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
March 9, 2005
Mihran Keoseian, Superintendent
Harvard Public Schools
39 Massachusetts Avenue
Harvard, Massachusetts 01451
Re:
Plan
Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action
Verification and Special Education Mid-cycle Review
Dear Superintendent Keoseian:
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 March 12, 2002.
While the Department of Education found certain noncompliance issues to be resolved, others
were partially corrected, not addressed at all and/or new issues were identified by the
Department’s onsite team. In areas where the district has failed to implement fully its approved
Corrective Action Plan, the Department views these findings to be serious.
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 June
1, 2005.
This Mid-cycle Coordinated Program Review Report includes an extraordinary number of
serious findings of persistent noncompliance particularly with special education law, many of
which were included in the Department’s Coordinated Program Review Report dated March 12,
2002. In consideration of this, we will be holding a meeting in the Department’s Malden offices
to provide you and the Chairperson of your School Committee with a more detailed explanation
of the basis of the Department’s most recent findings and the steps the Department is obligated to
take to enforce these laws in the Harvard Public Schools. This meeting will take place on June
21, 2005 at 1:30 p.m. Please call John Stager, Administrator of Program Quality Assurance
Services, to confirm your attendance at this important meeting regarding your school district.
As stated in the enclosed Mid-Cycle Review Report, the Department continues to document
areas of serious noncompliance with state and federal law, particularly in special education. In
2002, the district proposed corrective action to remedy all areas of noncompliance identified by
the Department at that time. The Department approved these corrective action plans, and since
that time the district has inconsistently provided the Department with written progress reports
describing implementation of these approved plans. Further, as a result of the verification
activities in January 2005, which consisted of staff interviews, student record reviews,
documentation review and classroom observations, the Department found that the approved
corrective action plans have either; (1) not been implemented as approved by the Department; (2)
been determined to be very unevenly implemented at the building level; (3) or been documented
to be implemented but have been found to be ineffective in addressing the identified
noncompliance. This is in direct contrast to the written assurances submitted by the district in
progress reports and other statements of assurance filed with the Department as condition for
receiving state and federal funds.
The Department documented 33 findings of special education noncompliance by the district in
2002, and the enclosed Mid-Cycle Report documents 20 findings of noncompliance in the
Harvard Public Schools’ special education programs, 8 of which are areas of continuing
noncompliance. This is not acceptable after three years of reported corrective action effort.
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 Follow-up Chairperson at 781-338-3733.
Sincerely,
Nathan Lemmon, 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
Sharon McCarthy, School Committee Chairperson
Charles Horn, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
Harvard Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on April 14, 2002
Progress Reports Submitted on October 30, 2002, September 2, 2003, November 28, 2003, February 25, 2004, August 16, 2004
Onsite Visit Conducted on January 27-28, 2005
Date of this Report May 19, 2005
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Special
Education
Requirements
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
Implemente
d 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
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 2
Required and
Optional
Assessments
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Student records indicate
that educational
assessments are not
consistently documented.
Please provide training to
special education staff,
including Team Chairs,
regarding the requirements
for conducting educational
assessments and
documenting this report in
the student record. Provide
a copy of the training
agenda and attendance
sheet to the Department by
September 30, 2005.

Student Record
and Staff
Interviews
Student records indicate
that the district conducts
optional assessments when
optional assessments are
recommended and
consented to.
Not Fully
Implemented
Document the results of the
district’s periodic internal
monitoring for compliance
with this standard. The
results should indicate the
date conducted, the number
of records reviewed and a
description of additional
steps taken where noncompliance was noted.
2
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
Implemente
d 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

Standard for meeting
compliance with this
criterion will be subject
to on-site review during
the ‘05-‘06 SY by the
Department.
SE 3
Special
requirements for
determination of
specific learning
disabilities
Partial
Student
Records, District
Documentation
and Staff
Interviews
The Team implements
some of the special
requirements for
determination of specific
learning disabilities
Not Fully
Implemented
Although a new process
has been put in place,
student records and staff
interviews indicate that
the district does not
consistently document all
the requirements for
determining Specific
Learning Disabilities.
Provide training to special
education staff, including
Team Chairs, regarding the
special requirements for
determining specific
learning disabilities (SLD)
and appropriate completion
of the SLD form. A copy
of the training agenda and
attendance sheet will be
provided to the Department
by September 30, 2005.
Document the results of the
district’s periodic internal
monitoring for compliance
with this standard. The
3
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
Implemente
d 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

results should indicate the
date conducted, the number
of records reviewed and a
description of additional
steps taken where noncompliance was noted.
Standard for meeting
compliance with this
criterion will be subject
to on-site review during
the ‘05-‘06 SY by the
Department.
4
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)
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Student records indicate
that the district does not
always initiate transition
services for students at
age 14. Transition goals
and vision statements are
sometimes lacking,
incomplete or absent.
Vision statements were
repeated in the student
record from year to year
on some student records,
indicating that the
information had not been
updated.
Provide training (an
external consultant would
be appropriate) to special
education staff, including
Team Chairs, and other
key personnel regarding
the special requirements
for transitional planning
for students 16 years of age
and older, and how to
appropriately document
that information in each
student’s IEP. Provide the
agenda, identify the trainer,
and provide the list of
attendees to the
Department by September
30, 2005.

