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
April 15, 2005
Hanover Public Schools
Mary Ann Jackman
Superintendent of Schools
188 Broadway
Hanover, MA 02339
Re:
Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action
Plan Verification and Special Education Mid-cycle Review
Dear Superintendent Jackman:
Enclosed is the Department's Coordinated Program Review Follow-up Monitoring Report
together with findings regarding your district’s Coordinated Program Review Mid-cycle Review.
This report contains the Department's findings based on the onsite activities conducted in your
school district to verify the implementation status and effectiveness of corrective steps taken in
response to your Coordinated Program Review Report issued on May 28, 2002.
While the Department of Education found certain noncompliance issues to be resolved, others
were partially corrected or new issues were identified by the Department’s onsite team. As the
Department previously informed you, in cases where a district fails to fully and effectively
implement a Corrective Action Plan, which was proposed by your district and approved by the
Department, the Department must then prepare a Corrective Action Plan for the district, which
must be implemented without further delay. You will find these requirements for corrective
action and further progress reporting included in the attached report together with any steps that
must be taken by the district to fully implement new special education requirements. Please
provide the Department with your written assurance that 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 Department's Onsite Chairperson by May
2, 2005.
Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated.
Should you require additional clarification of information included in our report, please do not
hesitate to contact the Onsite Team Chairperson at 781-338-3714.
Sincerely,
Nancy Hicks, Coordinated Program Review Follow-up Chairperson
Program Quality Assurance Services
John D. Stager, Administrator
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Suzanne Brady, School Committee Chairperson
James Shillinglaw, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
Hanover Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on October 2, 2002
Progress Reports Submitted on January 29 and May 28, 2003
Onsite Visit Conducted on February 8 and 9, 2005
Date of this Report April 15, 2005
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Special
Education
Requirements
SE 3
Special
requirements
for
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation


Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Student
records,
documenta-
The district has a policy that
meets all special requirements.
A form has been developed to
record the Teams confirmation
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
determination
of specific
learning
disabilities
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


tion and
interviews
of the finding but the district
needs to monitor student records
to ensure all parts of the form
are completed and that the form
is used whenever required.
2
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 6
Determination
of transition
services
(Emphasis on
practices in
determining
needed
transition
planning and
services and
consideration
of courses of
study related
to needed
transition)
SE 13
Progress
Reports and
content
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Partial
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
The record review
indicated that for students
age 16 and older the
course of study and goals
and objectives did not
always promote
movement to post
secondary objectives.
The district must provide
training to staff members on
the transitional elements of
the IEP including the age
related sections of the PLEP B
page of the IEP.

Student
records,
documentation and
interviews
The district consistently invites
students age 14 and older to
Team meetings.
Partial
The PLEP B page of the
IEP did not always
include age related
consideration when
needed.
Partial
Record
review,
documentation and
interviews
The district’s policy and
procedures ensure that progress
reports are issued when required
and they contain the required
elements. Some student records
contained progress reports that
were carefully written and
3
Partial
The record review
indicated that not all
student records contained
progress reports on all
IEP goals, and progress
reports were not always
present in the record for
Not sooner than June 1, 2005,
the Department will conduct a
record review to ensure that
IEPs of students age 16 and
older promote movement to
post secondary goals.
The district must provide
training to staff members on
the requirement to report on
all IEP goals, and they must
develop a procedure to ensure
that a copy of each progress
report is included in the
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting

contained detailed information
so that a parent could determine
what progress was being made
on IEP goals.
each reporting period.
The progress for a student
in an out-of-district
setting contained general
information and did not
address the progress on
the IEP goals.
student record.
When monitoring the
implementation of the IEP of
students in out-of-district
placements, the district must
ensure that the program is
providing documentation of
the progress being made on
IEP goals and objectives.
No sooner than June 1, 2005,
the Department will review
progress reports in a sample
of records.
4
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 15
Outreach by
the School
District (Child
Find)
SE 18A
IEP
development
and content
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Partial
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
The record review
indicated that not all IEP
goals were measurable
and that some IEPs had
missing elements.
For example:
Portions of the PLEP A
page of the IEP were
blank;
The PLEP B page of the
Not before June 1, 2005 the
Department will conduct a
record review of 10 randomly
selected IEPs to ensure that all
required portions of the IEP
are being addressed and that
IEP goals are measurable.

Student
records,
documentation and
interviews
Record
review,
documentation and
interviews
The district reaches out to
private schools, physicians and
early childhood service
providers to identify students
who may be in need of services.
Notices are mailed to agencies
and schools and information
was presented to an
organization of preschool
service providers. Procedures
are in place to identify students
within the schools themselves
who may be in need of services.
Many IEPs reviewed had all
required elements and welldeveloped, measurable goals
and objectives.
The district recently conducted
a training on IEP development.
5
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

IEP was blank when age
considerations or
behavior should have
been addressed;
Parent concerns was
blank; and,
Transportation was
blank.
6
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 18B
Determination
of placement;
immediate
provision of
IEP to parent
SE 20
Least
restrictive
program
selected
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified



Student
records,
documentation and
interviews

Student
records,
documentation and
interviews
In most cases after the Team
meeting, the IEP was
immediately provided to the
parent along with the placement
page. The district consistently
met the requirement of holding
the Team meeting within 45
days of receiving the consent for
the evaluation.
The district has policies and
procedures in place and a strong
commitment to educating
students in the least restrictive
setting. The district has put
extensive supports in place to
bring students with significant
needs back to the district from
private schools. A behavior
consultant has been hired, and
classes have been established
for students with autism and
behaviors that affect their
learning.
7
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 22
IEP
implementation and
availability
(Emphasis on
provision of
IEP services
without delay;
provision of
the IEP at the
beginning of
the school
year; and,
alternative
methods of
service
delivery where
there is a lack
of space
and/or
personnel))
SE 26
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified



Student
records,
documentation and
interviews
Teachers are required to read
their students’ IEPs and to sign
a statement to that effect.
Services are provided without
delay.
Consistent efforts are made to
8
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Parent
participation in
meetings
(Emphasis on
district’s
attempts to
ensure parent
participation
at IEP Team
meetings)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified



Student
records,
documentation and
interviews
involve parents in their child’s
program. Documentation
indicated that when parents
were not present at the Team
meeting, alternate means were
used to involve the parent.
9
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 28
Parent
provided the
IEP or notice
of no
eligibility
together with
notification of
procedural
safeguards and
parents' rights
SE 29
Communications are in
English and
primary
language of
home
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified



Student
records,
documentation and
interviews

Student
records,
documentation and
interviews
The parent was provided the
IEP in most all records
examined with procedural
safeguards. The N1 form did
not always document receipt of
Parents’ Rights, but all
questions on page two of the
form were most often addressed.
The district has policies and
procedures that meet the
requirements under this
standard.
Note that when the primary
language of the home is other
than English, but English is
understood and translation is not
required, this information
should be documented in the
IEP.
10
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 32
Parent
advisory
council for
special
education
SE 50
Responsibilities of the
School
Principal and
Administrator
of Special
Education
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified




Student
records,
documentation and
interviews
Documentation and
interviews
The district has an active
Special Education Parent
Advisory Council. By-laws are
in place and a workshop on
parents’ rights was held this
year. The group conducted a
survey of parents of special
education students that had a
very good response. The results
of the survey were compiled and
shared with the school
committee.
Interviews indicated that there is
regular communication between
school administrators and the
director of special education.
There is instructional support
for teachers and students, and
training has been provided in
meeting the diverse learning
needs of all students. Policies
and procedures are in place to
insure that children confined to
11
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 54
Professional
development
regarding
special
education
SE 56
Special
education
programs and
services are
evaluated
Other
Requirements
SE 8
Evaluation
Team
Composition
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified



Documentation and
interviews

Documentation and
interviews

Student
records,
documentation and
interviews
home or hospital receive
services.
The district offers a wide array
of topics to professional and
paraprofessional staff members
related to special education.
Interviews indicate that training
in the required topics has been
provided.
The district regularly evaluates
the effectiveness of its special
education programs.
Student records and interviews
indicated that evaluation Teams
have the required members,
including someone with the
authority to commit the
resources of the district.
12
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 9
Eligibility
Determination: timelines
for evaluation,
immediate
provision of
IEP
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified



Student
records,
documentation and
interviews
Partial
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Interviews indicated that
the extended school year
is not always discussed at
the Team meeting.
By June 1, 2005 please
submit a description of how
the requirement to discuss
extended school year
requirements was made
known to Team chairpersons.
If it was addressed at a
meeting, submit the agenda

Student
records,
documentation and
interviews
SE 14
Annual
Reviews
SE 21
School day
and school
year
requirements
Method(s)
of Verification
Student
records,
documentation and
interviews
Although the record review
indicated that there were cases
where the evaluations were not
completed within 30 days of
receipt of the consent to
evaluate, the Team meeting took
place within 45 days.
The record review indicated that
some annual reviews took place
after the expiration of the last
IEP.
Student records indicated that
the extended school year is
noted on student’s IEPs with the
services included on the service
delivery page.
13
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting

and if it was communicated
by memo please include a
copy.
SE 24
Notice to
parent
regarding
proposal or
refusal to
initiate or
change the
identification,
evaluation, or
educational
placement of
the child or the
provision of
FAPE

Student
records,
documentation and
interviews
Student records indicated that
the proposed action form was
completed when required and in
most cases the questions on
page 2 of the form are
addressed.
14
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 25
Parental
consent
SE 34
Continuum of
alternative
services and
placements
SE 36
IEP
implementation,
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
The record review
indicated that the consent
to evaluate did not always
correctly indicate the
evaluations that were
completed. There were
education evaluations left
blank on the form and a
consent that was not sent
out within 5 days of the
request for the evaluation.
Not before June 1, 2005 the
Department will conduct a
record review of a random
sample of records that contain
a recently completed initial or
reevaluation.

The record review indicated that
the consent to evaluate form
was present in student records.
Partial

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Student
records,
documentation and
interviews
Interviews
and
document-
Interviews and student records
indicate that the high school
provides speech and language
and adapted physical education.
An adjustment counselor is
available to work with students
and counseling is provided as an
IEP service.
Interviews indicated that there is
no delay in the implementation
of IEP services.
15
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

ation
SE 40
Instructional
Grouping

SE 41
Age Span

SE 55
Special
Education
Classrooms
Comments Regarding
Corrective Action Plan
Implementation

accountability
and financial
responsibility
SE 44
Behavioral
interventions
Method(s)
of Verification
Interviews
and
documentation
Interviews
Interviews


Documentation and
interviews
Interviews indicated that classes
meet regulatory requirements
regarding class size.
Interviews indicated that the age
span requirements were met.
Interviews indicated an
awareness that suspensions
involving transportation need to
be counted with other
suspensions.
Interviews and site visit
indicated that the location of
special education classes in the
district maximizes the
integration of eligible students
into the life of the school.
16
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

MOA 17
Handbooks
MOA 17A
Use of
physical
restraint on
any student
enrolled in a
publiclyfunded
education
program
Method(s)
of Verification


Documentation and
interviews

Documentation and
interviews
Documentation indicated that
student handbooks contain a
statement of nondiscrimination.
Interviews and documentation
indicate that the district is
meeting the requirement of the
regulations regarding the use of
physical restraints.
17
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress Reporting