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
January 31, 2006
Rosemary Joseph
Superintendent
Harwich Public Schools
81 Oak Street
Harwich, MA 02645
Re:
Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective
Action Plan Verification and Special Education Mid-cycle Review
Dear Superintendent Joseph:
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 November 7, 2001.
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
February 12, 2006
Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated. Should
you require additional clarification of information included in our report, please do not hesitate to
contact the Onsite Team Chairperson at 781-338-3755.
Sincerely,
Michelle Griffin, 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
Mr. M. Russell, School Committee Chairperson
Peter Bertucci, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
Harwich Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on December 31, 2001
Progress Reports Submitted on May 28, 2002
Onsite Visit Conducted on June 1 and 2, 2005; documentation submitted January 2005 and July 27, 2005
Date of this Report, January 31, 2006
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


Special
Education
Requirements
SE 3
Special
requirements for
determination of
specific learning
disabilities
Partial
Student
Record
Review
The district does make use of a
form in order to document the
Team’s finding of specific
learning disability (herein SLD
form).
Partial
Student record review
revealed that SLD forms
were not always fully
completed by the district.
In light of the reauthorization
of IDEA 2004, as described in
the previous column, for
districts seeking to resolve a
previous finding in this area,
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
However, statutory
requirements for the
determination of specific
learning disabilities have
been revised under the
recently reauthorized
IDEA 2004.
the Department will extend the
date required for final actions
on the part of the school district
to June 2006 and will consider
resolution at any time following
promulgation of final federal
regulations.


Corrective action will be
ordered by the Department at a
future date, with progress
reports due June 30, 2006.
2
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


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
√
Student
record
review
Interviews
Documentation
Record review indicates that
students 14 and over and do
participate in team meetings,
and that the district secures the
participation of outside agencies
in these activities.
While at times, the age of
majority discussion is held at the
team meeting at least one year
prior to the student’s 18th
birthday, in one instance, this
was not done. The Department
encourages the district to review
this requirement with staff at the
high school.
The Vocational Community
Program at the High School uses
a Transition folder, which
3
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


has much promise for assisting
families and students in
preparing for the transition to
adulthood/independence for the
students in this program.
Interviews indicate that students
are invited to Team meetings,
are asked for their input into
IEPs, that, where appropriate,
the Team considers appropriate
IEP goals, services and reevaluations to assist with postsecondary transition preparation.
Interviews further indicate that
the district is connected with
state agencies, including DSS,
DMR, Mass. Rehab.
Commission, DMH, and the
community college. These
connections assist in the
provision of transition services.
4
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Interviews also indicate that
Chapter 688 referrals are made,
and that age of majority letters
are sent to parents and students.
The district submitted under this
criterion a copy of a flyer
advertising a “Chapter
766/Section 504/pre-school
Informational Workshop, held
in the spring of 2004 and the
spring of 2005. The district
also submitted a copy of a page,
which includes a synopsis of
laws, including Title VI, Title
IX, Section 504, the Americans
with Disabilities Act, the Equal
Educational Opportunities Act
of 1974, Mass. General Laws
Ch. 76, sec. 5, and Chapter 688.
According to interviews, this
document is posted in all
5
teachers’ rooms in the district.
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


SE 13
Progress Reports
and content
Partial
Student
Record
Review
In some student records,
progress reports were
appropriately completed;
however, this was not always the
case.
Interviews
The district submitted a copy of
a form entitled “Annual Review
or Re-evaluation IEP Data.”
According to interviews, this
form is used by liaisons with
every progress report. Forms are
sent to the parent as well as the
Director of Pupil Personnel and
Special Education Services.
Data forms state that they are
used as one component of many
to evaluate programs, not
students and staff. According to
interviews, the Director of Pupil
Personnel and
6
Partial
Student records indicated
that progress reports were
inconsistently completed
appropriately.
Specifically, in one
instance, reports on one
goal were not found for
some progress report time
periods; in one instance,
progress reports were not
found for one marking
period; in one instance,
progress reports did not
report on the goals; and in
one instance, progress
reports were general and
did not reflect percentages
as was set forth in the
goal.
Please ensure that all staff
members that complete
progress reports receive
training on the appropriate
completion of progress reports
pursuant to this criterion.
Please ensure that training
addresses content and
frequency of progress reports.
Please provide the Department
with agenda, attendance sheets,
and training materials for this
training by March 31, 2006.
Please provide the Department
with a random sample of the
IEP goal pages and the last two
quarters’ progress reports for 3
students at each level. Please
provide this documentation by
July 15, 2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Special Education Services then
reviews some of these forms,
and trouble-shoots goal issues.
Interviews indicate that IEP
Teams are reconvened when
appropriate if progress reports
reflect a lack of student success.
7
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Interviews
√
SE 15
Outreach by the
School District
(Child Find)
Documentation
Interviews indicate that the
district has pre-referral teams in
all schools. In addition,
interviews indicate that the
district has close links with
community agencies, private
programs, therapists and
psychiatrists, with DSS and
DYS, with the town youth
counselor, the police and a local
youth minister, and that
periodically, interagency
meetings are held at the district.
Interviews indicate that all of
these connections aid in the
effort to identify all students
with disabilities. Interviews
further indicate that outreach
letters are mailed three times
yearly to private schools in the
8
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