Student Records
and Staff
Interviews
The Team, based upon the
student's needs, considers
the appropriate transition
services for most students.
Not Fully
Implemented
Interviews indicate that
the district provides few
transition activities to
students 16 and older
except for visits from
representatives from local
regional vocational high
schools.
5
Document the results of the
district’s periodic internal
monitoring for compliance
with this standard. The
results should indicate 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
Implemente
d 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

date conducted, the number
of records reviewed and a
description of additional
steps taken where noncompliance was noted.
Standard for meeting
compliance with this
criterion will be subject
to on-site review during
the ‘05-‘06 SY by the
Department.
6
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 7
Notice of Age of
Majority
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
The district does not
inform students of their
rights to educational
decision-making at age
17. The written policy
states that the district
informs the student at the
annual review following
the student’s 17th birthday.
Distribute a memo to all
special education staff,
guidance counselors, and
school psychologists
explaining the requirement
to consistently document
within the IEP and within
the student’s record, the
discussion of transfer of
rights at least one year
before the student’s age of
majority and, upon
reaching the age of
eighteen, a record of the
student’s consent to
continue the student’s
special education program.
Please provide a copy of
the memo to the
Department by September
30, 2005.

Student
Records, District
Documentation
and Staff
Interviews
The district provides a
notice to the student of his
or her right at age 18 to
make all decisions in
relation to special education
programs and services.
Not Fully
Implemented
Document the results of the
district’s periodic internal
7
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
Implemente
d 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

monitoring for compliance
with this standard. The
results should indicate the
date conducted, the number
of records reviewed and a
description of additional
steps taken where noncompliance was noted.
Standard for meeting
compliance with this
criterion will be subject
to on-site review during
the ‘05-‘06 SY by the
Department.
8
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 8
Evaluation Team
Composition
SE 9
Eligibility
Determination
Timelines for
Evaluations,
Provision of the
IEP
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Implemented
Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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

Staff
Interviews
&
Documentation
Student
Records, District
Documentation
and Staff
Interviews
Staff interviews and
documentation indicate that
Evaluation Team meetings
are composed of the
appropriate members.
The district refers students
found not eligible for
special education services
for consideration under
Section 504 program.
9
Not Fully
Implemented
Interviews, documents
and student records
indicate that the district
does not consistently meet
the 45-day timelines for
determination of
eligibility for services.
The district will draft and
distribute a memo to
special education staff,
including Team Chairs,
regarding timelines for
provision of Team
Meetings, IEPs to the
parents, or a written
explanation of the finding
of no eligibility within
forty-five school working
days after receipt of the
parent's written consent to
evaluate. A copy of the
memo will be provided to
the Department by
September 30, 2005.
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
Implemente
d 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

District must develop a
tracking system procedure
with person(s) responsible
for oversight and a
monthly schedule for
conducting a random
sample of records to verify
progress. Due by
September 30, 2005.
Document the results of the
district’s periodic internal
monitoring for compliance
with this standard. The
results should indicate the
date conducted, the number
of records reviewed and a
description of additional
steps taken where noncompliance was noted.
Standard for meeting
compliance with this
criterion will be subject
to on-site review during
10
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
Implemente
d 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

the ‘05-‘06 SY by the
Department.
11
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
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

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Student records indicate
that progress reports are
not always 1)
Documented in the
student record 2) Did not
always predict if student
would achieve goal by the
end of the year
Review with special
education teachers and
related services staff the
required elements to be
addressed when developing
written progress reports.
Document the materials
and attendance for this
review by September 30,
2005.

Student Records
and Staff
Interviews
The district has documented
that it provides to parents
some written
documentation of student’s
progress toward the annual
goals in the IEP.
Not Fully
Implemented
Document the results of the
district’s periodic internal
monitoring for compliance
with this standard. The
results should indicate the
date conducted, the number
of records reviewed and a
description of additional
steps taken where noncompliance was noted.
Standard for meeting
compliance with this
criterion will be subject
12
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
Implemente
d 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

to on-site review during
the ‘05-‘06 SY by the
Department.
13
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)
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Outreach only done at the
preschool level
(Interviews, Document
Reviews and Student
records)
The district must submit a
draft of its outreach policy
that includes outreach for
students at all levels,
elementary, middle and
high school, due at the
Department by September
30, 2005.

