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
Dr. Joseph Connors
Grafton Public School District
30 Providence Road
Grafton, MA 01519
Re: Mid-cycle Coordinated Program Review Report
Dear Dr. Connors:
Enclosed is the Department of 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 by the Department to address findings of noncompliance
included in the Grafton Public School District’s Coordinated Program Review Report issued on July 25,
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's self-assessment in the area of English learner education (ELE). (In the remainder of this letter,
please read “district” as meaning “school district.”) 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 Dowling-Grant 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 certain noncompliance issues,
others were partially corrected or not addressed at all, or the Department’s onsite team identified new
issues of noncompliance, either noncompliance with special education criteria added or substantially
changed in response to IDEA 2004, noncompliance with ELE criteria, or other new noncompliance.
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 action for
the district that must be implemented without delay. You will find these requirements for corrective
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 1 of 19
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 August 17, 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 781-338-3756, or my supervisor George Haile at 781- 338- 3780.
Sincerely,
Christina Gentile, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Nancy Varello, Grafton School Committee Chairperson
Donna Dias, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 2 of 19
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Grafton Public School District
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): March 17-21, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: September 30, 2003
Dates of Corrective Action Plan Progress Reports: July 27, 2004; March 14, 2005; December 23, 2005
Dates of this Mid-cycle Review Onsite Visit: May 2-4, 2006
Date of this Report: July 24, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Requirements)
Approved
Corrective
Action
Determined
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
Education
Criteria
Originally
Cited in CPR
Report
and Monitored
in Mid-cycle
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 3 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Implemented
and Effective
Requirements)

SE 9/9A
Eligibility
Determination
Partial
Interviews
Documents
Student
records
SE 15
Outreach by the
School District
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Interviews
Documents
The district has a procedure in
place regarding the conducting
of evaluations, convening IEP
Team meetings, and providing a
proposed IEP and placement
within the mandated timelines.
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
Student record review
indicated that the district does
not consistently meet the
mandated 30-day and 45-day
timelines for completing
initial evaluations, convening
the IEP team, and providing
the proposed IEP and
placement to the
parent/guardian.
The district sends a letter to the
parents of all 2.5-4.5 year olds,
and to daycare, nursery schools,
and public agencies, in order to
identify children in need of
special education services.
Additionally, the district posts
information on the district’s
website, on local cable
television, and in local
newspapers. The district also
sends letters to private schools
and collaboratives in the area.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 4 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Submit the results of a review
of student records from the
elementary, middle, and high
schools regarding the
completion of initial eligibility
determinations (indicate the
number of records reviewed,
the number of records where
timelines were met, and
indicate any further steps taken
by the district to address
adherence to the timelines for
initial eligibility) by
December 18, 2006.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Implemented
and Effective
Requirements)

SE 17
Initiation of
Services at Age
Three
Partial
Student
records
Interviews
Documents
SE 18A
IEP
development
and content
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Partial
Student
records
Interviews
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 has a policy in
place for ensuring that services
commence at age 3. The district
also participates in transition
planning conferences with the
referring agency and the parent.
Upon receipt of parental
consent, the district provides an
evaluation, holds a Team
meeting, develops an IEP and
determines placement for
children transitioning from
Early Intervention programs.
Partial
The district should ensure that
records of initial evaluations
include documentation of an
observation. Based on a
review of student records, the
district does not document
observations of children’s
interactions in their natural
environment or early
intervention program.
The district regularly drafts
IEPs prior to Team meetings.
The district ensures that IEP
teams fully discuss all elements
of draft IEPs during the Team
meetings. IEPs are written in
language that is generally
understandable.
Partial
Student records indicated that
IEPs do not consistently
contain individualized
measurable goals. Some IEPs
contain general goals that all
students are expected to meet,
such as obtaining passing
grades.
IEP nonparticipation
justification statements often
indicate that the student needs
pull-out services but not why.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 5 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Submit the results of a review
of student records for children
who have been assessed this
calendar year to determine
eligibility for services at age 3,
regarding the completion and
documentation of an
observation (indicate the
number of records reviewed,
the number of records where
observations were conducted,
and indicate any further steps
taken by the district to ensure
that observations are conducted
and documented in student
records) by December 18,
2006.
Submit the agenda and signed
attendance sheets from staff
training regarding the
development of measurable
annual goals and completion of
the nonparticipation
justification statement.
Submit the results of an
administrative review of
student records and IEPs from
the elementary, middle and
high schools.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Requirements)
Approved
Corrective
Action
Determined
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
Additionally, district records
do not always contain copies
of IEPs signed by the district,
and sometimes IEPs are
missing entirely from student
records. IEPs are not always
revised and updated from year
to year to reflect student
progress and needs.
Indicate the number of student
records reviewed, the number
of records with missing or
unsigned IEPs, the number of
IEPs with annual measurable
goals, the number of IEPs with
detailed nonparticipation
justifications, and the number
of records where IEPs were not
updated annually to reflect
student progress and needs.
Include a narrative addressing
further action by the district to
address any continuing
problem areas.
Above due December 18,
2006.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 6 of 19
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