area (including border towns) in
order to assist in identifying
students with disabilities.
Evaluations of private school
students were noted in
interviews.
The district submitted a copy of
a letter to the Director of Pupil
Personnel and Special Education
Services from Cape Cod Child
Development dated October 28,
2004, enclosing a list of children
in the district who would be
turning three in the next twelve
months.
The district also submitted under
this criterion a copy of a flyer
advertising a “Chapter
766/Section 504/pre-school
9
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Informational Workshop”, held
in the spring of 2004 and the
spring of 2005.
The district submitted a copy of
a press release concerning
screening of three and four year
olds that was sent to the Cape
Cod Times, the local access
cable channel, and the Cape Cod
Publishing Company, in October
2003.
The district sent a copy of a
letter sent in January 2004 to
private schools, attempting to
identify children with
disabilities.
10
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


See SE 15 above.
SE 17
Initiation of
services at age
three and Early
Intervention
transition
procedures
√
Interviews
Documentati
on
Student
record
review
Interviews indicate that IEP
services consistently begin by a
student’s third birthday.
Student record review indicated
substantial compliance with this
criterion. However, due to
inappropriate use of extended
evaluation, in one instance, a
student’s IEP services did not
begin at age 3. See finding
under SE 19.
11
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Although student record
review indicates that IEPs
are generally well
developed, not all IEPs
contained measurable
goals. See also SE 20
concerning the nonparticipation justification.
Please provide training for
special education personnel
who develop IEP goals on the
completion of appropriate
annual, measurable goals.
Please provide the Department
with agenda, attendance sheets,
and training materials for this
training by March 31, 2006.


SE 18A
IEP development
and content
Partial
Interviews
Student
record
review
Interviews indicate that team
chairs have the authority to
commit the resources of the
district, in most instances.
Partial
Student record review reveals
that IEPs are generally well
developed.
Please provide the Department
with the documentation (goal
pages) requested with regard to
SE 13 above. Please provide
this documentation by July 15,
2006.
12
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Record review indicates
that in two instances, the
IEP was not provided
immediately following its
development. Interviews
indicate that the summary
form is not being used
consistently, and that
sometimes, IEPs are not
issued immediately
following their
development.
Please provide training for
special education personnel
who develop IEPs on the
immediate provision of the IEP
in the regulations. Please
provide the Department with
agenda, attendance sheets, and
training materials for this
training by March 31, 2006.


SE 18B
Determination of
placement;
immediate
provision of IEP
to parent
Partial
Student
record
review
Interviews
Interviews indicate that the
district has implemented the use
of a summary form, which is
provided to parents after the
Team meeting and which
includes current concerns,
disability, vision, goals and
objectives, and service delivery.
13
Partial
Please provide the Department
with a random sample of three
notices from each level
proposing IEPs, along with
accompanying IEPs, summary
forms and team meeting
attendance sheets, for IEPs
created after the training.
Please provide this
documentation by July 15,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 20
Least restrictive
program selected
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Student record review
indicates that the nonparticipation justifications
in IEPs do not always
focus on the reasons for
removal of students from
the general education
curriculum, and,
specifically, that they are
not always focused on the
student and the student’s
disability.
Please provide training for
special education personnel
who develop IEPs on the
requirement that if the student
is removed from the general
education classroom at any
time, the Team states why the
removal is considered critical to
the student’s program and the
basis for its conclusion that
education in a less restrictive
setting with the use of
supplementary aids and
services could not be achieved
satisfactorily. Please provide
the Department with copies of
the agenda, attendance sheets
and training materials used in
this training. Please provide
this documentation by March
31, 2006.