Student
Records, District
Documentation
and Staff
Interviews
The district provides liaison
with some groups from
which promotion or transfer
of students in need of
special education may be
expected.
Not Fully
Implemented
Further, the district must
document its expanded
outreach efforts.
Standard for meeting
compliance with this
criterion will be subject
to on-site review during
the ‘05-‘06 SY by the
Department.
SE 17
Initiation of
services at age
Implemented
Staff
Interviews
The on-site Team found the
through interviews and
14
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
three and Early
Intervention
transition
procedures
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
Implemente
d or
Additional
Issues
Identified

&
Documentation
documentation that the
district has provided
continuity of services and
has ensured the
development and
implementation of IEP
plans prior to the child’s
third birthday.
15
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 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

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Student Records indicate
that the IEP Goals and
Objectives where
frequently not measurable.
Vision statements often
did not take into account
the student’s input and
needs. Assistive
Technology is provided
only when the services are
available in the district.
Goals and Objectives are
repeated year to year.
Placement pages were
missing. Service providers
not labeled correctly on
Service Delivery Grid.
Provide training to Team
chairpersons and key
special education personnel
regarding the requirements
for and appropriate
documentation in the IEP
for
1) developing
measurable annual
goals;
2) developing vision
statements based
on student input
and for older
students postsecondary plans;
3) assistive
technology based
on individual
student needs not
on what is
currently available;
4) service providers
identified by

Student Record
and Staff
Interviews
The district does develop an
IEP using student
evaluation data.
16
Not Fully
Implemented
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
Implemente
d 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

certification,
license or role (i.e.
paraprofessional)
on the Service
Delivery Grid and;
5) the requirement for
issuing completed
PL1 forms with
each IEP. District
must provide the
agenda, materials
and signed
attendance sheet to
the Department by
September 30,
2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
17
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
Implemente
d 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

SE 18B
Determination of
placement;
immediate
provision of IEP
to parent
Partial
Student
Records, District
Documentation
and Staff
Interviews
SE 19
Extended
Evaluation
Partial
Student
Records, District
Documentation
and Staff
Interviews
Students in the district are
educated in the school that
he or she would attend if
the student did not require
special education.
18
Not Fully
Implemented
Student Records and
Interviews indicate that
the placement page of the
IEP is not always
documented in the student
record. Interviews and
records indicate that IEPs
are not always sent to
immediately following the
development of the IEP.
See required corrective
action for issuing the IEP
immediately for SE 9.
See required corrective
action for completion of
the placement page (PL1)
For SE 18A.
Not Fully
Implemented
Staff interviews and
student records indicate
that the district uses the
extended evaluation to
allow additional time to
complete required
assessments.
Submit documentation to
verify that Team members
have been trained on
extended evaluation
regulations. This
documentation must
include the following:
 Agenda for
training
 Signature and
professional title of
all staff in
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
Implemente
d 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

attendance
This documentation must
be received at the
Department of Education
by September 30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
19
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 20
Least restrictive
program selected
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))
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
Implemente
d or
Additional
Issues
Identified

Implemented
Staff
Interviews
&
Documentation
Staff interviews and
documents show that the
district provides programs
in the student’s least
restrictive environment.
Implemented
Staff
Interviews
&
Documentation
Staff interviews and
documentation show that
the district provides
services without delay
following accepted IEP
plans.
20
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 24
Notice to Parent
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Records and Interviews
indicate that the district
does not always provide
notice to parents within a
reasonable time for all
actions. Specifically, the
district does not provide
N1 notices that address all
questions.
Provide to the Department
documentation of training
for all Special Education
Chairpersons on the
requirement to provide
written notice when
responding to requests and
when proposing or refusing
to initiate or change the
identification, evaluation,
or educational placement
of the child or the
provision of FAPE by
September 30, 2005.

Student
Records, District
Documentation
and Staff
Interviews
Student records and staff
interviews indicate that
when a student is referred
for an evaluation to
determine eligibility for
special education, the
school district sends written
notice to the child’s
parent(s) within 5 school
days of receipt of the
referral.
Not Fully
Implemented
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
SE 25
Partial
Student
Not Fully
21
Records indicate that
Please see SE 18 B.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Parental Consent
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
Implemente
d or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Records, District
Documentation
and Staff
Interviews
Implemented
22
parental consent for
placement is not
consistently documented
in all student records
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
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Records and Interviews
indicate inconsistent use
of the N3 and N3A
Provide training on the
requirements of notice as it
relates to Team Meeting
Invitations and Attendance
Sheets consistent with
M.G.L. c. 71B, § 3 and 34
CFR 300.503-504 to
special education staff,
including Team Chairs, by
September 30, 2005.

