cycle Report
Dear Superintendent Farmer:
Enclosed is the Department of Elementary and Secondary Education's ’08 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 October 21, 2005. The ’08 Midcycle 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.
While the Department of Elementary and Secondary Education found your district to have
resolved certain noncompliance issues, others were partially corrected. Where the district has
failed to fully implement its Coordinated Program Review Corrective Action Plan, the
Department views these findings to be serious. The Office of Special Education Programs of the
U.S. Department of Elementary and Secondary Education requires that all special education
noncompliance be corrected as soon as possible, but in no case later than one year from the time
of identification; where the district has failed to implement its CPR Corrective Action Plan, this
one-year period has long since passed.
In all instances where noncompliance has been found, the Department has prescribed corrective
action for the district that must be implemented without delay. (In the case of new findings of
noncompliance, this corrective action must be corrected as soon as possible, but in no case later
than a year from the date of this report.) 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 in the report.
You must submit your statement of assurance to me by August 22, 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 781-338-3731.
Sincerely,
Donna Feinberg, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education
Greg Verga, School Committee Chairperson
JoAnne Reiss, District Program Review Follow-up Coordinator
Encl.: ’08 Mid-cycle Report
Mid-cycle Cover Letter 2008.doc
Rev. 2-21-08
MASSACHUSETTS DEPARTMENT OF
ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE REPORT
Gloucester Public Schools
Date of Coordinated Program Review (CPR) Final Report: October 21, 2005
Date Coordinated Program Review Corrective Action Approved or Ordered: April 24, 2006
Dates of this Mid-cycle Review Onsite Visit: June 17-19, 2008
Date of this Report: August 6, 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
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

SE 2
Required and
optional
assessments

Student
Records
The educational assessment and the
assessment by a teacher are
completed and documented in the
student records for initial
evaluations and reevaluations.
SE 7
Age of Majority

Student
Records,
Documentation
and
The IEP Teams are discussing the
transfer of parental rights with
students one year prior to their 18th
birthday and documenting who has
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
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 1 of 13
Required Corrective
Action, Timelines for
Implementation,
and Progress Reporting
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

SE 9/18B
Timelines for
provision of
documentation
to parent

Interview
decision-making authority at the age
of majority.
Student
Records
The district adheres to the mandated
timelines for the completion of
assessments and the provision of the
proposed IEP to the parent/guardian.
Student
Records and
Interview
IEP Teams convened within the tenday timeline upon receipt of an
independent educational evaluation,
to review the results of the
evaluation and to review and revise
the current IEP, if necessary and
appropriate.
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

SE 11
Independent
Educational
Evaluations
SE 18A
IEP
Development

Student
Records and
Interview
The majority of the IEPs reviewed
addressed all the elements and were
appropriately completed.
SE 20
Least Restrictive
Environment

Student
Records,
Documentation
and
Interview
IEP Teams consider the least
restrictive program for students and
the accommodations, modifications
and the services needed to maintain
the student in the least restrictive
environment.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 2 of 13
Required Corrective
Action, Timelines for
Implementation,
and Progress Reporting
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

SE 22
Implementation
And availability

Student
Records and
Interview
The district has a process in place to
monitor that IEPs are implemented
upon receipt of parent consent.
SE 29
Communications
in English and
the Primary
Language of the
Home

Student
Records and
Interview
The district demonstrates substantial
compliance with the provision of
translation assistance to parents
through interpreters in the primary
language of the home and through
the translation of the necessary
documentation of the IEPs,
evaluations and progress reports.
SE 32
Parent Advisory
Council
Partial
Interview
The district has attempted to conduct
the annual workshop on student and
parents’ rights and other programs
but has had limited success
regarding parent participation. The
district does involve parents of
children with disabilities on systemwide matters pertaining to the
education and safety of students
with disabilities.
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Partial
Basis of
Determination that
Implementation of
Corrective Action
was Incomplete or
Ineffective or
Basis of Finding of
New Noncompliance
The district currently
has no Parent Advisory
Council in place.
Required Corrective
Action, Timelines for
Implementation,
and Progress Reporting
The district must develop an
action plan regarding the steps
to take to re-establish a Parent
Advisory Council and to
provide ongoing outreach to
parents of children with
disabilities in the planning,
development and evaluation of
the district’s special education
programs.
Submit an action plan by
October 3, 2008.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 3 of 13
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