Interviews
Student
record
review
Interviews indicate that teams
consistently consider the least
restrictive program, and that the
Director of Pupil Personnel and
Special Education has discussed
this topic with regular and
special education staff at faculty
meetings and at monthly special
education department meetings,
in order to ensure that students
are not removed from the
general education classroom
when curriculum modification
might have been sufficient, and
that ongoing opportunities for
workshops concerning inclusion
and the least restrictive
environment are provided.
Additionally, the Director of
Pupil Personnel and Special
Education has recently
emphasized training in positive
14
behavioral interventions, in
order to assist in meeting the
Partial
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


least restrictive environment
provisions of the law. At the
time of the review, training in
differentiated instruction and
classroom training was planned
for the fall of 2006.
The district submitted copies of
Student Support Team referral
forms, and a blank SST Prereferral Classroom
Accommodation form for
documenting recommendations
from the SST.
The district submitted a
document entitled “Differences
Between Section 504 and
IDEA.”
15
Please provide the Department
with a random sample of the
IEP pages containing the nonparticipation justification for
IEPs created for three students
at each level following the
training.
Please provide this
documentation by July 15,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 22
IEP
implementation
and availability
(Emphasis on
provision of IEP
services without
delay; provision
of the IEP at the
beginning of the
school year; and,
alternative
methods of
service delivery
where there is a
lack of space
and/or
personnel))
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

√
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Student
record
review
Interviews
Interviews and student record
review indicate that the district
is appropriately implementing
the requirements of this
criterion. IEP services begin
without delay. Relevant
portions of IEPs are given to all
staff that work with individual
students at the beginning of a
school year and upon
amendment; the IEPs are made
available to appropriate staff as
well. In addition, there is a
mechanism in place for ensuring
that annual reviews and reevaluations occur in a timely
manner.
16
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


SE 26
Parent
participation in
meetings
(Emphasis on
district’s attempts
to ensure parent
participation at
IEP Team
meetings)
√
Student
record
review
Student records indicated parent
participation in all Team
meetings. Interviews indicated
compliance with this criterion.
Interviews
The district also submitted under
this criterion a copy of a flyer
advertising a “Chapter
766/Section 504/pre-school
Informational Workshop, held
in the spring of 2004 and the
spring of 2005.
Documentation
The district submitted a copy of
a flyer advertising an
Informational Parent Meeting
held on December 1, 2003 by
the Wilson Language Program
and Title I.
17
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


The district submitted a copy of
a blank sample letter to parent,
used when the district has not
secured parental consent for an
IEP, and indicating that if
consent was not received by a
date certain, the district would
be filing it with the BSEA as
rejected, and may consider
request a hearing at the BSEA
(denial of FAPE).
18
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 28
Parent provided
the IEP or notice
of no eligibility
together with
notification of
procedural
safeguards and
parents' rights
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Record review indicates
that Notices of
Proposed/Refused School
District Action
inconsistently contained
the appropriate content as
required by federal law
and regulation.
Please provide training for
special education personnel
who develop IEPs and notices
proposing or refusing to take
actions on the appropriate
completion of these notices, as
required by federal law and
regulation. Please provide this
documentation by March 31,
2006.

Student
record
review
Interviews
Documentation
Partial
The district submitted under this
criterion copies of flyers
advertising a “Chapter
766/Section 504/pre-school
Informational Workshop,” held
in the spring of 2004 and the
spring of 2005. The district
also submitted a copy of a
document entitled “Parent
Student Rights in Identification,
Evaluation and Placement,”
concerning Section 504.
19
See SE 18B regarding the
immediate provision of
IEPs in the regulations.
Please see SE 18B for
corrective action due July 15,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
SE 29
Communications
are in English and
primary language
of home
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

√
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Record review and interviews
indicate that special education
documentation is translated,
when necessary.
Interviews indicate that the
district has resources for
accessing interpreter and
translation services, when
necessary. (See also list of
documentation submitted with
criterion MOA 7.)
The district submitted a copy of
a form entitled “Interpreter
Form,” that includes a place to
indicate type of meeting, content
of information conveyed to
parent, and signature by
interpreter, chair and parent that
the content of the meeting is
understood.
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


