Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148-4096 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 May 15, 2013 Susan Hollins, Superintendent Greenfield Public Schools 141 Davis Street Greenfield, MA 01301 Re: Mid-cycle Report Dear Superintendent Hollins: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based on the onsite visit conducted in your district in February 2013. During the Mid-Cycle Review the Department monitored selected special education criteria to determine your district’s compliance with special education laws and regulations. The review consisted of information gathered from one or more of the following activities: interviews, review of student records, examination of documentation, and classroom observation(s). The Department determined that one or more of the criteria monitored in your district was “Partially Implemented” or “Not Implemented.” In all instances where noncompliance was found, the Department has prescribed corrective action for the district. This corrective action must be implemented 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 submitting progress reports using the enclosed form. Please provide the Department with your written assurance that all of the required corrective action will be implemented by your district within the timelines specified in the report. You must submit your statement of assurance to Darlene Lynch, Director, Program Quality Assurance Services, by May 31, 2013. 1 Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have questions about this letter or the enclosed report, please do not hesitate to contact Marc Oldenburg at 413314-6707 Sincerely, Marc Oldenburg, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services cc: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Michelle Poulin, Supervisor, Program Quality Assurance Services John Lunt, School Committee Chairperson William Bazyk, Local Program Review Coordinator Encs: Mid-cycle Report Mid-cycle Progress Report Form 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT Greenfield Public Schools Dates of the Mid-cycle Review Onsite: February 27, 2013 Date of this Report: May 15, 2013 PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS. Required Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 7 Transfer of parental rights and student participation and consent at age of majority Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Student Record Review Interview Documents Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Student record review, document review and an interview indicate that one year prior to the student reaching age 18 the district sends notice to the student and the parent/guardian of the rights that will transfer from the parent/guardian to the student upon the student’s 18th birthday. The notification provided by the district to the student and parent/guardian explicitly states the rights accorded to Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 1 of 11 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation parents under special education law that will transfer to the student upon his or her 18th birthday. At the age of 18, the school district does implement procedures to obtain consent from the student, the cosigning student/adult, or the designated adult, to continue the special education program. Student Record Review Interview SE 8 IEP Team composition and attendance Documents Student record review, document review and an interview indicate that at all school levels, required members of the Team are in attendance at IEP meetings unless the parent and district agree to use alternative means, such as a video conference or a conference call. Alternately, the district and the parent may agree, in writing, that the attendance of a Team member is not necessary because the member´s area of the curriculum or related services is not being modified or discussed. If a required member’s excusal for participation is sought, the parent and the district agree, in writing, that the Team member provides written input into the development of the IEP to the Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 2 of 11 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation parent and the IEP Team prior to the meeting. Student Record Review Documents SE 18A IEP Development and content SE 25 Parental consent Interview Documents Student record review and document review indicate that whenever the IEP Team evaluation indicates a student's disability affects social skills development, or when the student's disability makes him or her vulnerable to bullying, harassment, or teasing, or for students identified with a disability on the autism spectrum, the IEP Team does address the skills and proficiencies needed for the student to avoid and respond to bullying, harassment, or teasing and documents these considerations on the Notice of Proposed School District Action and supports within the IEP. At the time of the review, no parent had revoked consent for a student's special education services during the period of one year prior to the midcycle review. Document review indicates that the district has procedures for when a parent/guardian revokes consent for special education Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 3 of 11 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation services in writing, which includes the district‘s need to act promptly to provide written notice to the parent or guardian of the district´s proposal to discontinue services, as well as to provide the parent with information on how they may obtain a copy of their right to procedural safeguards. The district’s procedures also include notice a reasonable time before the district intends to discontinue the services and that the district may not use mediation or request a due process hearing to obtain agreement or a ruling requiring the continuation of services, consistent with federal regulation. Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 4 of 11 (b) Progress Report Due Date(s) and Required Elements Additional Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Criterion Implemented SE 9 Timeline for determination of eligibility and provision of documentation to parent SE 12 Frequency of re-evaluation Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Student Record Review Student record review and document review indicate that the district determines eligibility and provides the IEP to parents within 45 school working days after receipt of parental written consent. Documents Student Record Review Interview Documents SE 13 Progress Reports and Student Record Review Documents If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Student record review, document review and an interview indicate that the district conducts re-evaluations every three years with the consent of the parent. Student record review and document review indicate that parents receive reports on their student's progress toward reaching his or her IEP goals at Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 5 of 11 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation content SE 14 Review and revision of IEPs Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements least as often as parents are informed of the progress of non-disabled students. PI Student Record Review Documents Student record review and document review indicate that the district does not consistently convene a Team meeting at least annually, on or before the anniversary date of the IEP, to consider the student’s progress and to review, revise, or develop a new IEP or refer the student for a re-evaluation, as appropriate. Conduct an analysis of a cross section of annual reviews across all grade levels, from November 2012 to March 2013, to determine why annual reviews are not routinely being held on, or before, the anniversary date of the last accepted IEP. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible to ensure that annual reviews are consistently held on or before the anniversary date of the IEP. Conduct a second review of a sample of student records for annual reviews conducted subsequent to the implementation of all corrective actions, to verify that the district is meeting timelines for annual reviews. Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 6 of 11 Submit the results of the district’s analysis. Include a description of the root cause(s) of the noncompliance, a description of the steps the district will take to correct the root cause(s), and the district’s proposed timeline for implementation of corrective actions by June 28, 2013. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation *Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 7 of 11 (b) Progress Report Due Date(s) and Required Elements the designated person(s) responsible by June 28, 2013. Submit a report of the results of the second record review. Include the number of records reviewed; the number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the noncompliance by December 6, 2013. Criterion SE 18B Determination of placement; provision of IEP to parent Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation PI Student Record Review Student record review and document review indicate that although parents at the conclusion of the IEP Team meeting are provided with a summary of the proposed IEP, they do not consistently receive the complete IEP and proposed placement within ten school working days. Conduct an analysis of a cross section of student records from all grade levels from November 2012 to March 2013, to determine why parents are not routinely being provided with the proposed IEP and proposed placement within ten school working days after the conclusion of the IEP Team meeting. Documents Develop an internal tracking and oversight system with periodic review by designated person(s) responsible to ensure that parents are routinely being provided with the proposed IEP within the required timelines. Please submit the results of the district’s analysis. Include a description of the root cause(s) of the noncompliance, a description of the steps the district will take to correct the root cause(s), and the district’s proposed timeline for implementation of corrective actions by June 28, 2013. Select a sample of student records from all grade levels whose activity (initial evaluation, annual review, or re-evaluation) occurs after implementation of all corrective actions, to review for compliance with providing parents or guardians with the proposed IEP and proposed placement within ten school working days after the conclusion Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 8 of 11 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation of the IEP meeting. *Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). SE 41 Age span requirements Student Record Review Interview Student record review, interview and document review indicate that the ages of the youngest and oldest child in any instructional grouping Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 9 of 11 (b) Progress Report Due Date(s) and Required Elements responsible by June 28, 2013. Submit a report of the results of the second record review. Include the following: number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and describe the specific action(s) taken by the district to remedy the noncompliance by December 6, 2013. Criterion SE 53 Use of paraprofessionals SE 54 Professional development Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Documents within the district do not differ more than 48 months. Interview Interviews and document review indicate that persons employed as paraprofessionals and assistants do not design instruction for students with disabilities and only implement instruction under the supervision of an appropriately certified or licensed teacher who is proximate and readily available to provide supervision. Documents PI Interview Documents Interview and document review indicate that the district does not ensure that special education and general education staff are trained on state and federal special education requirements and related local special education policies and procedures. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Conduct training for special education and general education staff across all levels on state and federal special education requirements and related local special education policies and procedures. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible to ensure that all required professional development activities are being Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 10 of 11 (b) Progress Report Due Date(s) and Required Elements Please submit to the Department evidence of staff training (agenda, signed and dated attendance sheet with staff role, and training materials) by December 6, 2013. Submit a description of the Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation conducted annually. SE 55 Special education facilities and classrooms Interview Observation The Strides Program has been re-located from Newton School to The Discovery School at Four Corners. The Strides Program is equal in all physical aspects to the average standards of general education facilities and classrooms located in The Discovery School at Four Corners. The new location maximizes the inclusion of students in to the life of the building and provides accessibility in order to implement fully each student’s IEP. Greenfield Public Schools Coordinated Program Review Mid-cycle Report May 15, 2013 Page 11 of 11 (b) Progress Report Due Date(s) and Required Elements district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by December 6, 2013. MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REVIEW School District: Greenfield Public Schools M I D – CY C L E P R O G R E S S R E P O R T Date Prepared: ____________________________________ Prepared by: __________________________________________________________________ (name and title) Criterion: _______________________ Topic: ________________________________________________________________________ For each criterion for which you prepare a progress report, please make a copy of this cover page, fill in the information requested above, and attach a complete description of the corrective action taken and any accompanying documentation. (Description of corrective action for each criterion and any accompanying documentation should include all of the “Progress Report Required Elements” for that criterion in the Mid-cycle Report.) Send the whole set of completed progress reports to: Darlene Lynch, Director Program Quality Assurance Services Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street Malden, MA 02148-4906