SE 28
Parent Provided
IEP or Notice
of No
Eligibility
Together with
Notification of
Procedural
Safeguards and
Parent’s Rights
Partial
SE 29/MOA 7
Communications are in
English and
Primary
Language of the
Home
Method(s)
of
Documents
Student
records
Interviews

Documents
Interviews
The district generally provides
parents with the proposed IEP
and placement, or a finding of
no eligibility, within the
required timelines. The district
also provides the Notice of
Procedural Safeguards.
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
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
N-1 forms are not sufficiently
complete, and in some cases,
do not accompany IEPs at all.
Submit the agendas, handout
material and signed attendance
sheets from staff training
regarding the completion of
N1s.
Not all questions on the N1
are included on the completed
form or answered
appropriately or at all, and
sometimes N1s are undated.
Grafton indicated that no
families have indicated a need
for translation assistance.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 7 of 19
Submit the results of a review
of student records from the
elementary, middle, and high
schools regarding the
completion of N-1 forms
(indicate the number of records
reviewed, the number of
records where N1s were
missing, the number of records
where N1s were not
sufficiently completed, and
indicate any further steps taken
by the district to address
completion of N1s)
Above due by December 18,
2006.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

SE 49
Related
Services
Partial
Documents
Student
Records
Interviews
The district currently provides a
number of related services,
including speech- language
therapy; counseling and
psychological services; physical
therapy; occupational therapy;
orientation and mobility
therapy; school nurse services;
and parent counseling and
training.
The district has developed a
policy for tracking missed
sessions, informing parents of
missed sessions, and making up
missed sessions of services.
The district provided tracking
sheets indicating the method
used to make up missed
services.
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
Interviews indicated that
service providers are unclear
on what the system-wide
procedure is when services are
missed. Because of staffing
and scheduling concerns, it is
often difficult to make
services up or to find
replacement service providers,
especially for speech language
pathologists.
Documentation and
interviews indicated that
many missed sessions are due
to IEP meetings.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 8 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Submit the following by
December 18, 2006:
 Evidence that the district’s
procedure for making up
missed services has been
reviewed with all Team
chairpersons and service
providers.
 Tracking forms for related
service providers for
September – December of
2006.
 Description of the steps
taken by the district to
address patterns of missed
services and to address the
reasons for missed services.
 Schedules for related service
providers that show blocks
set aside for testing, service
delivery, IEP Team
meetings, and report writing.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Requirements)
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and 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
Review of student records
revealed that students’
IEPs do not always
include transition goals
and transition services.
Additionally, students’
vocational goals are not
consistently measurable.
See SE 18A regarding the
inclusion of measurable goals.
Basis of Determination
Required Corrective Action,
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 6
Determination
of Transition
Services
Partial
Interviews
Documents
Student
Records
Criterion
Approved
Method(s)
The district has in place the
“Pathways” and “Directions”
programs for special education
students 14-18 years and 18-22
years, respectively. The
programs emphasize vocational
training and job placement.
Based on documentation and
student records, the district
incorporates transition goals and
services into IEPs beginning at
age 15, for most students.
Additionally, the district ensures
that the vision statement is
based on student preferences
and interests. 688 referrals are
made when appropriate. Team
Chairpersons have begun to use
the Transition Planning Chart.
Students are participating in on
and off-campus job placements.
Basis of Determination that
Partial
Corrective
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 9 of 19
Submit the results of an
administrative review of IEPs
regarding the inclusion and
measurability of transition
goals and services in students’
IEPs (include the number of
IEPs reviewed, the number of
IEPs with transition goals
and/or services and the number
of IEPs with vocational goals
that are not measurable, and
indicate any further steps taken
by the district to address the
lack of transition planning and
goals in students’ IEPs) by
December 18, 2006.
Number
and
Topic
(Refer to full
text of 20052006 CPR
Corrective
Action
Determined
of
Verification
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