SE 32
Parent advisory
council for special
education
√
Documentation
Interviews
The district submitted copies of
a Harwich Public Schools
“Application for Use of
Facilities,” completed for the use
of district space for PAC
meetings for the 2003-2004 and
2004-2005 school years.
Interviews indicate that the
district has a collaborative
relationship with the PAC and
that it supports the PAC
financially and with regard to
trainings. Interviews indicate
that the district will provide a
survey to parents to solicit their
input in the evaluation of special
education programs and
services.
21
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


The district submitted a copy of
an invoice for payment for a
“Homework Presentation” to the
PAC, dated 10/04. The invoice
indicates that it was paid in
January 2005.
The district submitted another
agenda from a PAC presentation
held on 2/23/04.
The district submitted a copy of
a memo from the former
Director of Pupil Personnel and
Special Education Services
(PPS) informing PPS staff of
SPED Staff meetings and PAC
meeting dates for the 2003-2004
school year.
22
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


SE 50
Responsibilities
of the School
Principal and
Administrator of
Special Education
√
Documentation
Interviews
The district submitted a Student
Accommodation Plan, with
copies of individual Curriculum
Accommodation Plans for each
of its three schools (elementary,
middle and high school).
Individual plans were dated
2001-2002.
The district also submitted a
copy of a District Curriculum
Accommodation Plan, dated
11/4/03.
Interviews indicated compliance
with this criterion. Specifically,
interviews indicated that the
curriculum accommodation
plans are in effect, and that staff
are aware of these, as well
23
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


as other options for meeting the
needs of students within regular
education (e.g., Section 504,
Wilson reading, counseling,
community volunteer tutors,
student tutors, behavioral plans,
academic monitoring forms).
Interviews indicate that district
guidance counselors at the
middle and high schools are
responsible for the identification
and evaluation of students for
504 eligibility, as well as the
preparation, implementation and
monitoring of these plans. At
the elementary school, the
assistant principal fulfills these
duties.
The district submitted an
organizational chart.
24
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


The district submitted Job
Descriptions for the Director of
Pupil Personnel, Special
Education and Title I (one role)
and for Principals.
Interviews indicate that
Principals and the Director of
Pupil Personnel and Special
Education meet at least every
other week, and have frequent
contact, sometimes as much as
daily.
The Director of Pupil Personnel
and Special Education Services
coordinates the provision of
services in the home and
hospital.
25
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Interviews indicate that training
has been provided on
accommodating the diverse
learning needs of all students.
26
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


SE 54
Professional
development
regarding special
education
√
Documentation
Interviews
See also SE 50 and SE 53.
The district submitted the
following:
 Copy of January 12,
2005 In-service agenda,
which was apparently a
middle school in-service
that included academic
subject areas as well as
special needs issues for
the upcoming MCR.
 Copy of a January 12,
2005 Agenda and signin sheets for a
Professional
Development activity
for guidance
professionals and
psychologists
27
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


on Special Education
Eligibility.
 Copy of a January 12,
2005 Harwich High
School agenda,
including special
education topics.
Interviews indicate that the
district provides additional
professional development topics
required by this criterion.
28
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 56
Special education
programs and
services are
evaluated
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Although the evaluation
dated August 18, 2003 did
thoroughly address most
areas required by this
criterion, evaluations do
not address the success of
programs based on
students’ statewide and
local assessment results,
dropout and graduation
rates for special education
students.
Please provide the Department
with a plan for addressing all
areas required by this criterion.

Interviews
Documentation
Partial
The district submitted a copy of
a 2003-2004 “IDEA Grant
Evaluation,” which was
prepared by Regis Consultants.
The district submitted a copy of
a Special Education Program
Evaluation from August 2003.
Interviews indicate that the
Director of Pupil Personnel and
Special Education reviews
MCAS results and progress
reports of students with
29
Please provide this plan by
March 31, 2006. Please
provide an update regarding
this year’s program evaluation
activities by July 15, 2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


disabilities. Additionally, at the
time of the review, a survey of
special education and general
education staff was to be
completed.
Other
Requirements
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)
SE 2
Required and
Optional
Assessments
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