SE 26
Parent
participation in
meetings
(Emphasis on
district’s attempts
to ensure parent
participation at
IEP Team
meetings)
Implemented
Staff
Interviews
&
Documentation
SE 27
Content of Team
Meeting Notice to
Parent
Partial
Student
Records, District
Documentation
and Staff
Interviews
Student records and staff
interviews indicate that
parents participate in the
IEP process and that the
district makes multiple
attempts with a variety of
methods to ensure parent
participation.
Not Fully
Implemented
Standard for meeting
compliance with this
23
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
Implemente
d 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

criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
24
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
Implemente
d 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
Records and Interviews
indicate that the district
does not translate
documents for
parents/guardians when
needed. The district does
not have a consistent
procedure for the
identification of students
or parents/guardians who
may require translated
information or
interpreters.
The district must develop
procedures and implement
them district-wide for
identifying the primary
language of the home. The
district must also develop
procedures for securing
interpreters and providing
translated documents to
parent/guardians who are
speakers of languages
other than English. These
procedures must be

SE 28
Parent provided
the IEP or notice
of no eligibility
together with
notification of
procedural
safeguards and
parents' rights
Implemented
Staff
Interviews
&
Documentation
Staff interviews and student
records indicate substantial
compliance with the
immediate provision of the
IEP to parents with
notification of procedural
safeguards and parents’
rights.
SE 29
Communications
are in English and
primary language
of home
Partial
Student
Records, District
Documentation
and Staff
Interviews
Staff interviews indicate
that some district
communications with
parents whose primary
language is not English
have been provided via
translation at meetings.
25
Not Fully
Implemented
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
Implemente
d 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

reviewed with all district
administrators and fully
implemented by the
beginning of the 20052006 SY. Please provide
copies of the procedures
and evidence of there
review with district
administrators to the
Department by September
30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
26
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 34
Continuum of
Alternative
Services and
Placements
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
Implemente
d 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
Interviews and record
reviews indicate that the
district does not provide a
full continuum of services
and alternative placements
to meet the needs of all
students with disabilities.
Specifically, the district
does not provide
substantially separate
programs for in-district
students.
Submit the district’s plans
to expand its capacity to
provide district-based
substantially separate
opportunities for
appropriate students by
September 30, 2005.

Implemented
Staff
Interviews
&
Documentation
The on-site Team found
that the district has
established a Parent
advisory council for Special
Education that meets the
requirements of the
regulations of Chapter 71B,
Section 3; 603 CMR
28.07(4).
Partial
Student
Records, District
Documentation
and Staff
Interviews
The district provides an
array of special education
services including
alternative placements to
meet the needs of most
students with disabilities.
27
Not Fully
Implemented
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during 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
Implemente
d 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

’05-’06 SY.
28
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 39
Procedures for
Services at
Private Schools at
Private Expense
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
The district has shown no
documentation that the
district provides outreach
to private schools at
private expense to
determine the number of
eligible students.
The district must develop
procedures for determining
the number of eligible
private school students in
consultation with private
school representatives by
September 30, 2005.

Student
Records, District
Documentation
and Staff
Interviews
Not Fully
Implemented
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
SE 44
Procedures for
Recording
Suspensions
Implemented
Staff
Interviews
&
Documentation
The district has been found
to have a procedure to
record the number and
duration of suspensions,
including any suspensions
from any part of the
student’s IEP program
(including transportation).
29
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
Implemente
d or
Additional
Issues
Identified

30
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
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d or
Additional
Issues
Identified

SE 45
Procedures for
Suspensions up to
10 Days and After
10 Days (General
Requirements)
Implemented
Staff
Interviews
&
Documentation
Staff interviews and student
record reviews indicate that
the district meets the
general procedural
requirements for
suspensions up to 10 days
and after 10 days.
SE 46
Manifestation
Determination
Implemented
Staff
Interviews
&
Documentation
Staff interviews and district
documentation indicate that
the district has appropriate
procedures in place for
suspension of students with
disabilities when
suspension exceeds 10
consecutive days or when a
pattern has developed for
suspensions exceeding 10
cumulative days.
31
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
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Student Records and
Interviews indicate that
the district does not
provide a full range of
psychological services for
students identified for
such services. Much of the
psychological services
provided for students are
provided by guidance
counselors.
The district must revise its
policy in this area and
provide access to a range
of appropriately qualified
professionals, based on the
individual needs of the
student as determined by
the IEP Team. Provide the
Department with a
description of how the
district proposes to expand
its capacity to provide
appropriate counseling
services consistent with
individual student need. .
Provide to the Department