SE 40
Instructional
Grouping
Requirements
Partial
Documentation
and
Interview
The district has assigned aides to
instructional groupings when the
group size has exceeded the size
requirements.
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
Partial
There are instructional
groupings at the high
school level that exceed
the class size
requirements. In some
classes, aides have been
assigned to classes
exceeding the size
requirements. However,
some of the classes with
one and two aides still
exceed the size
requirements.
The Department
recommends that the
district review the form,
Notification of Increased
Instructional Group
Size, for use when there
is a possibility that the
size of an instructional
grouping will exceed the
required numbers during
the school year. The link
can be found at:
http://www.doe.mass.ed
u/sped/28mr/28m1.doc
The district has indicated that
for the 2008-09 school year, a
process will be put in place by
the high school principal and
the special education
administration to monitor the
instructional groupings
throughout the school year. In
addition, the district indicated
that the high school and
special education
administration are reviewing
the configuration of the special
education content area classes.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 4 of 13
Submit the following:
1. Written procedures for
monitoring the
instructional class size
groupings at the high
school. Indicate the key
personnel responsible for
the monitoring
2. Student roster for the
special education
groupings by block period
for the 2008-09 SY.
Indicate the name of the
teacher and
paraprofessional assigned
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

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
to each block.
Above due by October 3,
2008.
SE 42
Programs for
young children
three and four
years of age

Documentation
and
Interview
The district adheres to the class
requirements in its early childhood
programs.
SE 49
Related Services
Partial
Documentation,
Student
Records and
Interview
IEP Teams consider a student’s need
for counseling services and propose
services when necessary and
appropriate.
Partial
The review of the
service delivery grids at
the high school level
demonstrated that IEP
Teams are not always
indicating the specific
frequency and duration
of the proposed
counseling services and
the specific related
service provider
certified to provide the
counseling services.
The district must provide a
review to IEP Teams at the
high school regarding the
appropriate completion of the
service delivery grid when
proposing counseling services.
In addition, provide a
description of the monitoring
process in place to track the
appropriate completion of the
service delivery grids,
including the key personnel
responsible for the monitoring.
Submit the agenda and signed
attendance from the review
and the description of the
monitoring process by
October 3, 2008.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 5 of 13
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
Documentation
and
Interview
The documentation showed that the
majority of the special education
teachers are appropriately certified
or have an approved waiver. For
those teachers, who are unable to be
to obtain a waiver or be
appropriately certified in special
education, the district has taken
appropriate steps to reassign the
teachers being re-hired for the 200809 SY.

SE 51
Appropriate
Certifications for
Special
Education
Teachers

SE 53
Use of paraprofessionals

Documentation
and
I Interview
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
The district is using
paraprofessionals to implement the
instruction under the supervision of
certified or licensed special
education teacher or related service
provider.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 6 of 13
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
Criterion
Implemented

SE 3
Special
requirements
for
determination
of specific
learning
disability
Partial
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
Student
Records
The IEP Teams are aware of the
requirements regarding the
determination of students eligible
for services based upon a specific
learning disability. Observations
are conducted and documented.
Partial
The IEP Team’s written
determination was not
completed and documented for
every student who was
determined eligible with a
specific learning disability.
The district must provide
special education staff with a
review of the regulations and
the requirements regarding the
completion of the written
determination of a specific
learning disability for all
students determined eligible
through an initial evaluation or
re-evaluation.
Submit the following:
1. Evidence of a review
conducted with special
education staff. Include the
agenda and signed
attendance sheet.
2. Written procedures for
monitoring the completion
and documentation of the
written determination
statement. Indicate the
personnel responsible for
the monitoring.
Above due by October 3, 2008
SE 6 ##1 - 3
Determination
Partial
Student
Records and
The review of students’ IEPs
showed that the vision statements
Partial
The Transition Planning forms
do not always provide
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 7 of 13
The district must review with
regular and special education
Criterion
Number
and
Topic
Criterion
Implemented

of Transition
Services
Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Interview
were completed with student input
and that the IEP Teams did discuss
the student’s post-secondary goals.
Students were invited and
participated in IEP meetings.
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
information specific to the
individual student’s action plan
regarding acquisition of skills,
consideration of courses and
the student’s post-secondary
goals. In addition, the forms
are not always completed
annually for every student.
The Department notes that the
students’ IEPs contained
information specific to the
student’s post-secondary goals
but this information was not
always reflected and linked
into the student’s action on the
Transition Planning Form.
staff at the high school level, the
documenting of the IEP Team’s
discussion of all elements on the
mandated Transition Planning
form and the updating of the
above form on an annual basis.
Submit the following:
1. Evidence of a review
conducted with regular and
special education staff
regarding the completion of
a Transition Planning form.
Include the agenda and
signed attendance sheet.
2. Written procedures for
monitoring the completion
and documentation of the
IEP Team’s discussion on
the Transition Planning
form. Indicate the
personnel responsible for
the monitoring.
Above due by October 3,
2008.
SE 8
IEP Team
composition
and attendance