√
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Student
record
review
Record review indicates that the
district provides appropriate
required and optional
assessments.
Interviews
Interviews indicate that
assessments are appropriately
selected so as to ensure that
students are evaluated in all
areas of suspected disability.
In addition, interviews indicate
that if necessary, students would
be assessed in their native
language.
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)
SE 23
Confidentiality
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

√
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Student
record
review
Student record review indicates
that all files had the required
logs of access. In addition,
computer access to records is
either closed or password
protected, and files are locked.
32
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
SE 33
Involvement in
General
Curriculum
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Because the mathematics
curriculum is not
complete, the district has
not demonstrated that it
has taken steps to provide
all students, including all
students with disabilities,
with essential learning
opportunities that prepare
the students to reach the
state graduation standards.
Specifically, a complete
mathematics curriculum
was not provided.
Please provide the Department
with a written update as to the
status of the development of the
mathematics curriculum.
Please provide documentation
supporting this update.

Student
record
review
Documentation
Interviews
Student record review indicates
that students on IEPs are
involved in the general
curriculum.
Interviews indicate that all areas
of the district’s curriculum are
aligned with the Massachusetts
curriculum frameworks, that all
content areas of the frameworks
are available to all students on
IEPs and that all students in
substantially separate classes
receive instruction that is based
on the frameworks.
Partial
The district submitted its
December 2004 District
Math Curriculum for math
courses from pre-K
through Pre-Algebra.
33
Please provide the above
update and supporting
documentation by July 15,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


The manual states that the
curriculum was developed
using the entire
Massachusetts
Curriculum Frameworks,
November 2000 and the
Supplement to the
Massachusetts Math
Curriculum Frameworks,
Grades 3, 5, and 7, May
2004. Courses in Algebra
I, Algebra II, Algebra III
with Trigonometry,
Geometry, Pre-Calculus
and Calculus had not yet
been developed as of the
December 2004
curriculum manual.
34
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
SE 36
IEP
Implementation
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Documentation submitted by
the district does not
demonstrate that each time
the school district proposes
to access the parent’s private
insurance to support the
costs of IEP implementation,
that it obtains the parent’s
consent and informs the
parents that their refusal to
permit the school district to
access their private insurance
does not relieve the district
of its responsibility to ensure
that all required services are
provided at no cost to the
parents. The Department
notes, however, that the
Director of Pupil Personnel
and Special Education
indicates that the district has
not accessed parents’ private
insurance since he began in
his position.
Please provide the Department
with documentation that the
district meets the requirements
of this criterion.

Documentation
Interviews
Interviews indicate that the
district implements the
requirements of this criterion.
See also SE 22.
The district submitted the
following documentation:
 A copy of a blank form
used to document
parental permission to
share information with
the Massachusetts
Medical Assistance
Division for accessing
Medicaid regarding
children’s special
education services for
the purpose of obtaining
35
Partial
Please provide this
documentation by March 31,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


federal reimbursement
for the cost of those
services from the
Medicaid program.

A copy of Notice to
Parents Regarding
Municipal Medicaid
Reimbursement.
36
The district
is reminded to review all of
the requirements in the use
of public or private
insurance
covered in 34 CFR
300.142(e) - (i) and may
wish to include additional
elements of
informed consent in order to
encourage the use of these
benefits.
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
SE 52
Certification/
Licensure
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Some related services
providers have state
professional licenses, but
do not have Department of
Education certification.
Please provide the Department
with a complete list of
providers of special education
and related services staff ,
including indication of whether
these individuals have
appropriate educator licensure.
To the extent any individuals
do not have appropriate
educator certification, please
provide a plan for addressing
this issue.
Please provide this
documentation by March 31,
2006.

Documentation
The district submitted copies of
state licenses and DOE
certifications for related service
providers.
The district also provided
information concerning the
credentials of consultants and
evaluators.
37
Partial
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Interviews
SE 53
Paraprofessionals
√
Documentation
Interviews and documentation
indicate that appropriate training
is provided for
paraprofessionals. Interviews
indicate that special education
teachers design the instruction
for students with disabilities that
is provided by paraprofessionals,
and that the paraprofessionals
are supervised by the teacher
and the Director of Pupil
Personnel and Special
Education.
The district submitted the
following documentation:
 Copy of an agenda for a
workshop held in May
2002. Agenda is
38
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified





entitled “Developmental
Learning Assistants.”
Copies of agendas and
sign in sheets from
trainings held in the
2003-2004 school year.
Copies of an agenda and
sign-in sheets dated
3/12/02, which was for
a half day in-service for
paraprofessionals.
Copy of a Memo to
Holy Trinity School
from the former
Director of PPS inviting
staff from that school to
a workshop being held
for middle school
assistants in May 2002.
39
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
(Formerly
MOA 2)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The middle school student
handbook has only a
general statement that it
does not discriminate in
any educational program
or activity. The
elementary school
handbook contains a nondiscrimination statement,
however, the statement
lacks the category of
“color.”
The district must review all
handbooks for compliance with
applicable requirements found
in the Department of
Education’s Civil Rights and
Special Education instruments,
specifically, with criteria MOA
10A, 11A and 12A and SE 44,
45, 46, and 47. Please provide
the Department with the results
of this review, as well as copies
of the most recent district
handbooks and any proposed
revisions to the handbooks.

Interviews
MOA 12A
Publication of
Notices of Nondiscrimination
Comments Regarding
Corrective Action Plan
Implementation
Documentation
The district submitted the
following documentation:
 Copies of postings for a
school nurse (11/19/04),
and a Long-term
Substitute Sped
Assistant and ELL
Tutor (both dated
4/14/05), which contain
the following statement:
“Equal Opportunity
Employer/Affirmative
Action.”
 Copies of applications
for employment that
includes a statement
40
Partial
The district submitted a
copy of the 2004-2005
Middle School Parent
Handbook, which contains
the same general
statement as the student
handbook.
Please ensure that parents and
students are notified of any
amendments required to the
2005-2006 handbooks.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


that the district is an Equal
Opportunity Employer.
The district submitted student
handbooks from the middle and
high schools, as well as the
family handbook from the
elementary school and a parent
handbook for the middle school.
The high school handbook
contains an appropriate nondiscrimination statement, which
references all classes as required
by law.
See also MOA 11A and MOA
10A.
41
Please provide all of the above
documentation, including
evidence of how students and
parents were notified of any
amendments required to the
2005-2006 handbooks by
March 31, 2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


√
MOA 7
General
information and
materials in
language other
than English
(Formerly
MOA 3)
The district submitted the
following documentation:
 A copy of a contract
between the district and
an individual for
document translation
services from Spanish
to English, ending June
2005.
 Copies of invoices for
interpreter services,
paid in October and
December 2004.
 A copy of a fax cover
sheet used to request
interpreter services
from the Visiting Nurse
Association of Cape
Cod.
42
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified




A copy of an English
and Spanish versions of
an elementary school
Principal’s Newsletter
from February 2004
and accompanying
“Translation Time
Sheet.”
A copy of district
“Translation
Procedures,” listing
various resources for
interpreter and
translation services.
The district is cautioned
that when it uses
“community
volunteers,” it ensure
that these individuals
43
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


are appropriately
trained in the subject
matter of the service
(e.g., special
education), and that the
district is cognizant of
confidentiality laws and
regulations.
Interviews indicate that general
announcements, and notices of
extracurricular activities and
other opportunities are translated
for families with limited English
skills, when necessary.
See also SE 29.
44
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The elementary school
handbook lacks grievance
procedures other than a
statement that “complaints
alleging discrimination shall
be made to the appropriate
compliance coordinator, or
shall be referred to the
coordinator if received by
other persons within the
institution.”
See MOA 12A (formerly MOA
2) above for corrective action.

MOA 11A
Documentation
Grievance
Procedures
Interviews
(Formerly MOA
6)
Comments Regarding
Corrective Action Plan
Implementation
The district submitted a copy of a
page that includes a synopsis of
laws, including Title VI, Title IX,
Section 504, the Americans with
Disabilities Act, the Equal
Educational Opportunities Act of
1974, Mass. General Laws Ch. 76,
sec. 5, and Chapter 688. The
coordinators/liaisons and grievance
procedures are not, however,
indicated on this form. According
to interviews, this document is
posted in all teachers’ lounges.
The district submitted a copy of
“504/ADA grievance Procedure,”
which contains procedures for
handling 504 or ADA complaints,
and states that it is intended to meet
the requirements of the ADA. This
does identify the former Pupil
Personnel Services director as the
coordinator. It is not clear how
this document is distributed to 45
members of the school community.
Partial
The high school student and
parent handbook does
contain grievance procedures
for allegations of
harassment, but not
discrimination. The
“504/ADA grievance
Procedure” unnecessarily
limits the persons who can
complain, in that it excludes
students (parents/guardians
are required to file), and the
procedure does not meet
requirements of this
criterion.
The district should also ensure
that it has designated one or
more staff persons to serve as
liaison for homeless students,
carrying out the duties
described in NCLB: Title X,
Part C, Sec. 722(g)(6).
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