SE 8
IEP Team
Composition
and Attendance

Student
Records
Documents
Action Not
Implemented
or Not
Effective Or
New Issues
Identified

that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
The district has a local
monitoring policy in place
addressing IEP Team
composition and attendance.
The district provided a list of
individuals authorized to
commit the district’s resources.
Student records indicated that
the district ensures that all
required members of the Team
are present for IEP meetings.
At the high school level,
students age fourteen and older
and adult human service
agencies, when appropriate, are
invited to Team meetings.
SE 12
Frequency of
Re-evaluation

Student
records
The district regularly adheres to
the mandated timelines for
conducting re-evaluations.
Interviews
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 10 of 19
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

SE 13
Progress
Reports and
content
Partial
Interviews
Student
Records
Progress reports are provided to
parents four times a year, in
accordance with the report card
cycle. In most cases, progress
reports address all goals and
whether the student is making
sufficient progress to meet the
goal in question.
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
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Student record review
indicated that IEP Teams
do not always reconcene
when a student is not
making progress.
Interviews indicated that
team chairpersons and
special education liaisons
are unclear regarding their
individual roles and
responsibilities for
monitoring student
progress, both with
respect to IEP goals and
progress in the general
education classroom,
especially at the high
school level.
Additionally, there is no
mechanism for reviewing
progress reports before
they are sent to parents.
Submit a revised procedure for
tracking and monitoring
student progress. Include how
the district will ensure that IEP
Teams meet when a student is
not making progress; the key
personnel who are responsible
for monitoring students’
general progress; and the key
personnel who are responsible
for reviewing progress reports
before they are sent out.
Also submit an administrative
review of progress reports
written at the high school.
Include how many progress
reports were reviewed, how
many indicated no progress,
and in how many cases there
was a follow-up IEP Team
meeting to address the lack of
progress.
Submit the above by
December 18, 2006.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 11 of 19
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

SE 14
Review and
Revision of
IEPs

Student
Records
The district reviews IEPs at
least annually and uses
amendments appropriately.
The district submitted its
“September 2005 revised
procedures for immediate
delivery of IEP.”
SE 25B
Resolution of
disputes

Documents
Documentation submitted by the
district indicates that the district
has not yet needed to convene a
resolution session.
SE 30
Notice of
Procedural
Safeguards

Interviews
Documents
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 sends out the Notice
of Procedural Safeguards with
each annual IEP, the Evaluation
Consent Form, and no later than
the date on which the district
decides to take disciplinary
action that results in a student’s
change of placement.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 12 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
Approved
Corrective
Action
Determined
Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days

Documents
Student
Records
Interviews
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 conducts
manifestation determinations
before students’ 10th day of
suspension. The district
submitted a description of the
interim alternative educational
settings used by the district.
The district submitted
handbooks for the Elementary
School, Middle School, and
High School, all of which
contained disciplinary
procedures for students with
special needs.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 13 of 19
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
Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Implemented
and 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
Civil Rights
(MOA) and
Other General
Education
Requirements
MOA 1
Identification of
LEP Students
Partial
Student
Records
See ELE 1 & 3.
Partial
See ELE 5.
Partial
Documents
Interviews
MOA 2
Program
Modifications
and Support
Services for
LEP Students
Partial
MOA 10A
Student
Handbooks and
codes of
conduct
Partial
Criterion
Student
Records
Documents
Interviews
Approved
Documents
Method(s)
The district submitted student
handbooks for the Elementary
School, Middle School, and
High School. All handbooks
contain a code of conduct that
addresses due process
procedures and discipline
procedures for special education
students. Additionally, all
handbooks contain a
nondiscrimination policy and
harassment policy.
Basis of Determination that
Partial
The harassment/grievance
policy does not include
protection for religion.
The policy also does not
include timelines for a
written response.
Identify specific timelines for
written responses to grievances
and evidence of
communication of the same to
staff and parents. Submit an
updated harassment/grievance
policy that includes all required
elements.
Submit the above by
December 18, 2006.
Corrective
Basis of Determination
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 14 of 19
Required Corrective Action,
Number
and
Topic
(Refer to full
text of 20052006 CPR
Corrective
Action
Determined
of
Verification
Corrective Action was
Implemented and has been
Effective
Implemented
and Effective
Requirements)