Documentation,
Student
Records and
Interview
IEP Teams include the required
Team participants for annuals,
initial evaluation and re-evaluation
meetings.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 8 of 13
Criterion
Number
and
Topic
Criterion
Implemented

SE 12
Frequency of
re-evaluation

SE 13
Progress
Reports and
content
Partial
Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Student
Records
The district conducts re-evaluation
meetings consistent with the federal
requirement and implements
re-evaluation procedures when a
student is suspected of no longer
being eligible for special education
and/or related services.
Student
Records and
Interview
The district provides the
parents/guardians with progress
reports in accordance with the
report card cycle. IEP progress
reports responded to the annual IEP
goals.
Criterion
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented or
Not Implemented
Partial
The student records did not
include a summary of
academic achievement and
functional performance for
students who have graduated
or have exceeded the age of
eligibility.
Required Corrective
Action, Timelines for
Implementation, and
Progress Reporting
The district must conduct
training with special education
personnel at the high school
who are responsible for the
completion of the summary of
academic achievement and
functional performance.
Submit evidence of training
with the above high school
personnel regarding the
requirement to provide the
above summary and the
procedures for the appropriate
completion of the summary.
Include the agenda, signed
attendance sheet and the
summary form to be used.
Above due by October 3, 2008
SE 14
Review and
revision of
IEPs

Student
Records and
Interview
The district conducts annual
reviews on or before the
anniversary date of the IEP for
students. IEP Amendments are
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 9 of 13
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
used to make changes to students’
IEPs in between annual IEP
meetings.
SE 25B
Resolution of
disputes

Student
Records and
Interview
The district conducted resolution
meetings and developed
agreements to resolve disputes
during the 2007-08 school year,
upon receipt of an official hearing
request.
SE 33
Involvement in
the General
Curriculum

Student
Records
IEP Teams consider and document
participation in the general
curriculum. The district is
committed to full inclusion and
integration of students with
disabilities in the full range of
academic, nonacademic and
extracurricular courses and
offerings.
SE 39A

Student
Records
The district adheres to the required
procedures to provide services to
eligible students enrolled in private
schools at private expense.
Procedures
for services to
eligible
private school
students
whose
parents
reside in the
district
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 10 of 13
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 39B
Procedures for
services to
eligible
students in
private schools
in the district
whose parents
reside out of
state

Documentation
and
Interview
The district currently does not have
eligible students in private schools
whose parents reside out of state.
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days
Partial
Student
Records,
Documentation
and
Interview
The district has policy and
procedures in the student
handbooks. Manifestation
determination meetings are
conducted for students whose
suspensions have exceeded 10
days.
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 review of student records
showed that Teams are not
always documenting the
suspensions and the written
determination of the Team
based upon the review of
information and the suspension
incidents.
The district must review with
middle and high school staff the
information to document
regarding the suspension
incidents and the Team’s
written determination for
manifestation determination
meetings.
Submit evidence of training
with middle and high school
personnel regarding the
documenting of the suspensions
and the written determination
for manifestation determination
meetings.
Include the agenda, signed
attendance sheet and the
materials disseminated.
Above due by October 3, 2008
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 11 of 13
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
SE 52
Appropriate
certifications/
licenses or
other
credentials –
related service
providers

Documentation
and
Interview
The related service personnel and
interpreters used by the district
were appropriately certified and
licensed.
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
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
ELE 11
Equal Access to
Academic
Programs and
Services
Partial
Student
Records,
Documentation
Review and
Interview
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
Requirements
Partial
The review of student
records indicated that not all
written communications,
notices and reports are
translated into the student’s
home language.
Submit the following:
1. Procedures regarding the
documentation and provision
of translation assistance to
parents/guardians. Include the
key personnel responsible for
the implementation, oversight
LEP students are fully included in
the general curriculum and
participate in all the academic
programs. Appropriate procedures
are implemented to consider
students for Title I, special
education and other remedial
support services.
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 12 of 13
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
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
.
2.
3.
and monitoring of the
provision of translation
assistance.
Evidence of a review of the
above procedures with
building administrators
guidance and all teaching
personnel at the beginning of
the 2008-09 school year.
List of students who require
translation assistance for the
2008-09 SY. Indicate the
home language of the student
and the academic areas where
the student will need
language supports, including
career and technical education
programs, other non-core
regular education classes,
extracurricular classes and
academic counseling.
Above due by October 3, 2008.
Mid-cycle Report Format 2008.doc
Rev. 11/8/07
Gloucester Public Schools Coordinated Program Review Mid-cycle Report
August 6, 2008
Page 13 of 13