The district submitted copies of
the handbooks for the
elementary, middle and high
schools.
The elementary school
handbook identifies the
compliance coordinators for
complaints alleging
discrimination, and includes
contact information for the
coordinator of civil rights and
equal educational opportunities,
and the coordinator for Title IX.
46
The middle school
handbook lacks grievance
procedures other than
statements that
“complaints
alleging discrimination
shall be made to the
appropriate compliance
coordinator, or shall be
referred to the coordinator
if received by other
persons within the
institution,” and a
statement that “[I]f you
believe you or someone
you know has been a
victim of harassment, or
you have a question about
this issue, seek the help of
an adult whom you trust,
such as a teacher,
counselor,
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


The middle school parent and
student handbooks contain
contact information for the
coordinator for Title IX.
The high school student
handbook contains the names
and contact information for the
civil rights and equal
educational coordinator and the
Title IX coordinator.
47
administrator, your parent
or guardian. Please note a
grievance procedure,
through the Assistant
Principal, is available to
students in the event the
harassment issue is not
resolved.”
The middle school parent
and student handbooks
contain an address for, as
civil rights and equal
educational opportunities
coordinator, but do not
name an individual.
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


√
MOA 22
Accessibility of
district programs
and services for
students with
limited physical
mobility
Documentation
Building tour
The issue identified in the
Coordinated Program Review, at
the elementary school, has been
remedied, per prior progress
report and building tour.
(Formerly
MOA 7)
48
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


√
Interviews
MOA 14
Counseling
materials and
activities free
from bias and
stereotypes
(Formerly MOA
9)
Documentation
The district submitted a
statement from the Director of
Pupil Personnel Services
/Special Education that states
that the district provides
counseling materials and
services in an unbiased manner,
and that this objective is met by
reviewing the materials for
indicators of biased content or
implication by the guidance and
adjustment counselors. The
statement further notes that the
objective is further met by
reading the technical manuals
and reviewing normative
sampling information that
follows population parameters,
and that counseling materials
and manuals are viewed prior to
purchase for general usage, and
49
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


materials not meeting nonbiased standards are not used by
the district. Finally, the
statement indicates that if
materials in use indicate bias at
any point, their use is
discontinued.
Interviews indicate that
counseling and testing materials
are reviewed for bias when
purchased. In addition,
interviews indicate that if
necessary for an individual
student, counseling would be
provided in the student’s native
language, or, for example, in
sign language.
50
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Interviews indicate that students
are supported and encouraged in
education programs that are nontraditional for their gender.
51
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The district recognizes
continuing issues with
regard to the overidentification of male
students in special
education programs. See
also MOA 25.
Please provide the Department
with a self-assessment of
whether there exists an overidentification of male students
and/or an under-identification
of female students in special
education. If these placement
patterns are not consistent with
general population trends, the
district must be able to
demonstrate that such
placements have been made for
educationally relevant reasons.
(See Appendix I of the Civil
Rights Instrument for
guidance.)


√
Interviews
MOA 4
Placement of
linguistic, racial
minority and
female/male
students
(Formerly MOA
11)
Please provide this information
by July 15, 2006.
52
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
MOA 25
Institutional selfevaluation
(Formerly
MOA 23 )
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Interviews indicate that a
formal institutional selfevaluation is not occurring
consistently.
Please provide the Department
the district’s plan for
completing the institutional
evaluation by March 31,
2006.

