Massachusetts Department of Elementary and Secondary Education 350 Main Street, Malden, Massachusetts 02148-5023 3700 Telephone: (781) 338TTY: N.E.T. Relay 1-800-439-2370 July 2, 2008 Bradford L. Jackson Superintendent of Schools Holliston Public Schools 370 Hollis Street Holliston, MA 01746 Re: Mid-cycle Report Dear Superintendent Jackson: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report. This report contains findings based on onsite monitoring the Department conducted to determine the effectiveness of corrective action it approved or ordered to address noncompliance identified in your district’s last Coordinated Program Review Report, dated August 22, 2005. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. While the Department of Elementary and Secondary Education found your district to have resolved certain noncompliance issues, others were partially corrected or not addressed at all, or the Department’s onsite team identified new issues of noncompliance, including but not limited to noncompliance with special education criteria added or substantially changed in response to IDEA 2004. Where the district has failed to implement its Coordinated Program Review Corrective Action Plan, the Department views these findings to be serious. The Office of Special Education Programs of the U.S. Department of Elementary and Secondary Education requires that all special education noncompliance be corrected as soon as possible, but in no case later than one year from the time of identification; where the district has failed to implement its CPR Corrective Action Plan, this one-year period has long since passed. In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that must be implemented without delay. (In the case of new findings of noncompliance, this corrective action must be corrected as soon as possible, but in no case later than a year from the date of this report.) You will find these requirements for corrective action included in the enclosed report, along with requirements for progress reporting. Please provide the Department with your written assurance that all of the Department's requirements for corrective action will be 1 implemented by your district within the timelines specified in the report. You must submit your statement of assurance to me by July 14, 2008. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 781338-3722. Sincerely, Susan D. Nichols, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Lisa Galeaz, School Committee Chairperson Marla Colarusso, District Program Review Follow-up Coordinator Encl.: Mid-cycle Report 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT Holliston Public School District Date of Coordinated Program Review (CPR) Final Report: August 22, 2005 Date Coordinated Program Review Corrective Action Approved or Ordered: November 7, 2005 Dates of Corrective Action Plan Progress Reports: 2/3/06, 5/10/06, 10/30/06, 2/2/07 Dates of this Mid-cycle Review Onsite Visit: April 29-30, 2008 Date of this Report: July 2, 2008 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Special Education Criteria Cited in CPR Report and Monitored in Mid-cycle Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 2 Required and optional assessments Record Review Interviews Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance A review of student records and interviews indicated that assessments are comprehensive and individualized, and evaluation consent forms identify the areas of suspected disability. Evaluations are Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 1 of 18 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting A review of student records indicated that the proposed IEP and proposed placement are not always sent to parents within required timelines. Develop an internal oversight and tracking system to ensure that the district provides parents with a copy of the proposed IEP and placement immediately following its development. conducted within appropriate timeframes and educational Assessments Part A and Part B are consistently completed. SE 18B Placement/ Provision of IEP Partial Record Review Interviews A review of the student records and interviews indicated that Teams are determining appropriate placements to deliver services on students’ IEPs. Partial Submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight. Submit this information to the Department by October 1, 2008. Conduct an internal review and submit the following information to Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 2 of 18 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting the Department: The number of records reviewed; The number of records found to be in compliance with providing a copy of the proposed IEP and placement to parents immediately; Corrective action taken if any noncompliance was found. Submit this information to the Department by January 15, 2009. SE 20 Least restrictive program SE 25 Parental consent Record Review Interviews Partial Record Review Interviews IEP Teams at the high school are appropriately selecting and providing services in the least restrictive environment for students. A review of the documentation and interviews indicated that the district is not implementing special education services without prior written parental Partial These efforts, which may include letters, written notices, telephone calls, email correspondence, etc. were not evident in the Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 3 of 18 Develop and disseminate internal procedures for staff to follow to ensure parental consent and/or participation, as required. Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective acceptance of the IEP. Staff interviews indicated that when the participation or consent of the parent is required and the parent fails or refuses to participate or provide consent, attempts to secure consent are implemented through multiple attempts. Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting student records reviewed where participation or consent was not evident. Submit these procedures to the Department by October 1, 2008. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 4 of 18 Conduct an internal review and submit the following information to the Department: The number of records reviewed where parents did not provide consent or participate, as required; The number of records that document other methods used to ensure parent participation or consent; Corrective action taken if any noncompliance was found. Submit this information to the Department by January 15, 2009. Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 29 Communications are in English and primary language of home Partial Record Review Interviews A review of the documentation and interviews indicated that the district has provided interpreters at IEP meetings. Documentation also indicated that procedural safeguards and some IEPs have been translated. Corrective Action Not Implemented or Not Effective or New Issues Identified Partial Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Student records and interviews indicated that progress reports are not translated for parents whose primary language is not English. Develop procedures for ensuring that progress reports are provided in both English and the primary language of the home if such language is other than English. Ensure that these procedures are disseminated and reviewed with key personnel, such as Team chairpersons. Provide a description of these procedures and evidence of the dissemination and review of these procedures with key personnel by October 1, 2008. Submit the results of an internal monitoring report from the period of October to December, 2008, for evidence that communications are Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 5 of 18 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting made in the primary language of the home when other than English. Indicate the number of records reviewed, the rate of compliance and any additional steps taken if non-compliance is found. Submit this information to the Department by January 15, 2009. SE 34 Continuum of alternative services and placements SE 37 Procedures for approved and Documentation Record Review Interviews Documentation Record Review A review of the documentation, interviews and student records indicated that the district is providing vocational education opportunities and experiences for students on IEPs through the Bridges Program, the district’s school to career internship program and vocational high schools. Record review, documentation, and interviews indicated that the school district is monitoring the provision of Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 6 of 18 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective unapproved out-of-district placements Interviews SE 41 Age span requirements SE 43 Behavioral interventions SE 47 Procedural requirements applied to students not yet determined to be eligible for Documentation Interviews Record Review Interviews Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Student handbooks do not include information regarding protections for students who are not yet determined eligible, where the district knew or should have known that the Submit a copy of the procedural requirements applied to students not yet determined to be eligible for special education that has been included in the 2008- services and programs of students in out-of-district placements. Documentation and interviews indicated that the ages of the youngest and oldest child in the instructional groupings do not differ by more than 48 months. A review of student records and interviews indicated that the district, and in particular the high school, includes behavioral interventions in IEPs if students’ behaviors impede their learning or the learning of others. Teams also consider the need for functional behavioral assessments. Documentation Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 7 of 18 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective special education Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting student was a student with a disability. The district did not provide verification that this information is provided to parents and students. 2009 student handbooks. Please provide evidence that these procedures have been reviewed with key district personnel responsible for their implementation. Submit this information by October 1, 2008. SE 54 Professional development SE 56 Special education programs and services are evaluated Documentation Interviews Documentation Interviews A review of the documentation and interviews indicated that all teaching staff are receiving training regarding state and federal special education requirements and related local special education policies and procedures. A review of the documentation and interviews indicated that the district has conducted a recent evaluation of its special education programs and services. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 8 of 18 Special Education Criteria Created or Revised in Response to IDEA-2004 Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number and Topic Criterion Implemented SE 3 Special requirements for determination of specific learning disability SE 6 ##1 - 3 Determination of Transition Services Method(s) of Verification Record Review Interviews Record Review Documentation Interviews Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented A review of student records and interviews indicated that the district has procedures for and is appropriately making determinations of specific learning disabilities. In addition, the district is aware of the new forms for determining specific learning disabilities, which will be required next year. A review of the documentation, student records and interviews indicated that IEP Teams are discussing the student’s transition needs annually beginning no later than when the student is 15 years old and documenting the discussion on the Transition Planning Form. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 9 of 18 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic SE 8 IEP Team composition and attendance Criterion Implemented Method(s) of Verification Record Review Documentation Interviews SE 12 Frequency of re-evaluation SE 13 Progress Reports and content Record Review Interviews Documentation Interviews Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented IEP Teams also review the Transition Planning Form annually and update information on the form and the IEP, as appropriate. A review of student records and interviews indicated that IEP Teams include the required members. The district is aware of the responsibility for having parental agreement for a Team member to be excused, and that this excusal shall be in writing. The district also provided samples of written excusals. A review of the student records and interviews indicated that re-evaluations are conducted in a timely manner and as appropriate, including before finding a student no longer eligible for special education. A review of the documentation and interviews indicated that the district follows appropriate procedures for writing Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 10 of 18 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented progress reports and providing progress reports to parents. For students whose eligibility terminates due to graduation or exceeding the age of eligibility, the district follows appropriate procedures for providing a summary of academic achievement and functional performance. SE 14 Review and revision of IEPs Record Review Documentation Interviews SE 25B Resolution of disputes Record Review Documentation Interviews A review of student records, documentation and interviews indicated that IEP Teams are reviewing IEPs at least annually and IEPs are revised appropriately through amendments. A review of student records, documentation and interviews indicated that within 15 days of receiving notice that a parent has made an official hearing request to the Bureau of Special Education Appeals, the district convenes a meeting with the parent and the relevant members of the IEP Team, including a Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 11 of 18 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented representative of the district with decision-making authority, to try to resolve the dispute. SE 33 Involvement in the General Curriculum Record Review Documentation Interviews SE 39A Procedures for services to eligible private school students whose parents reside in the district Documentation Interviews A review of the student records, documentation and interviews indicated that district personnel understand the rights of students with disabilities to be full participants in the general curriculum. Teams are documenting in the IEPs participation in the general curriculum. A review of the documentation and interviews indicated that the district is meeting the requirements regarding the provision of services to eligible students enrolled in private schools at private expense. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 12 of 18 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Documentation There are currently no private schools in the district. Procedures are in place consistent with the requirements of this criterion. SE 46 Procedures for suspension of students with disabilities more than 10 days SE 52 Appropriate certifications/ licenses or other credentials – related service providers (to be reviewed Not applicable Interviews Documentation Record Review Interviews Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented A review of the student records, documentation and interviews indicated that the district has appropriate procedures for the suspension of students with disabilities when students are suspended for more than ten days. The district currently has no providers of interpreting services. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 13 of 18 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting only with respect to providers of interpreting services) Criteria from Other Regulated Programs Monitored During this Mid-cycle Review Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements ELE 11 Equal access to academic programs and services Partial Documentation A review of the documentation and interviews indicated that the district is not segregating limited English proficient (LEP) students from nonEnglish speaking peers, except when programmatically necessary to implement an English Partial Classroom teachers are not sufficiently trained in sheltered English immersion. The school district’s training plan indicates that some, but not all, teachers have been trained in Sheltered English Instruction (SEI). The district must continue to provide SEI training in all four categories to teachers who have LEP students in the classrooms. Provide the district’s plan for the 20082009 school year for implementing professional development that provides teachers with training in Interviews Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 14 of 18 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified learner education program. The district is providing access to a full range of academic opportunities and supports afforded non-LEP students, such as special education services, Section 504 Accommodation Plans and Title I services. The district is addressing the need for LEP students to have the opportunity to receive support services, such as guidance and counseling, in a language that the student understands. CR 7 Information to be translated into languages other than English Partial Documentation Interviews Documentation and interviews indicated that some information has been translated into major languages other than English for parents or guardians with limited English language skills. Partial Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements As the district does not have all staff with ELE students trained in SEI, students are not taught to the same academic standards and provided the same opportunities to master such standards as their English-speaking peers. sheltering content instruction. Notices are not consistently provided to limited English proficient (LEP) students in a language and mode of communication that they understand. Not all important information and documentation, specifically handbooks and codes of conduct, are translated into the major languages spoken by parents or guardians with limited English skills. The district does not have a district-wide procedure Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 15 of 18 Submit a plan that addresses how information will be provided to LEP students in a language or mode of communication that they understand. Submit the above information to the Department by October 1, 2008. Submit a description of the means by which the district will notify parents that documents and information may be translated for parents or guardians with limited English language skills by October 1, 2008. Provide copies of information and documents published in Criterion Number/Topic CR 7A School year schedules Approved Corrective Action Implemented and Effective Method(s) of Verification Documentation Interviews CR 7B Structured learning time Documentation Interviews CR 14 Counseling and counseling material free from bias and stereotypes CR 17A Documentation Interviews Partial Documentation Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements for informing parents that they may receive information translated into languages other than English. English and in translation. A review of the Submit the agendas and staff Submit this information to the Department by January 15, 2009. A review of the documentation and interviews indicated that Holliston High School meets the required 990 hours of structured learning time. A review of the documentation and interviews indicated that the district is in compliance with structured learning time regulations. The school district’s documentation included a statement of assurance that limited English proficient students have the opportunity to receive counseling in their primary language and that school principals or their designees are responsible for arranging this. A review of the Partial Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 16 of 18 Criterion Number/Topic Approved Corrective Action Implemented and Effective Use of physical restraint Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified documentation and interviews indicated that the district is providing information to staff regarding the use of restraint. Interviews Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements documentation and interviews indicated that the district is not consistently providing training on physical restraint during the first month of school, and it is not clear if all staff at all buildings participate in the training. attendance sheets for physical restraint training provided within the first month of school at each building. Interviews indicated that staff are not clear on the procedures to follow or who to contact regarding appropriate responses to student behavior that may require immediate intervention. CR 21 Staff training regarding civil rights responsibilities Documentation Interviews A review of the documentation and interviews indicated that the district has provided staff with training regarding civil rights responsibilities. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 17 of 18 Submit this information to the Department by October 1, 2008. Criterion Number/Topic CR 25 Institutional self-evaluation Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Documentation Interviews Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements A review of the documentation included a statement of assurance that the superintendent has conducted interviews with staff and has reviewed district-wide compliance in this area, but no documentation that describes any evaluations, conclusions reached or any resolution of any identifies issues was submitted. The district must annually evaluate all aspects of its K-12 program to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities. Conduct and submit an institutional self-evaluation, as required in accordance with this criterion. Holliston Public School District Coordinated Program Review Mid-cycle Report July 2, 2008 Page 18 of 18 Submit this information to the Department by January 15, 2009.