MOA 11A
Designation of
liaison/
coordinator(s)
Partial
Documents
Partial
Documents
See MOA 10A and 11A.
MOA 21
Staff training
regarding civil
rights
responsibilities

Documents
The district submitted training
material and attendance sheets
for staff training on civil rights
responsibilities, specifically
harassment.
MOA 25
Institutional
self-evaluation

MOA 12A
Annual and
continuous
notification of
nondiscrimination and
coordinators
The district has designated
individuals to serve as Title VI
Coordinator, Title IX
Coordinator, and
Harassment/Grievance Officer.
The Middle School handbook
includes a policy for homeless
students.
Action Not
Implemented
or Not
Effective Or
New Issues
Identified

that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Partial
The High School and
Elementary School
handbooks do not include
a homeless policy.
Additionally, there is no
identification of a
Homeless Coordinator.
Partial
Apart from handbooks,
the district did not submit
documentation pertaining
to this criterion, such as
copies of employment
applications.
The district submitted a Special
Education Evaluation from the
2004-2005 school year. The
district’s Evaluation was based
on a survey consisting of 21
questions, to which 137 parents
responded. Additionally, the
district submitted the timeline
for the School Committee’s
review of policies.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 15 of 19
Timelines for
Implementation,
and Progress Reporting
Submit an updated homeless
policy to be included in the
High School and Elementary
School handbooks. Include a
designation of the Homeless
Coordinator.
Submit the above by
December 18, 2006.
Submit documentation,
including employment
applications, demonstrating
compliance with this criterion
by December 18, 2006.
Submit documentation of a
district review, for all staff,
on grievance procedures and
staff responsibilities as a
mandated reporter by
December 18, 2006.
Grafton Public 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
ELE 2
MCAS
Participation
ELE 3
Initial
Identification
Comments Based on the Department’s Review of Local ELE
Self-Assessment
Required Corrective Action, Timelines for Implementation, and
Progress Reporting
The district annually assesses the English proficiency for all LEP
students by administering the MEPA and MELA-O.
Limited English Proficient (“LEP”) students participate in MCAS,
and have access to bilingual dictionaries when necessary.
It is unclear whether the district has written guidelines that include
clear criteria to determine whether students are or are not LEP. The
district administers a Home Language Survey to incoming students;
however, the survey is not available in parents’ home languages. The
district does not have effective identification procedures, as
interviews indicated that not all LEP students are identified.
Interviews and student records indicated that students are sometimes
determined to be LEP solely based on the results of the Home
Language Survey without any assessments. Additionally, student
records and documents (“Identification Process Overview”) reflected
that the MELA-O is sometimes used to identify students as LEP, and
that students are not always initially assessed in the four areas of
reading, writing, speaking and listening.
Several of the district’s documents, including “Teaching ESL
Students in Sheltered English Immersion Classrooms in the Grafton
Public Schools,” inaccurately describe the identification process for
LEP students.
Submit the following documentation by December 18, 2006.
 Samples of Home Language Surveys that have been translated into the
major languages represented in the district.
 Revised procedures that describe the identification and assessment
process for LEP students, including the criteria for making a
determination of LEP status, and what assessments will be completed for
identification purposes.
 List of newly enrolled students whose first language is not English; the
results of their Home Language Survey; their LEP status; and what
assessments were performed, if any.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 16 of 19
ELE Criterion
Number
and
Topic
ELE 4
Waiver
Procedures
Comments Based on the Department’s Review of Local ELE
Self-Assessment
Required Corrective Action, Timelines for Implementation, and
Progress Reporting
The district provided appropriate waiver application forms for
students under 10 years of age and students over 10 years of age.
ELE 5
Program
Placement and
Structure
LEP students are placed in general education classrooms rather than
Sheltered English Immersion (“SEI”) classrooms. Additionally, not
all beginning LEP students receive daily English Language
Development (“ELD”), and high school LEP students’ schedules do
not reflect any ELD instruction. Not all ELD/ESL tutors/teachers are
appropriately certified. Interviews indicated that rather than
receiving instruction based on the Massachusetts English Language
Proficiency Benchmarks and Outcomes (“ELPBO”), many LEP
students are being re-taught classroom material or being assisted with
homework.
ELE 6
Program Exit
and Readiness
The district does not re-designate students from LEP to Formerly