SE 47
Procedural
Requirements
Students Not Yet
Found Eligible
for Services
Implemented
Staff
Interviews
&
Documentation
SE 49
Related Services
Partial
Student
Records, District
Documentation
and Staff
Interviews
Staff interviews and district
documentation indicate that
the district has appropriate
procedures in place for
students not yet found
eligible for services.
Not Fully
Implemented
32
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
Implemente
d 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

a copy of the district’s
revised policy and provide
the Department with
evidence that it was
reviewed with all district
Chairpersons by
September 30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
33
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
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

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
District interviews
indicate that the Harvard
Public Schools has no
developed DCAP. There
is no coordinated Teacher
Support Team at the High
School level. The district
has not documented the
provision of Educational
Services in Home or
Hospital.
The district must develop a
procedure for meeting the
requirements of 603 CMR
28.03(3) for implementing
the district’s curriculum
accommodation plan and
for meeting the
responsibilities of the
school principal for
instructional support at the
High School level. Also,
the district must develop
and submit to the
Department a policy for the
implementation of
Educational Services in
Home or Hospital that
meets the requirements of
state law by September
30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the

Student
Records, District
Documentation
and Staff
Interviews
Not Fully
Implemented
34
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
Implemente
d 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

Department during the
’05-’06 SY.
35
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
Implemente
d 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
Interviews indicate that
Professional Development
training for relevant
Special Education
requirements has occurred
for Special Education staff
only.
Develop a training plan for
all staff on key required
topics, including

SE 53
Use of
Paraprofessionals
Implemented
Staff
Interviews
&
Documentation
SE 54
Professional
development
regarding special
education
Partial
Student
Records, District
Documentation
and Staff
Interviews
Interviews with district staff
and documentation
provided to the on-site
Team found that training
has been provided to
paraprofessionals in
providing special education
or related services and
paraprofessionals do not
design instruction for
students with disabilities.
Not Fully
Implemented
36
1) state and federal
special education
laws;
2) confidentiality of
student records;
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
Implemente
d 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

3) analyzing and
accommodating
diverse learning
styles;
4) methods of
collaboration and
5) training in the
provision of prereferral services
within regular
education,
(particularly at the
High School level)
for the 2005-2006
SY by September
30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
37
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 56
Special education
programs and
services are
evaluated
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d 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
Interviews indicate district
has not evaluated its own
programs (No Docs). In
the past, letters have been
sent out to parents asking
about HPS services.
The district must develop
and implement a plan for
evaluating all of the
district’s special education
programs and services,
including administration.
The evaluation plan must
include methods of
determining the
effectiveness of programs
in assisting students with
disabilities to achieve the
goals set forth in their IEPs
in the least restrictive
environment. Data used to
determine success should
include local and statewide
assessments results,
dropout rates and
graduation rates for special
education students. The
district’s evaluation plan
must be submitted to the
Department by September

Student
Records, District
Documentation
and Staff
Interviews
Not Fully
Implemented
38
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
Implemente
d 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

30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Other
Requirements
MOA 1
Identification of
Limited English
Proficient
Students
Partial
Student
Records, District
Documentation
and Staff
Interviews
At the time of the midcycle, the district did not
have any limited English
proficient students. The
district indicated that it
screens all students using a
Home Language Survey,
however, the example
surveys provided were all in
English; it is not clear that
the district offers these
surveys in a family’s native
39
Not Fully
Implemented
The district’s procedures
did not indicate how it
would obtain the qualified
personnel to administer
and interpret the results of
the tests used to identify a
student’s English
language proficiency. The
district did not include
what its criteria are for
entry to their English
learner education
The district must provide
to the Department by
September 30, 2005 the
following:
- Evidence that the Home
Language Survey is
available in the family’s
native/primary language
- The criteria for entry into
the district’s English
Language Learner
program.
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
Implemente
d 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

language. The district has
identified the Language
Assessment Scale Oral
(LAS-O) and the Language
Assessment Scales Reading
and Writing (LAS R and
W) as the assessments used
to determine English
language proficiency
following screening using
the Home Language
Survey.
40
program.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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

MOA 2
Program
Modification and
Support Services
for Limited
English Proficient
Students
Partial
Student
Records, District
Documentation
and Staff
Interviews
At the time of the mid-cycle
the district did not have any
limited English proficient
students. See ELE 5 for the
finding under this criterion.
MOA 6
Availability of InSchool Programs
for Pregnant
Students
Implemented
Staff interviews
and District
Documentation
The district has provided
the Department with a copy
of a policy that meets the
requirements of this
criterion.
MOA 7
Information to be
Translated into
Languages Other
than English
Partial
District
Documentation
Staff Interviews
The district has provided a
copy of a memo from the
Superintendent to the
principals of the Bromfield
School and Harvard
Elementary School
referencing (attached)
copies of notices written in
41
See ELE 5 for the finding
under this criterion.
Not Fully
Implemented
The district has not
provided evidence that
school and promotional
materials are disseminated
to persons whose primary
language is other than
English who reside in the
community.
Provide copies of examples
and an explanation of
dissemination methods for
school and program
recruitment and
promotional materials that
are provided to persons in
the community who are
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