Interviews
Documentation
Interviews indicate that topics
related to discrimination
/limitation of educational access
in the district’s programs and
policies often come up and are
addressed, and that the district is
very cognizant of subcategories,
and issues related to overidentification.
The district submitted a copy of
the Corrective Action Plan grant
application from 2002,
indicating that some funds
would be used for a Special
Education program evaluation
(in response to the finding from
the most recent CPR with regard
to SE 56, and the failure of the
district to have a
53
Partial
Please provide the Department
with a completed institutional
self-evaluation by July 15,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


comprehensive procedure in
place for the evaluation of all
special education programs and
services.)
The district submitted a copy of
a Special Education Program
Evaluation. See also SE 56.
54
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Interviews
MOA 16
Notice to students
who have left or
are about to leave
school without a
high school
diploma
Comments Regarding
Corrective Action Plan
Implementation
Documentation
Interviews indicate that the
district is following these
procedures.
Partial
The district submitted a
“Withdrawal Form” for students
who plan to leave school
without a high school diploma.
(Formerly MOA
24)
55
The form submitted does
not meet all requirements
of this criterion.
Specifically, it does not
inform students/parents of
the right to meet with a
representative of the
district. In addition, it
does not appear that this is
the form used if a student
has been absent fifteen
consecutive days, rather, it
seems to be used when
someone voluntarily
withdraws. The district
should ensure that the
form is used consistently
within ten days from a
student’s fifteenth
consecutive absence.
Please update the form so that
it is consistent with the
requirements of this criterion.
Please provide appropriate high
school and middle school staff
members with training on this
procedure and the appropriate
use of the notice required by
this criterion. March 31, 2006
Please provide documentation
of the training, including
agenda, training materials,
revised form and attendance
sheets. Please provide the
Department with this
documentation by March 31,
2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


Please provide the Department
with three sample notices sent
to students and parents
pursuant to this criterion, sent
after the previously mentioned
training. Please submit this
documentation by July 15,
2006.
ADDITIONAL
CRITERIA
IDENTIFIED
BY THE MIDCYCLE
REVIEW
TEAM
56
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
SE 19
Extended
Evaluation
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Interviews
Student
Record
Review
Interviews indicate that the
district is aware of the
appropriate use of the Extended
Evaluation.
57
Partial
Student record review
indicates that the
Extended Evaluation is
not being used
appropriately. In addition,
the district is using an
outdated Department form
for completion of
Extended Evaluations.
Please provide training to
district chairpersons on the
appropriate completion of
Extended Evaluations. Please
provide the Department with
the agenda, attendance sheets
and materials used in this
training. Please provide the
above documentation by
March 31, 2006.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
MOA 10A
Student
Handbooks and
Codes of Conduct
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The high school handbook
contains potential
consequences for students
who harass, but not for
students who discriminate.
See MOA 12A (formerly MOA
2) above for corrective action.

Documentation
The high school handbook,
middle school student and
parent handbooks, and
elementary school handbooks
lack specific disciplinary
procedures for disabled students,
pursuant to this criterion.
58
Partial
Procedures in other
handbooks do not contain
the disciplinary measures
that the school may
impose if it determines
that harassment or
discrimination had
occurred.
Criterion
Number
and
Topic
(Refer to full text
of requirements
in 2004-2005
Special
Education
Information
Package)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


The high school handbook
contains an appropriate nondiscrimination statement, which
references all categories required
by law.
The middle school parent
and student handbooks
contain provisions that are
similar to M.G.L. ch. 71
section 37H and 37H ½,
however, the language is
condensed in such a way
that the due process
protections and
procedures under these
statutes are unclear or
incorrect.
The middle school student
handbook has only a
general statement that it
does not discriminate in
any educational
59
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)
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


program or activity.
See MOA 12A concerning the
procedures for accepting,
investigating and resolving
complaints alleging
discrimination or harassment.
60
The elementary school
handbook contains a nondiscrimination statement
that does not include the
category of color.
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)
MOA 17A
Implementa
-tion Status
of
Requiremen
ts
or
Corrective
Action Plan
Determined
to be
Substantially
Implemente
d

Partial
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Documentation
Interviews
Interviews indicate that the
district has in place procedures
for physical restraint, found in
the “black book” in every
school, and that these
procedures needed to be
updated. In addition, interviews
indicate that there is annual
training on restraint provided to
all staff.
61
The district submitted a
restraint policy that had
not yet been approved by
the school committee.
Interviews and
documentation indicate
that it is not clear how the
district informs parents of
the district’s restraint
policies.
Please provide documentation of
the revised school committee
policy. Please provide this by
March 31, 2006.
Please provide written assurance
that the district will provide all
district staff with training on the
new policies and procedures
within the first month of the
school year, and, for new
employees, within one month of
the date of employment. Please
clarify how the district will inform
parents of the restraint policies.
Please provide this documentation
by July 15, 2006.