Limited English Proficient (“FLEP”) until the student is deemed
proficient using multiple testing measures; the student is able to
participate independently and meaningfully in the mainstream
education program; and a Guided Decision Plan is established for
monitoring.
Submit the following documentation by December 3, 2006:
 Description of the English language support program in place for
students K-12 for the 2006-07 SY.
 List of LEP students for the 06-07 SY. Indicate the grade level and the
classroom placement of each student, the type and amount of English
language support that the student needs, and the amount of English
Language Development instruction that the student is receiving.
 Name of teachers participating in sheltered English instruction training
for the 06-07 SY.
 List of ELL tutor/teacher(s) and qualification(s), including copy of
current licensure certification and/or waiver.
 Description of how the district is ensuring that students are receiving
instruction based on ELPBO.
ELE 7
Parent
Involvement
Apart from copies of translated handbooks and ELL Parent
Handbooks, the district did not submit documentation regarding
parent involvement. It is unclear whether the district has developed a
process for including parents of LEP students in matters pertaining to
the students’ educations.
Submit the following documentation by December 18, 2006:
 Description of the opportunities for parent involvement and methods for
parent-teacher communication.
 Copies of translated notices, announcements, and report cards.
ELE 8
Declining Entry
to a Program
The district has an “opt out” procedure in place. The district
indicated that it continues to monitor students’ educational progress.
However, based on interviews, the district does not offer supports to
students who have declined to enroll in the program.
Submit a description of the supports available to students who have
declined entry into the program by December 18, 2006.
ELE 9
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 17 of 19
ELE Criterion
Number
and
Topic
Instructional
Grouping
ELE 10
Parental
Notification
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 and
Fluency
Requirements
Comments Based on the Department’s Review of Local ELE
Self-Assessment
Required Corrective Action, Timelines for Implementation, and
Progress Reporting
See ELE 5.
The district provided a Parent Notification of Limited English
Proficiency letter. The letter does not contain all of the required
elements. Additionally, the district’s Guided Decision Form does not
meet the requirements under this standard. The notification letter is
not provided in parents’ native language.
Submit the following documentation by December 18, 2006:
Interviews indicated that academic support is only available to
students who are on IEPs.
Provide a description of what regular education academic support is
available to LEP students by December 18, 2006.
 Updated parent letter that contains all required elements.
 Samples of translated parent notification letters.
Documentation submitted by the district indicated that LEP students
have equal access to nonacademic programs and extracurricular
activities.
See ELE 6.
By continuing to train teachers during the summer of 2006, the
district plans to have a total of twelve teachers trained in Categories 2
and 3 by June of 2007. Currently, ELE teachers do not have the
requisite amount of training.
Refer to the corrective action and progress reporting ordered under ELE 5.
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 18 of 19
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
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
See ELE 14. The district has a professional development plan based
on a Professional Development Needs Assessment.
Based on interviews, ESL tutors/teachers do not have sufficient space
that is comparable to instructional areas provided to other students.
ESL tutors/teachers often work with students in hallways, libraries,
or in spaces shared with special education teachers.
Provide a list of the locations where ESL tutors/teachers provide services
to students and indicate what steps the district has taken to address any
insufficient space by December 18, 2006.
The district reports the required information to the Department
annually. Additionally, the district conducts periodic evaluations of
its ELE program.
LEP student records did not include all required components,
including a log of access; parent notification letters; and MELA-O,
MEPA, and MCAS scores.
Mid-cycle Report Format 2006.doc
Submit the following documentation by December 18, 2006:
 Documentation tracking form for required elements of ELE student
records and the name of the personnel responsible for monitoring the
documenting of the required paperwork.
 Results of an administrative review regarding the documentation of the
required elements in the LEP student records for the 06-07 SY. Indicate
what steps were taken to address any records identified with incomplete
documentation.
Rev. 5/22/06
Grafton Public School District Coordinated Program Review Mid-cycle Report
July 24, 2006
Page 19 of 19