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 September 6, 2006 Joseph Ruscio, Superintendent Greenfield Public Schools 141 Davis Street Greenfield, Massachusetts 01301 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Ruscio: 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 Greenfield Public Schools Coordinated Program Review Report issued on June 13, 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. 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. 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 September 19, 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 David Lanoie, School Committee Chairperson Pam DeGregorio, Interim Director of Student Services Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Greenfield Public Schools ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION Date of Coordinated Program Review (CPR): March 10, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: October 6, 2003 Dates of Corrective Action Plan Progress Reports: December 10, 2003 Dates of this Mid-cycle Review Onsite Visit: June 7 – 9, 2006 Date of this Report: September 6, 2006 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 1 of 30 Criterion Number and Topic (Refer to full text of 2005-2006 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 Partially Implemented During the onsite visit it was determined that the district was not always completing and filing in student records the educational assessments as required in section 1c Required Corrective Action, Timelines for Implementation, and Progress Reporting Special Education Criteria Originally Cited in CPR Report and Monitored in Mid-cycle SE 1 Assessments are appropriately selected and interpreted for students referred for evaluation Yes Student record review and documentation The district uses a multitude of assessments that are conducted and interpreted by qualified individuals. SE 2 Required and optional assessments Partially Implemented Student record review Student record review indicated that some, but not all, assessments are conducted and filed in student records. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 2 of 30 The district 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 Criterion Number and Topic (Refer to full text of 2005-2006 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 of this criterion. Required Corrective Action, Timelines for Implementation, and Progress Reporting all required elements, and are filed in student records. By December 1, 2006 the district is to submit to the Department an agenda and sign-in sheet verifying this training. By December 1, 2006 the district must also submit to the Department a sample of 20 Educational Assessment reports from initial evaluations and reevaluations. SE 3 Special requirements for determination of specific learning disabilities Statutory requirements for the determination of specific learning disabilities have been revised under the recently reauthorized IDEA 2004. Therefore, until final Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 3 of 30 Criterion Number and Topic (Refer to full text of 2005-2006 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 implementing regulations have been adopted, the Department is not making findings related to school district practices under this criterion. SE 4 Reports of assessment results Yes Student record review and interviews SE 5 Participation in general State and 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. Interviews indicate that special education students who receive accommodations during Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 4 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 CPR requirements) Approved Corrective Action Determined to be Implemented and Effective Method(s) of Verification SE 9 Eligibility determination: Timelines for evaluation, provision of IEP and/or identification of other needed instructional programs 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 Partially Implemented See SE 12. Required Corrective Action, Timelines for Implementation, and Progress Reporting instructional times are provided with MCAS testing accommodations. district-wide assessment programs SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority Basis of Determination that Corrective Action was Implemented and has been Effective Yes 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. Partially Implemented Documentation and student record review The district has developed a tracking system to accurately oversee and adhere to regulated timelines; however, not all regulated timelines are being met. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 5 of 30 See SE 12. Criterion Number and Topic (Refer to full text of 2005-2006 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 SE 10 End of school year evaluations Yes Student record review and interviews The district is completing evaluations before the close of the school year when the evaluations are received within 30-45 school days of the end of the school year. SE 18A IEP development and content Yes Student record review and interviews Yes Student record review, documentation, and interviews Student record review and interviews indicate 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 DOE IEP format. The district implements the required procedures to determine placement at initial/reevaluations and annual review meetings. SE 18B Determination of placement; provision of IEP to parent 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 Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 6 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 Interviews 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 consent, conducts the evaluation, and holds a Team meeting within 8 weeks of parent consent. SE 19 Extended evaluation Yes SE 20 Least restrictive program selected Yes Student record review, documentation, and interviews 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 The district considers the least restrictive environment and opportunities for inclusion for students through Team Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 7 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 Effectively Implemented Record review indicated that notice forms (N1 and N2) were not consistently completed. On some forms, page 2 did not include the required guiding questions that must be answered. On other forms, the answers to these guiding questions were not complete, The district should provide training for the staff members whose responsibility it is for completing notice forms. Evidence of training (agenda, sign-in sheet) will be submitted to the Department no later than December 1, 2006. discussions at IEP meetings. SE 22 IEP implementation and availability SE 24 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the Yes Student record review, documentation, and interviews The 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. Student record review Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 8 of 30 Criterion Number and Topic (Refer to full text of 2005-2006 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 depriving parents of their right to receive adequate notice. provision of FAPE SE 25 Parental consent Yes Student record review SE 27 Content of Team meeting notice to parents Yes Student record review and documentation SE 29 Communications are in English and primary language of home Yes Student record review and documentation Student records reviewed by the onsite Team indicated consent forms were present and signed by the parent or guardian. 