Reserved
MOA 10
Implemented
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

English and Spanish for
translation and interpreter
service availability. The
memo also instructs that the
notices included should be
posted conspicuously
throughout the schools.
MOA 10A
Handbooks and
Codes of Conduct
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d or
Additional
Issues
Identified
Documentation,
Staff Interviews
The district has provided
copies of the requested
revised and updated staff
guides to the Department
including:
nondiscrimination
statements, harassment
policy, complaint
procedures and names of
the Section 504, Title VI
42
speakers of languages
other than English by
September 30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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
Based on staff interviews
not all district staff have
been provided training on
the district’s policy
Provide to the Department
documentation that the
district has developed and
implemented staff training

and Title IX coordinators.
MOA 12
MOA 12A
Annual and
Continuous
Notification
Concerning
Nondiscriminatio
n and
Coordinators
Reserved
Implemented
Documentation,
Staff Interviews
See MOA 10A.
Documentation
and Staff
Interviews
The district has submitted a
detailed policy to describe
appropriate responses to
student behavior that may
Reserved
MOA 17
MOA 17A
Use of Restraint
Partially
Implemented
43
Not Fully
Implemented
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
Implemente
d or
Additional
Issues
Identified
Partial
Further Corrective
Action
Ordered by the
Department of Education
and Timelines for
Implementation and
Further Progress
Reporting
governing the use of
physical restraint in
accordance with M.G.L.
c.71, s.37G. Training
must be provided within
the first month of school
and for employees hired
after the year begins,
within a month of their
employment.
at least annually on the use
of restraint consistent with
regulatory requirements by
September 30, 2005.
The materials provided to
the Department with the
subject of sexual
harassment have a date of
January 14, 2004. It is not
clear to the Department
The district will be
required to document
through agenda(s) and
dates that training on the
required civil rights topics
has been provided to all

require immediate
intervention, methods for
preventing student violence,
self-injurious behavior and
suicide, including deescalation of potentially
dangerous behavior, a
description and explanation
of the methods of district’s
physical restraint, a
description of the district’s
training requirements and
reporting requirements, a
procedure for receiving and
investigating complaints
regarding restraint
practices.
MOA 21
Staff Training
Regarding Civil
Rights
Responsibilities
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Staff Interviews
and District
Documentation
The district has provided a
copy of a memo from the
Superintendent to all staff
that a Civil Rights training
was to occur on February
16, 2005. Also included
44
Not Fully
Implemented
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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

Implemented
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
when or if these materials
were used during the
2004/2005 school year
annual Civil Rights
training. The district did
not document that training
regarding civil rights
responsibilities were
provided to staff hired
beyond the start of the
school year within a
month of hire.
district staff both following
the start of the 2005/2006
school year and following
the hire of individuals
within a month of hire by
September 30, 2005.

with the district’s
documentation are copies of
some materials to use
during training for district
staff on sexual harassment.
MOA 24
Curriculum
Review
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d or
Additional
Issues
Identified
Staff Interviews
and District
Documentation
The district has provided a
copy of its policy in this
area that meets the
requirements of the
criterion. The district also
provided a copy of a memo
from the Superintendent to
Principals of the Bromfield
School and Harvard
Elementary School
45
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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

announcing the newly
developed policy.
.
Not
Implemented
ELE 1
Annual
Assessment
District documentation
and staff interviews
indicate:
The district did not
provide documentation
that appropriate district
staff have been trained to
administer the required
annual assessments for all
limited English proficient
(LEP) students to include
the Massachusetts English
Proficiency Assessment
(MEPA) in grades 3-12
and the Massachusetts
English Language
Assessment – Oral
(MELA-O) in grades K-
46
Provide documentation that
appropriate district staff
have been trained to
administer the required
annual assessments for all
limited English proficient
(LEP) students to include
the Massachusetts English
Proficiency Assessment
(MEPA) in grades 3-12
and the Massachusetts
English Language
Assessment – Oral
(MELA-O) in grades K-12.
Standard for meeting
compliance with this
criterion will be subject
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
ELE 2
MCAS
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
Implemente
d 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