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. The Department had no compliance concerns with this criterion. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 9 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 SE 32 Parent advisory council for special education Yes Documentation and interviews SE 33 Involvement in the general curriculum Yes Student record review and interviews 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 The school district has an established Parent Advisory Council that meets the requirements of this criterion. Interviews indicated that the district has developed a curriculum that is based on the Massachusetts Curriculum Frameworks and all students receive instruction based on this curriculum. All staff in the district has been provided with training on the curriculum, and Team meetings always include, at minimum, an individual who is familiar with the curriculum and can discuss appropriate access for the student. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 10 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 SE 34 Continuum of alternative services and placements Yes Documentation, student record review, and Interviews Documentation, record review and interviews indicate that the district has established a wide range of programs and services to meet the individual needs of all students. Appropriately credentialed providers staff all programs. SE 35 Specialized materials and assistive technology Yes Student record review Student records indicate that assistive technology is provided to students when needed. SE 36 IEP implementation, accountability and financial responsibility Yes Documentation Documentation indicated that the district has procedures in place for IEP implementation, accountability, and financial responsibility. 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 Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 11 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 SE 37 Procedures for approved and unapproved outof-district placements Yes Documentation Documentation indicated that the district has a process in place for the oversight of out-of district placements. SE 43 Behavioral interventions Partially Implemented Student records review and documentation The district provided sample behavior intervention plans for students that illustrate the nature and scope of behavioral interventions undertaken by district staff to modify negative student behaviors. SE 44 Procedure for recording suspensions Yes Documentation and staff interviews The district has revised its procedures and tracking methods to appropriately monitor student absences and suspensions. 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 Partially Implemented Although the district implements behavioral intervention plans, the plans were not always included in the student’s IEP. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 12 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting By December 1, 2006 submit to the Department a random sample of 10 IEPs that include behavioral intervention plans. Criterion Number and Topic (Refer to full text of 2005-2006 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 Documentation Student handbooks contain all of the required procedures for suspensions up to 10 days and after 10 days. SE 45 Procedures for suspension up to 10 days and after 10 days: General requirements Yes SE 47 Procedural requirements applied to students not yet determined to be eligible for special education Yes Documentation and interviews The district has developed a procedure to ensure students who have not yet been determined eligible for special education services are afforded procedural protections pending the outcome of an expedited evaluation. SE 48 FAPE (Free, appropriate, public education): Equal Yes Documentation and interviews Information provided by the district indicated that all special education students have equal 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 Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 13 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 opportunity to participate in educational, nonacademic, extracurricular, and ancillary programs, as well as participation in regular education. opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education SE 49 Related services Yes 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 49A Special Transportation Yes Student records and documentation The district adheres to the state regulations and federal requirements Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 14 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 regarding the provision of special transportation to students who require special transport as determined by the IEP Team. SE 50 Responsibilities of the School Principal and Administrator of Special Education Yes Documentation and interviews Documentation and interviews demonstrated that the district’s administrator of special education is meeting all statutory requirements. SE 53 Use of paraprofessionals Yes Documentation and interviews Documentation and interviews indicated that paraprofessionals are appropriately trained and used. SE 54 Partially Documentation The school district offers Partially Documentation and Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 15 of 30 By December 1, 2006 Criterion Number and Topic (Refer to full text of 2005-2006 CPR requirements) Professional development regarding special education SE 56 Special education programs and services are evaluated SE 57 Special education child count 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 Implemented and interviews Yes Documentation and interviews Yes Documentation an extensive array of professional development opportunities for general and special education staff. Corrective Action Determined Not to have been Implemented or Not to have been Effective Or New Issues Identified Implemented Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance interviews indicated that not all transportation providers have received required training. Documentation indicated that the district is engaged in the evaluation of its special education services and programs. The district maintains appropriate procedures to ensure that an accurate child count is provided to the Department. MOA 4 Disproportionality [included in this report if the CPR report included a finding under MOA 4 of noncompliance with respect to Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 16 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting submit to the Department an agenda and sign-in sheet documenting in-service training on special education related topics for transportation providers. Criterion Number and Topic (Refer to full text of 2005-2006 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 racial/ethnic distribution in special ed, special ed placements, or disability categories] Yes Documentation Current data suggests no disproportionate representation of minorities in special education. 