The district does administer
the Massachusetts
Comprehensive Assessment
System (MCAS)
assessments to students in
grades 3-12
.
The district has not
provided accommodations
to LEP students for MCAS
testing because no students
have been determined to be
Limited English Proficient
47
Not
Implemented
12.
to on-site review by the
Department during the
’05-’06 SY.
The district has not
provided MCAS
accommodations to LEP
students because none of
the district’s students have
been identified as Limited
English Proficient. The
district has not provided
the Department with a
plan to implement the
provision of bilingual
dictionaries and/or
electronic translators to
LEP students and has not
provided a plan to inform
parents/guardians of their
option to not take the
MCAS English Language
Test during the first year
Provide the Department
with a plan to implement
the provision of bilingual
dictionaries and/or
electronic translators to
LEP (Limited English
Proficient) students for
MCAS and provide a plan
to inform parents/guardians
of their option to not take
the MCAS English
Language Test during the
first year following
original LEP identification
status by September 30,
2005.
Standard for meeting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
ELE 3
Initial
Identification
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
Implemente
d 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

District
Documentation
and Staff
Interviews
The district indicated that it
screens all students using a
Home Language Survey.
following original LEP
status.
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Not Fully
Implemented
The sample Home
Language Surveys
provided to the
Department were all in
English; it is not clear that
the district offers these
surveys in a family’s
native language. The
district did not include
what is the criterion for
entry to their English
Learner Education
program.
(See Requirements MOA 1)
Not
District documentation
The district must
The district has identified
the Language Assessment
Scale Oral (LAS-O) and the
Language Assessment
Scales Reading and Writing
(LAS R and W) as the
assessments used to
determine English language
proficiency following
screening using the Home
Language Survey.
ELE 4
48
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
Implemente
d 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

Waiver
Procedures
Implemented
and staff interviews
indicate:
The district has no
1) description of
waiver
implementation
practices;
2) no copy of a local
waiver form; and
3) no class roster of
students who have
been waived.
The district has stated that
there are currently no
children receiving ELE
programs and/or services.
There would be no
requirement for a roster if
no students had been
identified.
49
develop waiver
implementation
procedures, including a
local waiver form by
September 30, 2005.
.
Log all children who have
been waived if applicable.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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

Not
Implemented
ELE 5
Program
Placement and
Structure
District documentation
and staff interviews
indicate:
The district has not
documented a description
of its English Language
Learner implementation
practices and has not
documented evidence of
professional development
for teachers to provide
SEI (Structured English
Immersion) services.
The district has described
in its MOA 1 and MOA 2
documentation that,
“Sheltered English
instruction will be
provided by modifying
general classrooms to
include LEP students for
instruction in core
50
Explain how the district
intends to deliver an
English Language Learner
program consistent with
the requirements of
Chapter 71A.
Document a professional
development plan for staff
that may be responsible for
the instruction of limited
English proficient students.
Define specifically what
training will be required
for core academic teachers
in sheltered English
instruction (SEI) when
these services are provided
for students who have been
defined by the district as
having limited English
proficiency, as well as the
provisions the district will
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
Implemente
d 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
academic subjects as well
as the arts and physical
education classes.” (The
Department notes that
implementation guidance,
http://www.doe.mass.edu/
ell/sei/ describes in detail,
the specific and required
effective practices for
implementation of
Chapter 71A.
make to secure qualified
staff for providing
instruction in English
language skills. This
information is due to the
Department by September
30, 2005.

51
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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

Not
Implemented
ELE 6
Program Exit and
Readiness
District documentation
and staff interviews
indicate:
Provide a description of the
district’s implementation
practices for this criterion.
The district did not
respond to this particular
criterion during the
current mid-cycle review.
Describe the district’s exit
criteria from ELE (English
Language Learner)
programs and services by
September 30, 2005.
The district provided no
description of its
implementation practices
in this area or its program
exit criteria.
Not
Implemented
ELE 7
Parent
Involvement
52
District documentation
and staff interviews
indicate that the district
has not developed a
mechanism for including
parents or guardians of
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Describe the district’s
implementation practices
in this area.
Develop a mechanism for
including parents or
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
Implemente
d 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

LEP students in matters
pertaining to their
children’s education.
guardians of LEP students
in matters pertaining to
their children’s education.
Note: The district should
provide multiple
opportunities and a variety
of methods for parentteacher communication and
document the availability
of such opportunities. This
information is due to the
Department by September
30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
53
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
Implemente
d 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
District documentation
and staff interviews
indicate that the district
has not developed a plan
describing how it will
provide English language
support to students whose
parents have declined
entry to a sheltered
English immersion, twoway bilingual, or other
ELE program.
Describe the
implementation plan for
providing supports to LEP
students whose parents
decline entry into an ELE
program by September 30,
2005.
District documentation
and staff interviews
indicate that the district
has not developed a plan
describing how it will
group students of different
ages and ensure that LEP
students receive effective
Describe the
implementation plan for
appropriate instructional
groupings consistent with
this criterion by
September 30, 2005.