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 district is documenting Special Education Criteria created or revised in response to IDEA-2004 SE 6 Determination of Transition Services Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 17 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 Partially Implemented A person who can commit the school district resources is not always present at annual meetings, and the staff is not always clear who has this authority. By December 1, 2006, submit a revised list of the staff in the district that can commit district resources and a description of what this responsibility entails. In addition, submit evidence that this information has been reviewed and discussed with appropriate school personnel. 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 transition related activities on a grid in the student record. SE 8 IEP Team composition and attendance Partially Implemented Student record review, documentation, and Interviews Criterion Number and Topic Criterion Implemented Method(s) of Verification IEP Teams consistently have all required people in attendance at initial and reevaluations. Basis of Determination that Criterion was Implemented (Refer to full text of 2005-2006 CPR requirements) Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 18 of 30 Criterion Number and Topic (Refer to full text of 2005-2006 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 SE 12 Frequency of reevaluation 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 Not Implemented Record review and interviews indicated reevaluations are not always completed within the required timelines. Required Corrective Action, Timelines for Implementation, and Progress Reporting Conduct training for Team chairs on the following topics: The legal requirements mandating that IEPs be developed prior to their expiration date. Procedures to follow when parents do not provide consent to evaluate in a timely manner and the requirement to conduct the three-year reevaluation prior to the IEP expiration date. By December 1, 2006 submit the training agendas and sign-in sheets for the above training topics. By December 1, 2006 Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 19 of 30 Criterion Number and Topic (Refer to full text of 2005-2006 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 submit to the Department a random sample of the IEP documentation from all levels, (E, MS, HS) that indicates compliance with reevaluation timelines. Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Yes Student record review Progress reports are completed with the same frequency as the report card cycle. The district ensures that (Refer to full text of 2005-2006 CPR requirements) SE 13 Progress Reports and content Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 20 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic (Refer to full text of 2005-2006 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 SE 14 Review and revision of IEPs Yes Student records and interviews SE 25B Resolution of disputes Yes Documentation and interviews SE 30 Notice of procedural safeguards SE 46 Procedures for suspension of students with disabilities more than 10 days Yes Student record review and interviews Yes Student record review and interviews 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 IEPs are reviewed on or before the anniversary date of their implementation date to consider the student’s progress and develop a new IEP. The district has put into place procedures and forms for dispute resolution. N1 notices document that the district is providing parents with copies of the Interim Notice of Procedural Safeguards. Procedures have been put in place and staff members were aware of the manifestation determination process and procedures. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 21 of 30 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements See ELE 5 and 9. See ELE 5 and 9. Civil Rights (MOA) and Other General Education Requirements MOA 1 Identification of limited English proficient students Yes Student record review and interviews Documentation indicates the district has well-established procedures for initial identification of LEP students. Yes MOA 2 Program modifications and support services for limited English proficient students MOA 3 Access to a full Yes Documentation and interviews Based on documentation and interviews all students have Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 22 of 30 access to the full range of educational programming at all school levels. range of education programs MOA 7 General information and materials in languages other than English Yes Documentation The district arranges for the translation of notices and documents where appropriate. MOA 9 Promotional, recruitment, and employment practices of prospective employers of students Partially Implemented Documentation The district has created an 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 10A (formerly MOA 17) Student handbooks and codes of conduct Yes Documentation The district has handbooks and codes of conduct for students and staff that meet the requirements of this criterion. MOA 11 Publication of notices of nondiscrimination Yes Documentation All handbooks contain a nondiscrimination policy that is consistent with MGL c. 76, §5 and includes sexual orientation and disability. Partially Implemented During the documentation review, no signed antidiscrimination statements were present. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 23 of 30 To verify that the district is using the antidiscrimination statement, the district will submit 5 signed antidiscrimination statements from prospective employers when recruiting and/or employing students by December 1, 2006. MOA 11A (formerly MOA 12) Grievance procedures Yes Documentation and interviews The district has published grievance procedures for resolving complaints of discrimination and harassment. MOA 13 Availability of information and counseling on general curricular occupational/ vocational opportunities No Documentation and interviews No documentation was provided to the Department for this criterion. MOA 14 Counseling materials and activities free from bias and stereotypes Yes Documentation and interviews The district has a policy statement and uses a form to monitor that counseling and counseling materials, including tests, surveys and college planning packets, are reviewed for bias and stereotypes. Not Implemented The district was unable to document that it is providing the required equal access to the specified information and counseling as required under this criterion. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 24 of 30 The district must provide the required documentation to the Department by December 1, 2006. Specifically, the district must submit: Copy(ies) of course selection booklet(s) Description of counseling activities Description of information dissemination process and methods used to ensure that information is provided to all these groups MOA 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion Yes Documentation The district has a written notice that meets the requirements of this criterion. MOA 17A Use of physical restraint on any student enrolled in a publicly funded education program Yes Documentation and interviews The district provides annual physical restraint training to all district staff. MOA 18A School district employment practices Yes Documentation and interviews Documentation and interviews indicated that the district includes a nondiscrimination statement in recruitment vacancy announcements and job advertisements. MOA 21 Staff training regarding civil rights responsibilities Yes Documentation and interviews The district has conducted all required civil rights training for its staff. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 25 of 30 MOA 23 Comparability of facilities and programs Yes Interviews and observation Interviews and observations at the Green River and the Newton Schools indicated that all special education programs and facilities are equitable. MOA 25 Institutional self-evaluation Yes Interviews The district has in place a comprehensive evaluation process to examine and remedy policies and programs that discriminate or limit educational access. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 26 of 30 Greenfield Public Schools 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 Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting Documentation indicates the district has well-established procedures for annually assessing the English proficiency of students who have been identified as limited English proficient (LEP). The district utilizes trained staff to administer the MEPA that includes the MEPA R/W and MELA-O. Documentation indicates all LEP students participate in MCAS testing scheduled for their respective grades regardless of the program and services they are receiving. For those students in the country less than a year, they are only required to participate in the math and science and technology/engineering tests but may opt to take all MCAS tests scheduled for their grade. Documentation indicates the district has well-established procedures for initial identification of LEP students. None. ELE 4 Waiver Procedures Documentation indicates the district has well-established procedures to notify parents of LEP students of the district’s sheltered English immersion (SEI) program. To date no parent has waived the district’s SEI program. None. ELE 5 Documentation indicates the district’s program placement and The school district must demonstrate that its use of the pullout model is part of a ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification None. None. Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 27 of 30 ELE Criterion Number and Topic Program Placement and Structure Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting full-time language program. Please refer to Department guidance on this topic to be found at: http://www.doe.mass.edu/ell/sei/MEPA_guidelines.pdf. A narrative description of the use of pullout services throughout the district must be submitted to the Department no later than December 1, 2006. ELE 6 Program Exit and Readiness structure meet all requirements under this criterion with the exception of pull-out services continuing at the middle school. Although not prohibited when used in conjunction with a full-time language program, the Department discourages the use of pullout programs in the SEI model since by itself it does not meet the requirements of the law. Documentation indicates the district has well-established procedures to appropriately determine an LEP student’s program readiness and exit level. ELE 7 Parent Involvement Documentation indicates the district has well-established mechanisms in place for including parents/guardians of LEP students in matters pertaining to their children’s education. None ELE 8 Declining Entry to a Program Documentation indicates the district has well-established procedures for parents/guardians of LEP students who choose to decline entry to a district program. None ELE 9 Instructional Grouping The school district is currently in process of ensuring that all ELE classrooms’ curricula are based on the English Language Proficiency Benchmarks and Outcomes. By December 1, 2006, the district must provide a description of its process to ensure that all ELE programs’ curricula meet these requirements including staff training conducted on this topic for district staff. ELE 10 Parental Notification Documentation indicates the district’s annual parental notification letter contains all required elements. The district provides parents of LEP students, report cards and progress reports in the same manner and with the same frequency as general education reporting; however, report cards are not always written in a language understandable to the parent/guardian. The school district must provide assurance to the Department by December 1, 2006 that all report cards are written in a language understandable to the parent/guardian. None Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 28 of 30 ELE Criterion Number and Topic 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 District practices and documentation indicate that all LEP students have equal access to academic programs and services. None District practices and documentation indicate that all LEP students have equal access to non-academic and extracurricular programs. None Documentation indicates the district has well-established procedures to appropriately monitor formerly limited English proficient (FLEP) students. None Documentation indicates the district places LEP students in classrooms with appropriately trained and qualified staff. None Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 29 of 30 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 Documentation indicates the district has implemented a professional development plan that has provided, and continues to provide, high quality training to district staff to ensure the progress of LEP students in developing oral comprehension, speaking, reading, and writing of English, and in meeting academic standards. None Not Rated None Documentation indicates the district conducts periodic evaluations of the effectiveness of its ELE program. None Not Rated None Greenfield Public Schools Coordinated Program Review Mid-cycle Report September 6, 2006 Page 30 of 30