Not
Implemented
ELE 8
Declining Entry
into a Program
Not
Implemented
ELE 9
Instructional
Grouping
54
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Standard for meeting
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
Implemente
d 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

content instruction at
appropriate academic
levels based on the
Massachusetts curriculum
frameworks.
55
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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
District documentation
and staff interviews
indicate that the district
has not developed a plan
describing how it will
provide information to
parents of LEP students
describing the district’s
ELE program and
informing parents’ of their
rights to apply for a
waiver (ELE 4) or their
rights to decline to enroll
in the program (ELE 9).
Describe how the district
will meet the requirements
for parent notification by
September 30, 2005.
District documentation
and staff interviews
indicate that the district
has not developed a plan
describing how it will
provide equal access to all
LEP students to the full
range of academic
Describe the district’s plan
for ensuring LEP students
have equal access to all of
the district’s academic
program offerings by
September 30, 2005.

Not
Implemented
ELE 10
Parental
Notification
Not
Implemented
ELE 11
Equal Access to
Academic
Programs and
Services
56
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Standard for meeting
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
Implemente
d 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

opportunities and supports
afforded non-LEP
students.
57
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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
District documentation
and staff interviews
indicate that the district
has not developed a plan
describing how it will
provide equal access to all
LEP students to the full
range of non-academic
and extracurricular
programs afforded nonLEP students.
Describe the district’s plan
for ensuring LEP students
have equal access to nonacademic and extracurricular activities by
September 30, 2005.
District documentation
and staff interviews
indicate that the district
has not developed a plan
describing how it will
monitor and if necessary,
provide services for
students who have been
identified as no longer
limited English proficient
Describe the district’s plan
to provide follow-up
support for students who
have exited the ELE
program by September 30,
2005.

Not
Implemented
ELE 12
Equal Access to
Nonacademic and
Extracurricular
Programs
Not
Implemented
ELE 13
Follow-Up
Support
58
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Standard for meeting
compliance with this
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
Implemente
d 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

(LEP) as well as to the
extent possible, provide
access to adult basic
education in English
language and literacy skill
instruction for LEP
students who were
previously enrolled in a
public secondary school in
the Commonwealth.
59
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
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
Implemente
d 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
District documentation
and staff interviews
indicate that the district
has not developed a plan
for specifically how it will
assure that all teachers
who provide English
language instruction to
LEP students are
appropriately qualified.
Provide copies of all
applicable teacher licenses
and waivers.
Provide copies of
Personnel Data Sheet #7.
This information must be
provided to the Department
by September 30, 2005.

Not
Implemented
ELE 14
Licensure and
Fluency
Requirements
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Not
Implemented
ELE 15
Professional
Development
Requirements
60
District documentation
and staff interviews
indicate that the district
has not documented
specifically how it will
implement a professional
Describe the district’s
implementation plan for
ensuring high quality
training to staff in:
1) Second language
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
Implemente
d 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
development plan that
provides high quality
training for teachers to
ensure the progress of
LEP students in
developing oral
comprehension, speaking,
reading and writing of
English and in meeting
academic standards and
curriculum frameworks.
learning and
teaching;
2) Sheltering content
instruction;
3) Assessment of
speaking and
listening and;
4) Teaching reading
and writing to
limited English
proficient students.
Provide this information to
the Department by
September 30, 2005.

See also ELE 5.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
61
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
Implemente
d or
Additional
Issues
Identified

62
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
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

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
Not
Implemented
District documentation
and staff interviews
indicate that the district
has not documented
specifically how it will
ensure that LEP students
are provided facilities,
materials and services
comparable to those
provided to the overall
student population.
The district must describe
how it will ensure that LEP
students have access to
equitable facilities by
September 30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Not
Implemented
District documentation
and staff interviews
indicate that the district
has not documented an
annual report to the
Department of all required
information pertaining to
the implementation of
ELE programs.
The district must develop a
plan to provide the
Department with required
data and develop a
proposal for evaluating the
effectiveness of its ELE
programs by September
30, 2005.

ELE 16
Equitable
Facilities
ELE 17
DOE Data
Submission
Requirements and
Program
Evaluation
Corrective
Action Plan
Determined
to be Not
Fully
Implemente
d or
Additional
Issues
Identified
The district does report on
its MCAS and SIMS data
however, these reports are
not in the context of the
provision of ELE services.
Standard for meeting
63
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
Implemente
d 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

compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.
Not
Implemented
ELE 18
Records of LEP
Students
64
District documentation
and staff interviews
indicate that the district
has not documented a plan
for maintaining
cumulative records of
English Language
Learners to include all
documents required under
603 CMR 23.05, 23.07;
and M.G.L. c 69, § 1I;
Title VI
The district must develop
procedures for appropriate
maintenance of
information regarding LEP
students in student records
by September 30, 2005.
Standard for meeting
compliance with this
criterion will be subject
to on-site review by the
Department during the
’05-’06 SY.